New Audit Law: statutory audit mandatory for medium-sized entities too
TLDR
- Published in Official Gazette 84/2025 (31 July 2025), in force since 8 Aug 2025 — same package as the new Accounting Law.
- Statutory audit mandatory for: public-interest entities, medium-sized legal entities, parents of medium/large groups, investment firms and funds (Art. 35).
- Micro/small/medium/large classification follows the thresholds of the new Accounting Law.
- Mandatory rotation: the signing auditor / key audit partner must change at least every seventh year.
- Auditors and audit firms require licensing and mandatory professional-liability insurance.
Alongside the new Accounting Law, the same Official Gazette issue (84/2025) published a new Audit Law. Both have been in force since 8 August 2025 and together form Montenegro's new accounting-and-audit framework.
The key practical consequence for companies: statutory audit of annual financial statements is mandatory not only for large entities and public-interest entities, but also for medium-sized legal entities, and for parent companies whose groups (together with subsidiaries) qualify as medium or large (Art. 35).
Classification follows the new Accounting Law's thresholds: a medium entity exceeds the small-entity limits (50 employees / €10M revenue / €5M assets) but stays within the large-entity limits (250 employees / €50M revenue / €25M assets) — as a rule on two of three criteria.
The law also mandates rotation of the signing auditor / key audit partner at least every seventh year with the same client, compulsory professional-liability insurance, and regulates in detail the licensing of auditors and authorisation of audit firms.
If your company crosses the medium-entity thresholds, plan an auditor engagement for the current business year — the obligation covers annual financial statements prepared under the new accounting framework.