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2026-10-30
Personal Data Protection in Monaco: New Rules on International Data Transfers
Ministerial Order No. 2026-548 of 30 September 2026, published in the Journal de Monaco on 16 October 2026, establishes the list of countries, territories and international organisations recognised as providing an adequate level of protection for personal data. This development has important implications for Monaco-based businesses transferring personal data internationally. Adopted pursuant to Article 97 of Law No. 1.565 of 3 December 2024 on the Protection of Personal Data, the Ministerial Order clarifies the legal framework governing international data transfers from Monaco. Jurisdictions Recognised as Providing Adequate Protection The list includes the Member States of the European Union, the United Kingdom, Switzerland, Andorra, Argentina, Brazil, New Zealand and Uruguay. It also covers Iceland, Liechtenstein, Norway, Guernsey, Jersey, the Isle of Man, the Faroe Islands and the European Patent Organisation. Canada is also included, although its adequacy recognition specifically applies to private-sector organisations subject to the Personal Information Protection and Electronic Documents Act (PIPEDA) in the course of their commercial activities. Notably, the United States, Japan, the Republic of Korea and Israel are not included in the final list, although their inclusion had initially been contemplated. What Are the Implications for Monaco-Based Businesses? Transfers of personal data to jurisdictions recognised as providing adequate protection may be carried out without specific prior formalities relating to the transfer, provided that all other applicable legal obligations are met. Transfers to jurisdictions not benefiting from an adequacy recognition remain possible, subject to the mechanisms provided under Law No. 1.565, including: Article 98: Appropriate safeguards, such as standard data protection clauses approved by Monaco's Personal Data Protection Authority (APDP) or binding corporate rules. Article 99: Statutory derogations applicable under specific conditions. Article 100: Prior authorisation from the APDP based on specific safeguards. The publication of the APDP's standard data protection clauses, which could take place by the end of 2026, is expected to provide further guidance on international data transfers. A Key Compliance Consideration These developments are particularly relevant for Monaco-based businesses relying on international service providers, cloud services or IT solutions involving cross-border transfers of personal data. Businesses should therefore review their international data flows and ensure that appropriate legal safeguards are in place. How Gordon S. Blair Can Assist Gordon S. Blair advises businesses, investors and executives on the structuring and development of their projects in Monaco, providing legal guidance tailored to their needs and the Principality's regulatory environment. Drawing on its expertise in corporate and business law, risk management and regulatory compliance, the firm assists its clients in identifying and anticipating legal and regulatory challenges. The evolving personal data protection framework highlights the importance of integrating compliance considerations into business operations and projects to mitigate legal risks and support their long-term development.
2026-10-30
Personal Data Protection in Monaco: New Rules on International Data Transfers
Ministerial Order No. 2026-548 of 30 September 2026, published in the Journal de Monaco on 16 October 2026, establishes the list of countries, territories and international organisations recognised as providing an adequate level of protection for personal data. This development has important implications for Monaco-based businesses transferring personal data internationally. Adopted pursuant to Article 97 of Law No. 1.565 of 3 December 2024 on the Protection of Personal Data, the Ministerial Order clarifies the legal framework governing international data transfers from Monaco. Jurisdictions Recognised as Providing Adequate Protection The list includes the Member States of the European Union, the United Kingdom, Switzerland, Andorra, Argentina, Brazil, New Zealand and Uruguay. It also covers Iceland, Liechtenstein, Norway, Guernsey, Jersey, the Isle of Man, the Faroe Islands and the European Patent Organisation. Canada is also included, although its adequacy recognition specifically applies to private-sector organisations subject to the Personal Information Protection and Electronic Documents Act (PIPEDA) in the course of their commercial activities. Notably, the United States, Japan, the Republic of Korea and Israel are not included in the final list, although their inclusion had initially been contemplated. What Are the Implications for Monaco-Based Businesses? Transfers of personal data to jurisdictions recognised as providing adequate protection may be carried out without specific prior formalities relating to the transfer, provided that all other applicable legal obligations are met. Transfers to jurisdictions not benefiting from an adequacy recognition remain possible, subject to the mechanisms provided under Law No. 1.565, including: Article 98: Appropriate safeguards, such as standard data protection clauses approved by Monaco's Personal Data Protection Authority (APDP) or binding corporate rules. Article 99: Statutory derogations applicable under specific conditions. Article 100: Prior authorisation from the APDP based on specific safeguards. The publication of the APDP's standard data protection clauses, which could take place by the end of 2026, is expected to provide further guidance on international data transfers. A Key Compliance Consideration These developments are particularly relevant for Monaco-based businesses relying on international service providers, cloud services or IT solutions involving cross-border transfers of personal data. Businesses should therefore review their international data flows and ensure that appropriate legal safeguards are in place. How Gordon S. Blair Can Assist Gordon S. Blair advises businesses, investors and executives on the structuring and development of their projects in Monaco, providing legal guidance tailored to their needs and the Principality's regulatory environment. Drawing on its expertise in corporate and business law, risk management and regulatory compliance, the firm assists its clients in identifying and anticipating legal and regulatory challenges. The evolving personal data protection framework highlights the importance of integrating compliance considerations into business operations and projects to mitigate legal risks and support their long-term development.
