Kotor and UNESCO: Building Rules in Protected Zones

The short answer: the Bay of Kotor is a UNESCO World Heritage Site, so any work on an old house there needs conservation requirements on top of the usual permits. Since 18 March 2026, new UTU and building permits in the Kotor region have been suspended until a Management Plan and a Protection Study are adopted. Reconstruction within the existing outline, adaptation, repair and conservation are exempt.

If your house is in the Bay of Kotor, and especially inside the old town walls, forget what you know about a "simple" reconstruction. The rules are different here.

It isn’t bureaucracy for its own sake. The Natural and Culturo-Historical Region of Kotor is a UNESCO World Heritage Site, and that status comes with obligations for anyone who touches the historic fabric. Below is what it means for an owner, including the transitional regime that a new law introduced in spring 2026. As of 10.09.2026 it is in force.

Why is Kotor different?

Kotor was inscribed on the World Heritage List in 1979 - the same year a severe earthquake hit the area. Many monuments were damaged, among them four Romanesque churches and the town walls. The town was largely rebuilt with UNESCO’s help, and the key monuments and historic quarters kept their architectural and historic authenticity.

Today the old fabric is a living heritage, and Montenegro is answerable to the international community for looking after it. That is why a 2013 law set up a Council to manage the Kotor region and coordinate its protection.

Which laws apply in the heritage region?

Any construction, restoration or facade work here falls under two special laws:

• the Law on the Protection of the Natural and Culturo-Historical Region of Kotor (Zakon o zaštiti prirodnog i kulturno-istorijskog područja Kotora, 2013/2018);
• the Law on the Protection of Cultural Property (Zakon o zaštiti kulturnih dobara, 2010).

In practice, the usual sequence - plan, UTU, design - isn’t enough. There is an extra layer on top whose job is to protect the historic character.

Conservation requirements come from the Administration for the Protection of Cultural Property (Uprava za zaštitu kulturnih dobara), a government body based in Cetinje. The technical side is handled by the Centre for Conservation and Archaeology of Montenegro (Centar za konzervaciju i arheologiju Crne Gore).

What changed in 2026: the permit pause

In February 2026 the Parliament of Montenegro (Skupština Crne Gore) amended the law on the Kotor region. The amendments were published in Službeni list Crne Gore No. 33/26 on 10.03.2026 and came into force on 18.03.2026, as the sluzbenilist.me register confirms. The next day the Municipality of Kotor announced it too.

The amendments put the region under a transitional regime until two documents are adopted:

• the Management Plan (Menadžment plan prirodnog i kulturno-istorijskog područja Kotora), which needs UNESCO’s opinion first;
• the Cultural Heritage Protection Study (Studija zaštite kulturne baštine prirodnog i kulturno-istorijskog područja Kotora i zaštićene okoline), drafted and adopted by the Administration for the Protection of Cultural Property with UNESCO’s prior consent.

Together they will steer how the region is managed. Every planning document will have to agree with the Protection Study and with the strategic environmental assessment. The Study itself covers the whole region and its buffer zone: the cumulative impact of construction, individual impact assessments and remedial measures for illegal buildings.

The law gives 12 months to adopt both, so the deadline is 18.03.2027. After that, planning documents must be brought into line within 18 months; until they are, they apply only where the Administration has found them compliant.

What is on hold and what is still allowed

Until the Plan and the Study are adopted, no UTU or building permits are issued in the Kotor region, with five exceptions:

• structures of public interest;
• infrastructure;
• reconstruction within the existing footprint and height;
• adaptation and repair;
• conservation and restoration work under the cultural property rules.

Remember that, legally, reconstruction means work strictly within the building’s existing horizontal and vertical outline. Anything bigger is not covered by the exception.

Until then, you can only get a draft UTU. It’s purely for information - an extract from the plan, not a basis for design. Projects that had applied for a permit, or already had one, before the amendments came into force carry on as before.

The buffer zone has its own route. There, UTU and permits need a decision from the Administration for the Protection of Cultural Property. The decision confirms that the project, its parameters and its use fit the protection studies and measures in the valid plans, or an adopted individual impact assessment. For its part of the buffer zone, the Municipality of Tivat is named separately, with its own protection studies and regime maps.

Two more restrictions are worth knowing:

• In Old Kotor, Old Perast and Old Risan with Gabela Street, you may only repair damaged structures or rebuild destroyed ones, based on what physically remains or on reliable records of how they looked. The shoreline can’t be moved and the sea can’t be filled in, except for rehabilitation and revitalization provided for by law.
• Silence no longer means consent. If the Administration doesn’t issue and deliver its decision on conservation requirements or project approval in time, the application is not deemed approved.

