Monthly Legal Overview (September 2026)

99 AVOCATS ASSOCIÉS is pleased to present a review (selection) of legal developments concerning the Principality of Monaco, including at international level, in September 2026 (texts published in the Journal de Monaco, legislative work and other publications). and events in which its team took part.

OUR EVENTS

◾Annual Wealth Management Forum

Patricia KEMAYOU MENGUE, Head of the Company & Tax Department, took part in the 7th Annual Wealth Management Forum organised by Global Leaders Forum on 8 and 9 September in London. She co-moderated a panel discussion on "Asset Protection Strategies".

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◾International Conference on family law

Nathalie BLANGERO-BUISSON, Head of the Family Law Department, and Cécile MÉMETEAU FASSI, Senior Associate, took part in the 19th International Conference on “Family Law and Vulnerability” organised by the International Society of Family Law (ISFL), which took place from 9 to 12 September at Pîrî Reis University in Istanbul.

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◾Presentation on international sanctions in the maritime sector

On 22 September, 99 AVOCATS ASSOCIÉS (Paul TOMATIS), in collaboration with Norton Rose Fulbright (Philip ROCHE) and Bureau Veritas (Julien RAYNAUT), gave a presentation to members of the Monaco Club of Foreign Residents (CREM) entitled "International sanctions in the maritime sector: shipping & yachting".

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◾DPO Forum Monaco 2026

On 24 September, our associates Laurie BOUCHER and Anne ROBERT took part in the first DPO Forum Monaco, which brought together professionals from the fields of personal data protection, artificial intelligence and digital security.

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◾Moderation of a Conference on Monegasque company law

On 28 September, Grégoire GAMERDINGER, Lawyer Partner, and Victor BARDAWIL, Senior Associate of the Company & Tax Department, led a conference organised by the Monaco Economic Board (MEB), in partnership with the Order of Chartered Accountants of Monaco, on the topic of "Company law reform in Monaco (Law No. 1573): what impact on management?".

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TEXTS PUBLISHED IN THE JOURNAL DE MONACO

PUBLIC

◾Amendments to the regulations governing establishments and services catering for children under the age of six (nurseries, drop-in crèches, kindergartens, micro-nurseries)

Ministerial Order No. 2026-492 of 3 September 2026 and Erratum (JDM No. 8816 of 11 September 2026, and No. 8818 of 25 September 2026) amended Ministerial Order No. 2010-154 of 24 March 2010: new professionals are eligible to manage a facility or service providing childcare for children under the age of six (provided they hold a state-recognised qualification as a midwife, nurse, social work assistant, special needs teacher, social and family economics adviser or psychomotor therapist, or a DESS or Master II in psychology), provided that they also hold a three-year higher education qualification in management or leadership, or have three years’ experience in management or leadership within an early years childcare centre or service.

◾Amendments to the regulations governing taxis

Ministerial Orders No. 2026‑514 and No. 2026-515 of 10 September 2026, No. 2026-535 and No. 2026-536 of 17 September 2026 (JDM No. 8817 of 18 September 2026) provide, respectively, for:

• the submission of applications for authorisation by foreign taxi operators via an online service open from 1 October to 15 December;
• a change to the composition of the Advisory Committee for the granting of administrative authorisation to operate a taxi service (two representatives of the profession may be appointed by the Minister of State, instead of the President of the Association of Independent Taxi Operators of Monaco, who previously sat on the committee by right);
• the new flat-rate fares for taxis operating on a seasonal basis and during the Formula One Grand Prix period, and the new requirement to display a visible QR code inside the vehicle showing the fixed fares;
• the conditions for applying for a seasonal taxi licence in the absence of professional experience (certificate of successful completion of the professional qualification exams dated within the last year);
• the criteria for awarding licences to Monegasque nationals, and on a seasonal basis.

◾Increase in the basic index-linked salary for the civil service

Ministerial Order No. 2026-534 of 17 September 2026 (JDM No. 8817 of 18 September 2026) increased the basic index-linked salary corresponding to index 100 for civil servants of the Monaco State and Town to an annual sum of €8,406.04 €, with effect from 1 September 2026 (compared with €8,241.22 since 1 May 2026, representing a 2% increase: €164,82).