2026-10-29
Gordon S. Blair featured in the Global Law Experts & Global Advisory Experts Handbook 2026
Gordon S. Blair and its Managing Partner, Xavier de Sarrau, are featured in the 2026 edition of the Global Law Experts & Global Advisory Experts Handbook, published in September 2026, in the Monaco – Wealth Management Law section. An international reference guide Published by Global Law Experts and Global Advisory Experts, the Handbook presents law and advisory firms around the world each year, organised by jurisdiction and practice area. It is aimed at business leaders and decision-makers seeking international advice. More than a century advising on international wealth Founded in Monaco in 1920, Gordon S. Blair advises private individuals, entrepreneurial families, family offices, financial institutions and international groups on the structuring, protection and management of their private and corporate interests. Led by Xavier de Sarrau, a multidisciplinary team of around 50 legal and tax professionals advises on wealth management, international tax and estate planning, family governance, real estate, corporate law, M&A and cross-border projects. Key expertise highlighted in the profile The profile published in the Handbook highlights several of the firm's areas of work: Relocation to Monaco: support at every stage of the process, from residency and international tax to wealth structuring, business establishment and regulatory matters. Wealth preservation and succession: trusts, foundations, family offices, holding structures and governance frameworks designed across generations and jurisdictions. High-value assets: yachts, aircraft, real estate and art collections, from acquisition to transmission, integrating legal, tax and regulatory advice.
2026-10-29
Gordon S. Blair featured in the Global Law Experts & Global Advisory Experts Handbook 2026
Gordon S. Blair and its Managing Partner, Xavier de Sarrau, are featured in the 2026 edition of the Global Law Experts & Global Advisory Experts Handbook, published in September 2026, in the Monaco – Wealth Management Law section. An international reference guide Published by Global Law Experts and Global Advisory Experts, the Handbook presents law and advisory firms around the world each year, organised by jurisdiction and practice area. It is aimed at business leaders and decision-makers seeking international advice. More than a century advising on international wealth Founded in Monaco in 1920, Gordon S. Blair advises private individuals, entrepreneurial families, family offices, financial institutions and international groups on the structuring, protection and management of their private and corporate interests. Led by Xavier de Sarrau, a multidisciplinary team of around 50 legal and tax professionals advises on wealth management, international tax and estate planning, family governance, real estate, corporate law, M&A and cross-border projects. Key expertise highlighted in the profile The profile published in the Handbook highlights several of the firm's areas of work: Relocation to Monaco: support at every stage of the process, from residency and international tax to wealth structuring, business establishment and regulatory matters. Wealth preservation and succession: trusts, foundations, family offices, holding structures and governance frameworks designed across generations and jurisdictions. High-value assets: yachts, aircraft, real estate and art collections, from acquisition to transmission, integrating legal, tax and regulatory advice.
2026-10-23
Monaco strengthens the right to a bank account
Legal update – 16 October 2026 Published in the Journal de Monaco on 16 October 2026, Law No. 1.597 of 9 October 2026 strengthens the statutory right to a bank account introduced in 2020. The reform sets clearer deadlines for banks and facilitates access to the designation procedure where a bank refuses an application or fails to respond. Clearer processing deadlines The reform first sets a precise timetable for the bank receiving the application. Banks must request the necessary documents in writing within 30 working days of receiving a formally submitted application. Once all necessary documents have been received, the bank has 30 working days to open the account, subject to compliance with statutory due diligence requirements. A bank's silence constitutes an implied refusal One of the main advances of the law is the introduction of an implied refusal. Failure to respond within 30 working days of receiving the application, or following receipt of requested missing documents, constitutes an implied refusal. Eligible applicants may then refer the matter directly to the Budget and Treasury Department, without waiting for a refusal certificate. The Department must designate a bank within 10 working days of receiving the required documentation. Wider access to the right The law also removes two practical obstacles. First, eligible applicants may invoke their right to an account as soon as they receive notice terminating their existing account, without waiting for its actual closure. Second, holding a joint account does not prevent an eligible individual from opening an individual account. Remedies and sanctions The effectiveness of the regime is supported by judicial review and sanctions. A designated bank's refusal, or failure to open an account within the prescribed deadlines, may be challenged before the President of the Court of First Instance under the procedure applicable en la forme des référés. In addition, certain failures to issue a refusal certificate or to notify an applicant of a rejection may attract an administrative fine of up to €10,000. Best practice for applicants In practice, the reform highlights the importance of evidence. Applicants should formally submit their request by registered post, electronic registered delivery or hand delivery against a receipt, and retain evidence of the documents supplied. The right to an account remains subject to anti-money laundering and counter-terrorist financing requirements. Entry into force and transitional provisions The law took effect on 17 October 2026. Transitional provisions notably reserve the new application-processing rules and related sanctions for applications submitted after that date.
2026-10-23
Monaco strengthens the right to a bank account
Legal update – 16 October 2026 Published in the Journal de Monaco on 16 October 2026, Law No. 1.597 of 9 October 2026 strengthens the statutory right to a bank account introduced in 2020. The reform sets clearer deadlines for banks and facilitates access to the designation procedure where a bank refuses an application or fails to respond. Clearer processing deadlines The reform first sets a precise timetable for the bank receiving the application. Banks must request the necessary documents in writing within 30 working days of receiving a formally submitted application. Once all necessary documents have been received, the bank has 30 working days to open the account, subject to compliance with statutory due diligence requirements. A bank's silence constitutes an implied refusal One of the main advances of the law is the introduction of an implied refusal. Failure to respond within 30 working days of receiving the application, or following receipt of requested missing documents, constitutes an implied refusal. Eligible applicants may then refer the matter directly to the Budget and Treasury Department, without waiting for a refusal certificate. The Department must designate a bank within 10 working days of receiving the required documentation. Wider access to the right The law also removes two practical obstacles. First, eligible applicants may invoke their right to an account as soon as they receive notice terminating their existing account, without waiting for its actual closure. Second, holding a joint account does not prevent an eligible individual from opening an individual account. Remedies and sanctions The effectiveness of the regime is supported by judicial review and sanctions. A designated bank's refusal, or failure to open an account within the prescribed deadlines, may be challenged before the President of the Court of First Instance under the procedure applicable en la forme des référés. In addition, certain failures to issue a refusal certificate or to notify an applicant of a rejection may attract an administrative fine of up to €10,000. Best practice for applicants In practice, the reform highlights the importance of evidence. Applicants should formally submit their request by registered post, electronic registered delivery or hand delivery against a receipt, and retain evidence of the documents supplied. The right to an account remains subject to anti-money laundering and counter-terrorist financing requirements. Entry into force and transitional provisions The law took effect on 17 October 2026. Transitional provisions notably reserve the new application-processing rules and related sanctions for applications submitted after that date.