And legalization? Procedures in the region and the buffer zone that were started under the special law are suspended until the Plan and the Study are adopted. A building can then be legalized only if it meets both the legalization law and the new documents. The general rules and deadlines are in Legalization of Illegal Buildings in Montenegro; in Kotor you add a pause and a second filter.

Conservation requirements: the document that comes first

In the historic area, the key document is the set of conservation requirements (konzervatorski uslovi). They say which parts of the facade must be kept, which interventions have to stay reversible, where stone, timber and plaster must be restored in original materials - and whether reconstruction is possible at all. A good summary is in this Rona Legal overview.

So the limits come before the design, not after. An architect starts by reading the requirements: what can change, what can’t be touched, and what needs a careful, reversible hand. Planning documents also include a heritage impact assessment (HIA) based on the 2009 ICOMOS guidance. You get the requirements first and design to fit them, never the other way round.

How much more does it cost, and how long does it take?

More, and longer. The law firm Rona Legal estimates that work in the UNESCO zone typically adds 30-50% to the cost and 12-24 months to the schedule. On top of that come strict limits on facades, extra floors and the option of demolishing and rebuilding. That’s an estimate from practice, not a legal rule, but it’s an honest picture. The extra goes on original stone, traditional timber beams, restorers, archaeological supervision, the HIA and structural solutions for parts that can’t be touched.

Leave room in the schedule for the requirements stage itself: the same review suggests allowing 12-24 months.

Press reports add context. According to Monitor magazine (late 2024 to early 2025), as cited by Rona Legal, the Administration has had no appointed director since October 2023. About 350 UTU applications for Kotor alone are waiting in the queue, which means some 20 million euros in utility fees on hold. These are press figures from a secondary source, not official statistics, but it’s wise to plan with the queue in mind.

What should an owner do?

If your building is in the Bay of Kotor, here is a short plan:

• Find out where exactly it is - inside the Kotor region or in its buffer zone. Inside the region, permits are on hold apart from the five exceptions. In the buffer zone, they need a decision from the Administration.
• Check what kind of work you’re planning. Reconstruction within the existing outline, adaptation and conservation are exempt from the pause, but the conservation requirements still come first. Where reconstruction ends and adaptation begins is explained in Reconstruction or Adaptation: what the law treats as reconstruction in Montenegro; in Kotor the conservators have a say as well.
• Don’t count on silence meaning consent. In the region that rule no longer applies.
• If part of the building is illegal, start with Legalization of Illegal Buildings in Montenegro, then add the Kotor filter: procedures are suspended and the conditions are double.
• Check whether the Plan and the Study have been adopted. As of 10.09.2026, open sources show no published adoption. A new plan is being drafted, and the municipality launched a stakeholder survey on 17.07.2026. Once both are adopted, the pause lifts and plans are brought into line within 18 months.
• Budget with the Kotor margin: plus 30-50% and plus 12-24 months, as a rough guide rather than a calculation.

Where UTU fits into the process, and what it contains, is covered in UTU in Montenegro: What You Can Build on Your Plot. Just remember that in Kotor a draft UTU is for information only.

At ABRIS we start heritage reconstructions from the conservation requirements and the current pause rules. We design to fit the protected character from day one, prepare the input for the HIA and the approval route, and plan the budget and schedule with the Kotor margin built in.

Questions owners ask

In short

Reconstruction in the protected Bay of Kotor is the most demanding scenario in Montenegro. Paperwork alone won’t do: every decision goes through the heritage filter, and there’s no way around it. Since 2026 there is also a pause - no new UTU or permits in the region until the Management Plan and the Protection Study are adopted, except for reconstruction within the existing outline, adaptation, repair and conservation.

Herceg Novi, Budva, Ulcinj and Stari Bar are historic towns too, each protected under the general law on cultural property. The 2026 transitional regime, though, applies only to the Kotor region and its buffer zone.

Sources

• Zakon o izgradnji objekata (SL CG 19/25)
• Rona Legal: Real estate development in Montenegro, permits and approvals (2026)
• UNESCO: Natural and Culturo-Historical Region of Kotor
• Zakon o izmjenama i dopunama Zakona o zaštiti prirodnog i kulturno-istorijskog područja Kotora (SL CG 33/2026)
• Opština Kotor: stupio na snagu zakon, 19.03.2026
• Opština Kotor: upitnik za izradu novog Menadžment plana, 17.07.2026
• Zakon o zaštiti kulturnih dobara (SL CG 49/2010)