◾Notice inviting applications for inclusion in the register of economic operators standing for public works contracts awarded by the State

The State has published (JDM No. 8816 of 11 September 2026) a call for applications for inclusion in the register of economic operators standing for public works contracts, in particular for construction and/or maintenance (Article 23 of Sovereign Order No. 7.264 of 20 December 2018, Title I of Ministerial Order No. 2022-708 of 12 December 2022). The application pack must be requested by 9 October 2026 at the latest, and submitted, duly completed with all the required supporting documents, by 23 November 2026 at the latest, to the Direction des Travaux Publics (Public Works Directorate).

◾Notice of Invitation to Tender for the award of a public service contract

The State has published a Notice of Invitation to Tender for the award of a public service contract entitled "Restoration and monitoring of engineering structures" listed as part of the Principality’s heritage (JDM No. 8817 of 18 September 2026). The deadline for the submission of applications and tenders is 30 October 2026, 12 noon (Sovereign Order No. 7.264 of 20 December 2018).

HEALTH

◾Healthcare establishment: cooperation protocols authorising a nurse to carry out activities or procedures usually reserved for doctors

Ministerial Order No. 2026–523 of 17 September 2026 (JDM No. 8818 of 25 September 2026) inserted new Articles 38-2 to 5 into Ministerial Order No. 2011 –73 of 16 February 2011, which sets out the professional procedures that may be carried out by medical auxiliaries, as amended, and which governs the establishment and implementation by a healthcare establishment of one or more cooperation protocols allowing, by way of derogation, a nurse to carry out medical activities or procedures usually reserved for a doctor

TAXATION

◾Chair of the Advisory Committee responsible for examining disputes arising from the basis of assessment for corporation tax (ISB)

Sovereign Order No. 12.131 of 17 September 2026 (JDM No. 8818 of 25 September 2026) renews the appointment of Mr Thierry DESCHANELS, a Judge at the Court of First Instance, in his capacity as Chairman of the Advisory Committee ("Commission Consultative chargée d'examiner les litiges auxquels peut donner lieu l'assiette de l'impôt sur les bénéfices"), for a term of three years, with effect from 20 October 2026, pursuant to Article 27 of Sovereign Order No. 3.152 of 19 March 1964.

The Advisory Committee also comprises the Director of Tax Services or his delegate, a representative of the Department of Finance and Economic Affairs, as well as two full members representing businesses or companies whose activities are subject to ISB and two alternate members.

LEGISLATIVE WORK

FAMILY LAW • PRESS • JUDICIARY

◾Upcoming Bills on Civil Union for same-sex souples and children, professional journalists, Bill No. 1087 on remote biometric identification

At its Back-to-Work Conference on 17 September (Government News of 18 September 2026), the Government reiterated that "by the end of the year", a bill would be submitted to the Parliament "establishing a Civil Union open to same-sex couples, modeled after the systems in a number of neighboring countries, notably the Italian model, and conferring rights and obligations equivalent to those of marriage, particularly with regard to the moral and material management of the family and the obligation to live together. This civil union contract will be accompanied by a reform of family law for children raised in these families, covering the establishment of parentage, recognition, adoption, and the recognition of parentage established abroad."

Another bill (parliamentary Draft law No. 275 follow-up) concerning the journalism profession will also be submitted.

Finally, the Government has stated that it is “working” on Bill No. 1087 on the remote biometric identification of wanted or reported individuals in public places (already submitted to the Parliament), “which may provide police officers with more effective tools when it comes to analysing the images required for criminal investigations”.

OTHER PUBLICATIONS

BANKING & FINANCE

◾CCAF: 2025 Annual Report

On 23 September, the Commission for the Supervision of Financial Activities (CCAF) published its 2025 Annual Report on developments in the financial centre, its activities, its international relations, and the regulation of financial activities in Monaco.

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AML/CFT-P

◾AMSF: 2025 Activity Report

On 4 September, the Monegasque Financial Security Authority (AMSF) published its 2025 Activity Report on the fight against money laundering, terrorist and proliferation financing (AML/CFT-P).

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◾Meeting of the Coordination and Monitoring Committee for the National AML/CFT-P Strategy

On 10 September, the first panel of the Coordination and Monitoring Committee for the National AML/CFT-P Strategy reviewed progress on the process of being removed from the FATF grey list following the fourth progress report adopted last June, the forthcoming third National Risk Assessment (NRA) and MONEYVAL assessment (Government press release of 11 September 2026).