2026-10-23
Monaco: Draft Law no. 1131 introduces a new framework for crypto-asset services
Draft Law no. 1131 regulating the activities of crypto-asset service providers would introduce a new legal framework in the Principality. According to its explanatory memorandum, the proposed legislation notably reflects Monaco’s commitments under its Monetary Agreement with the European Union, including the adoption of measures equivalent to the European Markets in Crypto-Assets Regulation — MiCA. It also takes into account the recommendations of the Financial Action Task Force — FATF. A deliberately limited opening The approach adopted by the Princely Government is based on strategic considerations relating to the international environment. It provides for a limited opening of the permitted services, notably to reduce the Principality’s exposure to the risks associated with certain crypto-asset activities. The selected services would therefore constitute a natural extension of financial activities already carried out in Monaco. Against this background, the draft law is largely aligned with amended Law no. 1.338 of 7 September 2007 on financial activities, while adapting certain provisions to the specific features of crypto-asset services, particularly in relation to operating requirements. A framework limited to three services The draft law would authorise only three crypto-asset services: receiving and transmitting orders in crypto-assets on behalf of clients; • providing crypto-asset portfolio management services; • providing advice on crypto-assets. Other services falling within the scope of the proposed framework would be prohibited in the Principality. These would notably include: custody and administration of crypto-assets on behalf of clients; • operating a crypto-asset trading platform; • exchanging crypto-assets for funds; • exchanging crypto-assets for other crypto-assets; • executing orders on behalf of clients; • placing crypto-assets; • providing crypto-asset transfer services on behalf of clients. The issuance of crypto-assets within the Principality would also be prohibited. The draft law nevertheless provides for certain exclusions from its scope, notably for certain intragroup services, certain unique and non-fungible crypto-assets and crypto-assets already governed by other legal regimes. Prior authorisation from the CCAF Providing any or all of the three permitted services would require prior authorisation from the Commission de Contrôle des Activités Financières — CCAF. Authorisation could be granted to: Monaco public limited companies meeting the conditions set out in the legislation; • credit institutions headquartered in a foreign State, operating through a branch in Monaco and already authorised by the CCAF under Law no. 1.338. Within their respective areas of competence, the CCAF would seek the opinion of the Autorité Monégasque de Sécurité Financière and the Agence Monégasque de Sécurité Numérique. It would issue its decision within six months of receiving a complete application. Authorisation would notably be subject to requirements concerning: financial guarantees, own funds and prudential safeguards; • the competence and good repute of directors and shareholders; • AML/CFT and asset-freezing obligations; • business continuity and operational resilience; • information systems security. Client protection and conduct requirements Authorised providers would be subject to prudential and conduct-of-business rules, together with obligations relating to conflicts of interest, record-keeping and information systems security. Client mandates would have to be governed by written agreements. Providers would not be permitted to accept deposits of funds or crypto-assets from their clients. They would also be required to obtain information concerning each client’s knowledge and experience to assess whether the proposed service or crypto-asset is appropriate. Commercial approaches would also be regulated, particularly where made by unauthorised persons or entities. Restrictions would additionally apply to certain unsolicited approaches by authorised providers. Supervision, penalties and market abuse The CCAF would be the competent authority responsible for supervising the implementation of the framework. Its powers would include: determining applications for authorisation; • monitoring compliance with professional obligations; • conducting inspections and investigations; • cooperating with foreign authorities; • implementing the measures and penalties provided for by the legislation. The draft law also provides for criminal penalties, notably where services are provided without authorisation or prohibited activities are carried out. A specific regime would additionally address market abuse involving crypto-assets, including the unlawful use or disclosure of inside information and market manipulation. Finally, the draft legislation would amend several Monaco laws relating to digital matters, financial activities and AML/CFT. Article 60 would notably repeal amended Law no. 1.491 of 23 June 2020 on token offerings and Title II of Law no. 1.528 of 7 July 2022. A targeted approach Draft Law no. 1131 therefore adopts a targeted approach: only three crypto-asset services could be provided in the Principality, as an extension of existing financial activities and subject to prior CCAF authorisation. All other services falling within the proposed framework would be prohibited, together with any issuance of crypto-assets within Monaco. As the draft law remains subject to examination by the National Council, its provisions may evolve during the legislative process.
2026-10-23
Monaco: Draft Law no. 1131 introduces a new framework for crypto-asset services
Draft Law no. 1131 regulating the activities of crypto-asset service providers would introduce a new legal framework in the Principality. According to its explanatory memorandum, the proposed legislation notably reflects Monaco’s commitments under its Monetary Agreement with the European Union, including the adoption of measures equivalent to the European Markets in Crypto-Assets Regulation — MiCA. It also takes into account the recommendations of the Financial Action Task Force — FATF. A deliberately limited opening The approach adopted by the Princely Government is based on strategic considerations relating to the international environment. It provides for a limited opening of the permitted services, notably to reduce the Principality’s exposure to the risks associated with certain crypto-asset activities. The selected services would therefore constitute a natural extension of financial activities already carried out in Monaco. Against this background, the draft law is largely aligned with amended Law no. 1.338 of 7 September 2007 on financial activities, while adapting certain provisions to the specific features of crypto-asset services, particularly in relation to operating requirements. A framework limited to three services The draft law would authorise only three crypto-asset services: receiving and transmitting orders in crypto-assets on behalf of clients; • providing crypto-asset portfolio management services; • providing advice on crypto-assets. Other services falling within the scope of the proposed framework would be prohibited in the Principality. These would notably include: custody and administration of crypto-assets on behalf of clients; • operating a crypto-asset trading platform; • exchanging crypto-assets for funds; • exchanging crypto-assets for other crypto-assets; • executing orders on behalf of clients; • placing crypto-assets; • providing crypto-asset transfer services on behalf of clients. The issuance of crypto-assets within the Principality would also be prohibited. The draft law nevertheless provides for certain exclusions from its scope, notably for certain intragroup services, certain unique and non-fungible crypto-assets and crypto-assets already governed by other legal regimes. Prior authorisation from the CCAF Providing any or all of the three permitted services would require prior authorisation from the Commission de Contrôle des Activités Financières — CCAF. Authorisation could be granted to: Monaco public limited companies meeting the conditions set out in the legislation; • credit institutions headquartered in a foreign State, operating through a branch in Monaco and already authorised by the CCAF under Law no. 1.338. Within their respective areas of competence, the CCAF would seek the opinion of the Autorité Monégasque de Sécurité Financière and the Agence Monégasque de Sécurité Numérique. It would issue its decision within six months of receiving a complete application. Authorisation would notably be subject to requirements concerning: financial guarantees, own funds and prudential safeguards; • the competence and good repute of directors and shareholders; • AML/CFT and asset-freezing obligations; • business continuity and operational resilience; • information systems security. Client protection and conduct requirements Authorised providers would be subject to prudential and conduct-of-business rules, together with obligations relating to conflicts of interest, record-keeping and information systems security. Client mandates would have to be governed by written agreements. Providers would not be permitted to accept deposits of funds or crypto-assets from their clients. They would also be required to obtain information concerning each client’s knowledge and experience to assess whether the proposed service or crypto-asset is appropriate. Commercial approaches would also be regulated, particularly where made by unauthorised persons or entities. Restrictions would additionally apply to certain unsolicited approaches by authorised providers. Supervision, penalties and market abuse The CCAF would be the competent authority responsible for supervising the implementation of the framework. Its powers would include: determining applications for authorisation; • monitoring compliance with professional obligations; • conducting inspections and investigations; • cooperating with foreign authorities; • implementing the measures and penalties provided for by the legislation. The draft law also provides for criminal penalties, notably where services are provided without authorisation or prohibited activities are carried out. A specific regime would additionally address market abuse involving crypto-assets, including the unlawful use or disclosure of inside information and market manipulation. Finally, the draft legislation would amend several Monaco laws relating to digital matters, financial activities and AML/CFT. Article 60 would notably repeal amended Law no. 1.491 of 23 June 2020 on token offerings and Title II of Law no. 1.528 of 7 July 2022. A targeted approach Draft Law no. 1131 therefore adopts a targeted approach: only three crypto-asset services could be provided in the Principality, as an extension of existing financial activities and subject to prior CCAF authorisation. All other services falling within the proposed framework would be prohibited, together with any issuance of crypto-assets within Monaco. As the draft law remains subject to examination by the National Council, its provisions may evolve during the legislative process.
2026-10-19
Beneficial ownership: a compliance priority for Monaco businesses
Declaring beneficial ownership is not merely an administrative formality. Monaco businesses must ensure that the information they provide is accurate, complete and regularly updated. Any failure to do so may have significant legal and administrative consequences. Significant penalties for inaccurate declarations Where an inaccurate or incomplete declaration is made in bad faith, the penalties may include: imprisonment for up to six months; • a fine of up to €90,000. Even where bad faith has not been established, a failure to comply with the relevant reporting obligations may result in administrative measures. Monaco’s Business Development Agency may issue a formal notice requiring the company concerned to rectify the situation. The irregularity may also be referred to on the relevant register extract, while certain companies may face administrative fines of up to €20,000. If the failure persists, the matter may be referred to the Court of First Instance. The obligation to report discrepancies Professionals subject to obligations relating to anti-money laundering, counter-terrorist financing, counter-proliferation financing and anti-corruption – AML/CFT-P-C – must also report any discrepancy between the information recorded on the beneficial ownership register and the information available to them through their own due diligence procedures. Failure to report a discrepancy may expose those concerned to: imprisonment for up to six months; • a fine of up to €180,000, which may be increased depending on the status of the person concerned; • additional penalties which, in the most serious cases, may extend to the dissolution of the legal entity. Compliance as a core component of corporate governance Reliable beneficial ownership information and an effective compliance framework are not simply regulatory requirements. They are also essential components of responsible corporate governance, effective risk management and transparency within legal structures. Businesses and regulated professionals must therefore be able to demonstrate the relevance of their procedures, the effectiveness of their controls and the regular updating of the information they hold. How Gordon S. Blair can assist Gordon S. Blair assists businesses and regulated professionals with: implementing and updating their AML/CFT-P-C frameworks; • conducting compliance audits; • carrying out mandatory periodic reviews; • identifying and addressing potential compliance weaknesses; • strengthening internal control and governance procedures. Should you have any questions regarding your obligations or wish to assess your compliance framework, our teams remain at your disposal.