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PERSONAL DATA PROTECTION

◾APDP : Opinion on the Ministerial Order implementing the specific provisions on video surveillance of Law No. 1.565

Deliberation No. 2026-17 of 16 September 2026 of the Monegasque Personal Data Protection Authority (APDP) sets out its opinion on the draft Ministerial Order implementing Articles 83 to 85 (Processing relating to video surveillance) of Law No. 1.565 of 3 December 2024 on the protection of personal data.

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ADMINISTRATIVE • Environment • Vehicles

◾Prohibition on the supply, whether for a fee or free of charge, of disposable plastic containers, receptacles and packaging

Since 1 September, a ban has been in force in Monaco on the provision of boxes, trays, meal trays and salad bowls used to contain foodstuffs ready for consumption on the premises or for takeaway with a Use-by Date (UBD) of a maximum of 3 days or packaged for sale. Containers for fresh, cut and unprocessed fruit are exempt. Coatings made of PE (polyethylene), PLA (polylactic acid) or equivalent are permitted (Article A.431-2-2, fourth paragraph, 4°) of the Environment Code).

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◾Renewal of vehicle registration for 2027

The period for completing the procedures to renew vehicle registration for 2027 runs from 1 September to 31 December 2026. From now on, the certificate of payment for registration renewal issued by the Vehicle Registration Authority, which must be kept in the vehicle, replaces the physical stamp that used to be affixed to the number plate (Government press release of 2 September 2026).

SOCIAL

◾Reduction in the duration of benefits for jobseekers whose employment contract has ended following a mutually agreed termination ("rupture conventionnelle")

Since 1 September, the maximum duration of unemployment benefit following an individual contractual termination (RCI) has been set at 15 months for those under 55 (compared with 18 months at present) and at 20.5 months for those over 55 (compared with 22.5 months at present for those aged 55–56 and 27 months from the age of 57), although older workers may apply for an extension of their benefits, which will be assessed on a case-by-case basis (French Law No. 2026-470 of 11 June 2026).

This measure applies to employees in Monaco whose job loss results from a contractual termination as defined by Law No. 1.583 of 2 December 2025 and who are entitled to the return-to-work assistance allowance (ARE) funded by the French organisation UNEDIC.

JUSTICE

◾Judicial year and formal opening ceremony 2027

The judicial year will now begin on 1 January (rather than 1 October) each year, and the formal opening ceremony of the judicial year, preceded by the Mass of the Holy Spirit, will take place in January (on Monday 18 January 2027), in order to “optimise the budgetary and statistical reviews of the past year by enabling the finalisation of comprehensive and consolidated annual figures and statistics, which will be presented during the opening address.” (Directorate of Judicial Services Statement of 25 September 2026).

EUROPEAN UNION • Customs Union

◾New European Union Customs Code

Regulation (EU) 2026/2108 of 16 September 2026 establishing the new Union Customs Code (UCC recast) (OJEU of 19 September 2026), applicable from 21 September 2027, aims to strengthen and modernise the EU customs union: establishment of the EU Customs Authority (EUCA) to unify the actions of national customs authorities; centralisation and analysis of data submitted by businesses via the EU Customs Data Hub, a single interface that will replace existing national customs IT systems; centralised customs clearance; new arrangements for e-commerce; increased responsibility for the "importer"; new status "Trust & Check Trader".

In accordance with the Franco-Monegasque Customs Convention of 18 May 1963, the territory of Monaco is considered to form part of the customs territory of the European Union.

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INTERNATIONAL

◾New numbering scheme for new mobile lines, allocated exclusively with Monaco’s international dialling code +377

From 1 October 2026, the format of mobile numbers allocated to new lines in the Principality of Monaco will be exclusively Monegasque “+377 377 xx xxx”, “in accordance with the new bilateral protocols concluded between the Principality Government’s Directorate of Digital Platforms and Resources and the French Regulatory Authority for Electronic Communications, Postal Services and Press Distribution (Arcep)”. Mobile numbers for existing lines beginning with 06 will be retained (Government press release of 23 September 2026).