2026-10-19
Beneficial ownership: a compliance priority for Monaco businesses
Declaring beneficial ownership is not merely an administrative formality. Monaco businesses must ensure that the information they provide is accurate, complete and regularly updated. Any failure to do so may have significant legal and administrative consequences. Significant penalties for inaccurate declarations Where an inaccurate or incomplete declaration is made in bad faith, the penalties may include: imprisonment for up to six months; • a fine of up to €90,000. Even where bad faith has not been established, a failure to comply with the relevant reporting obligations may result in administrative measures. Monaco’s Business Development Agency may issue a formal notice requiring the company concerned to rectify the situation. The irregularity may also be referred to on the relevant register extract, while certain companies may face administrative fines of up to €20,000. If the failure persists, the matter may be referred to the Court of First Instance. The obligation to report discrepancies Professionals subject to obligations relating to anti-money laundering, counter-terrorist financing, counter-proliferation financing and anti-corruption – AML/CFT-P-C – must also report any discrepancy between the information recorded on the beneficial ownership register and the information available to them through their own due diligence procedures. Failure to report a discrepancy may expose those concerned to: imprisonment for up to six months; • a fine of up to €180,000, which may be increased depending on the status of the person concerned; • additional penalties which, in the most serious cases, may extend to the dissolution of the legal entity. Compliance as a core component of corporate governance Reliable beneficial ownership information and an effective compliance framework are not simply regulatory requirements. They are also essential components of responsible corporate governance, effective risk management and transparency within legal structures. Businesses and regulated professionals must therefore be able to demonstrate the relevance of their procedures, the effectiveness of their controls and the regular updating of the information they hold. How Gordon S. Blair can assist Gordon S. Blair assists businesses and regulated professionals with: implementing and updating their AML/CFT-P-C frameworks; • conducting compliance audits; • carrying out mandatory periodic reviews; • identifying and addressing potential compliance weaknesses; • strengthening internal control and governance procedures. Should you have any questions regarding your obligations or wish to assess your compliance framework, our teams remain at your disposal.
2026-10-19
Monaco: corporate audit and group reporting reform approved
A milestone for Monaco company law. On 5 October 2026, Monaco's National Council unanimously approved Bill No. 1112 concerning accounting professionals, statutory auditors and corporate financial statements. Here is what it means for groups, and the questions worth asking now. Building on the 2025 reforms This reform does not come out of nowhere. It follows the modernisation of company law in 2025 and tackles a core issue for trust in financial information: the independence of those who audit it. In practice, the reform strengthens auditor independence and addresses conflicts of interest. Consolidated accounts enter the picture The second key change: the bill introduces a framework for certain parent companies to prepare and file consolidated financial statements, subject to the applicable conditions and thresholds. For groups organised around a parent company, this may change how financial information is presented and managed. Practical questions for directors and shareholders For directors and shareholders, the focus is now practical. The questions concern both governance and financial reporting: Consolidation: does the group fall within the consolidation requirements? Organisation: how should reporting be organised? Independence: do auditor appointments meet the independence rules? Addressing these questions early makes it possible to approach implementation without pressure. Next steps Parliamentary approval marks a significant step, but not the final one. Publication of the final legislation and the relevant implementing provisions will clarify the applicable timetable and requirements. In the meantime, one thing is clear: groups that plan ahead will be best placed for the transition.
2026-10-19
Monaco: corporate audit and group reporting reform approved
A milestone for Monaco company law. On 5 October 2026, Monaco's National Council unanimously approved Bill No. 1112 concerning accounting professionals, statutory auditors and corporate financial statements. Here is what it means for groups, and the questions worth asking now. Building on the 2025 reforms This reform does not come out of nowhere. It follows the modernisation of company law in 2025 and tackles a core issue for trust in financial information: the independence of those who audit it. In practice, the reform strengthens auditor independence and addresses conflicts of interest. Consolidated accounts enter the picture The second key change: the bill introduces a framework for certain parent companies to prepare and file consolidated financial statements, subject to the applicable conditions and thresholds. For groups organised around a parent company, this may change how financial information is presented and managed. Practical questions for directors and shareholders For directors and shareholders, the focus is now practical. The questions concern both governance and financial reporting: Consolidation: does the group fall within the consolidation requirements? Organisation: how should reporting be organised? Independence: do auditor appointments meet the independence rules? Addressing these questions early makes it possible to approach implementation without pressure. Next steps Parliamentary approval marks a significant step, but not the final one. Publication of the final legislation and the relevant implementing provisions will clarify the applicable timetable and requirements. In the meantime, one thing is clear: groups that plan ahead will be best placed for the transition.
2026-10-09
Monaco: legislative proposal seeks to encourage the relocation and transparency of foreign entities holding real estate
On 2 April 2026, Monaco’s National Council adopted Legislative Proposal No. 276. The proposal pursues a dual objective: encouraging foreign entities owning real estate in Monaco to relocate to the Principality, and enhancing their transparency. It was transmitted to the Prince’s Government on 3 April 2026. Relocation to Monaco with continuity of legal existence The first key element of the proposal concerns the relocation mechanism itself. Subject to certain conditions, the entities concerned could relocate to Monaco while preserving their legal existence. The relocation would nonetheless be subject to a framework. In particular, the entities would need to correspond to a legal form recognised under Monaco law and comply with the applicable Monaco rules. A temporary exemption from proportional registration duties To facilitate these transactions, the proposal provides for exemptions from proportional registration duties for certain relocations and property contributions. This favourable regime would be time-limited: it would apply for a three-year period following the future law’s entry into force. Introduction of a 1% annual levy In parallel, the proposal would introduce an annual levy equal to 1% of the market value of the relevant property or property rights, calculated without deducting debt. Entities disclosing the identity of their ultimate beneficial owners annually would notably be exempt. This exemption is therefore consistent with the proposal’s objective of enhancing transparency. A legislative process still under way Adoption of a legislative proposal by the National Council does not bring it into force. The measures described above remain subject to the further legislative process, and their final terms may still change. Do you hold Monaco real estate through a foreign structure? Our team is available to assess the implications.
2026-10-09
Monaco: legislative proposal seeks to encourage the relocation and transparency of foreign entities holding real estate
On 2 April 2026, Monaco’s National Council adopted Legislative Proposal No. 276. The proposal pursues a dual objective: encouraging foreign entities owning real estate in Monaco to relocate to the Principality, and enhancing their transparency. It was transmitted to the Prince’s Government on 3 April 2026. Relocation to Monaco with continuity of legal existence The first key element of the proposal concerns the relocation mechanism itself. Subject to certain conditions, the entities concerned could relocate to Monaco while preserving their legal existence. The relocation would nonetheless be subject to a framework. In particular, the entities would need to correspond to a legal form recognised under Monaco law and comply with the applicable Monaco rules. A temporary exemption from proportional registration duties To facilitate these transactions, the proposal provides for exemptions from proportional registration duties for certain relocations and property contributions. This favourable regime would be time-limited: it would apply for a three-year period following the future law’s entry into force. Introduction of a 1% annual levy In parallel, the proposal would introduce an annual levy equal to 1% of the market value of the relevant property or property rights, calculated without deducting debt. Entities disclosing the identity of their ultimate beneficial owners annually would notably be exempt. This exemption is therefore consistent with the proposal’s objective of enhancing transparency. A legislative process still under way Adoption of a legislative proposal by the National Council does not bring it into force. The measures described above remain subject to the further legislative process, and their final terms may still change. Do you hold Monaco real estate through a foreign structure? Our team is available to assess the implications.
2026-10-07
Monaco: proposed reform of private international law concerning succession and gifts
Legislative Proposal No. 272, adopted by Monaco’s National Council on 6 November 2025, seeks to modernise certain provisions of Monaco’s Private International Law Code relating to succession and lifetime gifts in an international context. The proposal is intended in particular to clarify a number of rules applicable to cross-border wealth transmission. Succession: reaffirming the unity of the applicable law In succession matters, the proposal would remove the provision referring to the deceased’s national law for the purposes of determining forced heirship protection. This would reaffirm the principle that a single law governs the succession as a whole. The proposal would also clarify the powers of Monaco’s courts to take the steps necessary to administer an estate in certain international situations, irrespective of the law governing the succession. Lifetime gifts: clarification of the applicable law The proposal also addresses the rules governing lifetime gifts. It would clarify how the applicable law is determined and provide expressly for Monaco law to govern gifts of real estate located in the Principality. The text would also clarify Monaco’s international public policy exception, while taking account of rights lawfully acquired abroad. A reform still in the legislative process On 7 May 2026, the Prince’s Government confirmed its support for converting the legislative proposal into a government bill. The bill must be submitted by 10 May 2027. At this stage, the proposed measures are not yet in force. Their final scope will depend on the future government bill and the subsequent legislative process.
2026-10-07
Monaco: proposed reform of private international law concerning succession and gifts
Legislative Proposal No. 272, adopted by Monaco’s National Council on 6 November 2025, seeks to modernise certain provisions of Monaco’s Private International Law Code relating to succession and lifetime gifts in an international context. The proposal is intended in particular to clarify a number of rules applicable to cross-border wealth transmission. Succession: reaffirming the unity of the applicable law In succession matters, the proposal would remove the provision referring to the deceased’s national law for the purposes of determining forced heirship protection. This would reaffirm the principle that a single law governs the succession as a whole. The proposal would also clarify the powers of Monaco’s courts to take the steps necessary to administer an estate in certain international situations, irrespective of the law governing the succession. Lifetime gifts: clarification of the applicable law The proposal also addresses the rules governing lifetime gifts. It would clarify how the applicable law is determined and provide expressly for Monaco law to govern gifts of real estate located in the Principality. The text would also clarify Monaco’s international public policy exception, while taking account of rights lawfully acquired abroad. A reform still in the legislative process On 7 May 2026, the Prince’s Government confirmed its support for converting the legislative proposal into a government bill. The bill must be submitted by 10 May 2027. At this stage, the proposed measures are not yet in force. Their final scope will depend on the future government bill and the subsequent legislative process.
2026-10-07
Monaco: proposed Patrimonial Foundation to support wealth management and succession planning
Legislative Proposal No. 268 concerning the Monaco Patrimonial Foundation seeks to introduce a new legal structure for the management and transfer of wealth, primarily for the benefit of the founder’s family. With its own legal personality, the foundation could hold assets including real estate, company shares and intangible rights. A new wealth-holding structure The proposal provides for an initial cash endowment of at least €10 million. Establishing the foundation would require authorisation from the Minister of State and registration. Its operation would also be subject to specific governance, accounting and transparency requirements. The founder and at least a majority of the administrators would need to be domiciled in Monaco or, in the case of legal entities, have their registered offices in the Principality. An expressly regulated purpose The Monaco Patrimonial Foundation would be intended to manage and transfer wealth and could engage in commercial activities only on an ancillary basis. Assets transferred to the foundation would also remain subject to any forced heirship protection provided for by the law applicable to the succession. The proposed framework therefore combines a wealth structuring tool with safeguards designed to take account of succession rules that may apply in an international context. A reform still in progress On 19 December 2025, the Prince’s Government confirmed its support for converting Legislative Proposal No. 268 into a government bill. The bill must be submitted by 23 December 2026. At this stage, the Monaco Patrimonial Foundation remains a proposed framework. Its final scope and practical requirements will depend on the next stages of the legislative process.