◾eATA Carnet (customs formalities): destinations that have gone 100% digital

Since September, Monegasque businesses have to use the eATA Carnet (a "goods passport" authorizing the temporary movement of goods duty and tax-free within countries that are signatories to the Brussels Customs Convention on the A.T.A. Carnet of 6 December 1961 and/or the Istanbul Convention on Temporary Admission of16 June 1990) for shipments to Switzerland, the United Kingdom, Norway, and the majority of French Overseas Departments and Regions (DROM) or Overseas Collectivities (COM). These destinations have transitioned to a 100% digital system, meaning that the paper backup carnet is no longer a valid alternative (Monaco Economic Board (MEB) publication of 2 September 2026).

◾Cooperation with the European Patent Office (EPO) and adaptation of Monegasque law

During the EPO President’s visit to Monaco on 28 September, discussions centred on the digital transformation of industrial property services, in particular “the opportunity for Monaco to make use of the Front Office platform developed by the EPO, an online filing solution already adopted or in the process of being adopted by 20 Member States”, and “changes to Monaco’s industrial property framework that could be envisaged”, such as “the adaptation of the regulatory framework, the incorporation of certain recommendations arising from the EPO’s programme on the convergence of practices (...), legislative changes likely to bring the Monegasque system into line with international standards and the European Patent Convention (EPC), whilst enhancing its accessibility and legal certainty” (Government press release of 29 September 2026).

◾Ratification of the Convention on the Bureau of the European Civil Aviation Conference (ECAC)

On 4 September, Monaco ratified the Convention on the Bureau of the ECAC (Government news of 10 September 2026), an intergovernmental organisation established in 1955 on the initiative of the Council of Europe with the support of the International Civil Aviation Organization (ICAO), aimed at promoting the development of a safe, efficient and sustainable European air transport system and to harmonise policies and practices in the field of civil aviation amongst its 44 member States, of which Monaco has been a member since June 1989.

The role of the CEAC Bureau, established to replace the CEAC Secretariat, will be to support its activities and ensure the implementation of decisions adopted by the Directors-General of Civil Aviation of its member states.

◾81st session of the United Nations General Assembly (UNGA)

Monaco’s address to the General Debate of the 81st session of the UNGA on 25 September focused on: 1. trust, the currency of multilateralism; 2. peace, the rule of law and the protection of civilians; 3. the transformation of the UN; 4. the oceans, a common cause for humanity, 5. the climate, the 2030 Agenda and technological transformations (towards a Global Digital Pact and an international regulatory framework for artificial intelligence) (Government press release of 29 September 2026).

◾70th Annual General Conference of the International Atomic Energy Agency (IAEA)

As part of the Scientific Forum - "Rays of Hope: Delivering on the Promise of Cancer Care", the flagship event of the 70th IAEA General Conference, Monaco signed an agreement on 16 September with the Director General of the IAEA, "intended to strengthen the Principality’s long-term support for access to radiotherapy in countries where it remains insufficiently available" (Government press release of 18 September 2026).

The IAEA’s Marine Environment Laboratories, based in Monaco since 1961, which "will have access to larger premises" from 2027, estudying primarily marine radioactivity, pollution, climate change and their effects on the oceans, seas and the organisms living there (Headquarters agreement of 16 May 1986, amended by Addendum of 27 November 2024).

◾Participation in the International Space Summit

On 9 and 10 September, Monaco took part in the first International Space Summit in Paris (Government press release of 10 September 2026), which brought together heads of State and government, ministers, astronauts, space agencies, major players in the space industry and New Space start-ups.

The Summit addressed issues relating to the development and innovation of the space sector (the global space economy; advances in science, technology and space exploration; and space security).

◾Strengthening parliamentary cooperation between European small States

On 14 September, at the 19th Conference of Speakers of Parliament of the Small States of Europe (Conférence des Présidents de Parlement des Petits Etats d’Europe "CPPPEE"), Andorra, Cyprus, Iceland, Liechtenstein, Luxembourg, Malta, Monaco, Montenegro and San Marino signed a memorandum of understanding aimed at strengthening and structuring their cooperation on a long-term basis (establishment of a Secretariat, interim meetings, joint statements (common positions) to major inter-parliamentary bodies (Inter-Parliamentary Union (IPU), Parliamentary Assembly of the Council of Europe (PACE)), institutional and technical cooperation) (Monaco Parliament News, 15 September 2026).