2026-10-07
Monaco: proposed Patrimonial Foundation to support wealth management and succession planning
Legislative Proposal No. 268 concerning the Monaco Patrimonial Foundation seeks to introduce a new legal structure for the management and transfer of wealth, primarily for the benefit of the founder’s family. With its own legal personality, the foundation could hold assets including real estate, company shares and intangible rights. A new wealth-holding structure The proposal provides for an initial cash endowment of at least €10 million. Establishing the foundation would require authorisation from the Minister of State and registration. Its operation would also be subject to specific governance, accounting and transparency requirements. The founder and at least a majority of the administrators would need to be domiciled in Monaco or, in the case of legal entities, have their registered offices in the Principality. An expressly regulated purpose The Monaco Patrimonial Foundation would be intended to manage and transfer wealth and could engage in commercial activities only on an ancillary basis. Assets transferred to the foundation would also remain subject to any forced heirship protection provided for by the law applicable to the succession. The proposed framework therefore combines a wealth structuring tool with safeguards designed to take account of succession rules that may apply in an international context. A reform still in progress On 19 December 2025, the Prince’s Government confirmed its support for converting Legislative Proposal No. 268 into a government bill. The bill must be submitted by 23 December 2026. At this stage, the Monaco Patrimonial Foundation remains a proposed framework. Its final scope and practical requirements will depend on the next stages of the legislative process.
2026-10-02
Monaco bill seeks to strengthen access to basic bank accounts
MONACO, 16 March 2026 — Monaco’s National Council has received Bill No. 1,124, which seeks to strengthen the right to open a bank account established by the Law of 8 July 2020, while preserving anti-money laundering and counter-terrorist financing requirements. Under the bill, banks would have 45 working days to process a complete application. If a bank failed to respond within that period, its silence would be treated as an implicit refusal, allowing the applicant to ask the Budget and Treasury Department to appoint another institution. The scheme would also be extended to holders of joint accounts seeking an individual account and to customers who have been notified that their existing account will be closed. The latter could begin the procedure before the closure takes effect. The bill also provides for written notification of refusals, the possibility of requesting the appointment of another bank, and an expedited court procedure to challenge certain refusals or account closures. Derived from a proposal adopted by the National Council in October 2024, the bill must still be examined and passed before entering into force.
2026-10-02
Monaco bill seeks to strengthen access to basic bank accounts
MONACO, 16 March 2026 — Monaco’s National Council has received Bill No. 1,124, which seeks to strengthen the right to open a bank account established by the Law of 8 July 2020, while preserving anti-money laundering and counter-terrorist financing requirements. Under the bill, banks would have 45 working days to process a complete application. If a bank failed to respond within that period, its silence would be treated as an implicit refusal, allowing the applicant to ask the Budget and Treasury Department to appoint another institution. The scheme would also be extended to holders of joint accounts seeking an individual account and to customers who have been notified that their existing account will be closed. The latter could begin the procedure before the closure takes effect. The bill also provides for written notification of refusals, the possibility of requesting the appointment of another bank, and an expedited court procedure to challenge certain refusals or account closures. Derived from a proposal adopted by the National Council in October 2024, the bill must still be examined and passed before entering into force.
2026-09-16
VAT – Clarification of the VAT Treatment of Subcontracted Work Relating to Immovable Property in Monaco
In a tax ruling published on 9 September 2026, the French tax authorities have clarified an area of uncertainty and confirmed that the VAT reverse charge mechanism applicable to subcontracted work relating to immovable property also applies in Monaco. What does this mean in practice in Monaco? Where a subcontractor carries out work falling within the scope of the reverse charge mechanism for a Monaco-based customer subject to VAT, the relevant services are invoiced without VAT, with the wording “Reverse charge”, and the Monaco-based customer is responsible for accounting for the corresponding VAT. Particular attention should also be paid to the terms of the subcontracting agreement. Where a single contract includes both services that are subject to the reverse charge mechanism and other services that, if considered separately, would not fall within its scope, the entire supply under the contract is subject to the reverse charge mechanism. This clarification therefore has practical implications for Monaco-based companies operating in the construction sector, property developers and real estate professionals, who should ensure that their subcontracting agreements, invoicing and VAT reporting obligations are treated appropriately. 📌 Reference: BOFiP, BOI-RES-TVA-000269, 9 September 2026.
2026-09-16
VAT – Clarification of the VAT Treatment of Subcontracted Work Relating to Immovable Property in Monaco
In a tax ruling published on 9 September 2026, the French tax authorities have clarified an area of uncertainty and confirmed that the VAT reverse charge mechanism applicable to subcontracted work relating to immovable property also applies in Monaco. What does this mean in practice in Monaco? Where a subcontractor carries out work falling within the scope of the reverse charge mechanism for a Monaco-based customer subject to VAT, the relevant services are invoiced without VAT, with the wording “Reverse charge”, and the Monaco-based customer is responsible for accounting for the corresponding VAT. Particular attention should also be paid to the terms of the subcontracting agreement. Where a single contract includes both services that are subject to the reverse charge mechanism and other services that, if considered separately, would not fall within its scope, the entire supply under the contract is subject to the reverse charge mechanism. This clarification therefore has practical implications for Monaco-based companies operating in the construction sector, property developers and real estate professionals, who should ensure that their subcontracting agreements, invoicing and VAT reporting obligations are treated appropriately. 📌 Reference: BOFiP, BOI-RES-TVA-000269, 9 September 2026.
2026-09-11
Monaco: Bill establishing the proposed 2026 Amended State Budget submitted
Monaco: Bill establishing the proposed 2026 Amended State Budget submitted On 30 June 2026, the Princely Government submitted Bill no. 1,127 establishing the Amended State Budget for the 2026 financial year. The Bill revises the revenue and expenditure forecasts set out in the 2026 Initial Budget to reflect changes in the economic environment and the progress of public projects. Revenue revised downwards By way of background, Law no. 1,586 of 19 December 2025 established Monaco’s Initial State Budget for the 2026 financial year. Budget revenue was initially estimated at €2.217 billion, compared with €2.489 billion under the 2025 Amended Budget, representing a decrease of approximately 11%. The 2026 Amended Budget now forecasts revenue of €2.145 billion. This represents a reduction of €71.9 million, or 3.3%, compared with the Initial Budget. The decrease mainly results from lower tax receipts, particularly net Monaco VAT revenue and business profits tax. This reduction is nevertheless partly offset by increases in: State property income and revenue; revenue generated by administrative services. Expenditure also adjusted Budget expenditure has been reduced to €2.139 billion, compared with €2.208 billion under the Initial Budget. This represents a decrease of almost €69 million, or 3.1%. The overall adjustment reflects two contrasting developments. Increase in ordinary expenditure Ordinary expenditure has increased by €42.4 million, representing a 3% rise compared with the Initial Budget. This increase is mainly attributable to higher operating expenditure and public interventions. Reduction in capital and investment expenditure Capital and investment expenditure has been reduced by €111.5 million, or 14%. This decrease notably results from the postponement or rescheduling of several major projects, leading to a revision of the timetable for expenditure initially planned for 2026. The proposed 2026 Amended State Budget provides for a surplus Despite the reduction in revenue and the adjustment of expenditure, the proposed 2026 Amended Budget provides for a positive balance. The projected surplus, initially set at €8.8 million in the Initial Budget, has been revised to €5.9 million. The proposed Amended Budget therefore confirms the continued balance of Monaco’s public finances, notwithstanding lower projected tax revenue and changes to the public investment timetable. Improved position of the Special Treasury Accounts The Special Treasury Accounts also show an improved financial position. Their overall balance, initially projected to record a deficit of €2.7 million under the Initial Budget, would become a surplus of €2 million under the proposed 2026 Amended Budget. Key figures from the proposed 2026 Amended Budget Revenue: €2.145 billion Expenditure: €2.139 billion Projected surplus: €5.9 million Reduction in revenue compared with the Initial Budget: €71.9 million Reduction in expenditure compared with the Initial Budget: almost €69 million Special Treasury Accounts balance: +€2 million Bill no. 1,127 will now continue through Monaco’s legislative process.
2026-09-11
Monaco: Bill establishing the proposed 2026 Amended State Budget submitted
Monaco: Bill establishing the proposed 2026 Amended State Budget submitted On 30 June 2026, the Princely Government submitted Bill no. 1,127 establishing the Amended State Budget for the 2026 financial year. The Bill revises the revenue and expenditure forecasts set out in the 2026 Initial Budget to reflect changes in the economic environment and the progress of public projects. Revenue revised downwards By way of background, Law no. 1,586 of 19 December 2025 established Monaco’s Initial State Budget for the 2026 financial year. Budget revenue was initially estimated at €2.217 billion, compared with €2.489 billion under the 2025 Amended Budget, representing a decrease of approximately 11%. The 2026 Amended Budget now forecasts revenue of €2.145 billion. This represents a reduction of €71.9 million, or 3.3%, compared with the Initial Budget. The decrease mainly results from lower tax receipts, particularly net Monaco VAT revenue and business profits tax. This reduction is nevertheless partly offset by increases in: State property income and revenue; revenue generated by administrative services. Expenditure also adjusted Budget expenditure has been reduced to €2.139 billion, compared with €2.208 billion under the Initial Budget. This represents a decrease of almost €69 million, or 3.1%. The overall adjustment reflects two contrasting developments. Increase in ordinary expenditure Ordinary expenditure has increased by €42.4 million, representing a 3% rise compared with the Initial Budget. This increase is mainly attributable to higher operating expenditure and public interventions. Reduction in capital and investment expenditure Capital and investment expenditure has been reduced by €111.5 million, or 14%. This decrease notably results from the postponement or rescheduling of several major projects, leading to a revision of the timetable for expenditure initially planned for 2026. The proposed 2026 Amended State Budget provides for a surplus Despite the reduction in revenue and the adjustment of expenditure, the proposed 2026 Amended Budget provides for a positive balance. The projected surplus, initially set at €8.8 million in the Initial Budget, has been revised to €5.9 million. The proposed Amended Budget therefore confirms the continued balance of Monaco’s public finances, notwithstanding lower projected tax revenue and changes to the public investment timetable. Improved position of the Special Treasury Accounts The Special Treasury Accounts also show an improved financial position. Their overall balance, initially projected to record a deficit of €2.7 million under the Initial Budget, would become a surplus of €2 million under the proposed 2026 Amended Budget. Key figures from the proposed 2026 Amended Budget Revenue: €2.145 billion Expenditure: €2.139 billion Projected surplus: €5.9 million Reduction in revenue compared with the Initial Budget: €71.9 million Reduction in expenditure compared with the Initial Budget: almost €69 million Special Treasury Accounts balance: +€2 million Bill no. 1,127 will now continue through Monaco’s legislative process.