Anti-racism campaigners believe players are nearing the point when they will walk off the pitch if they continue to be subject to racist abuse, but concede it will be a "massive decision" to take.
UEFA has opened disciplinary proceedings against Montenegro, including a charge of racist behaviour which, if proven, "is punished with a minimum of a partial stadium closure", according to the regulations of European football's governing body.
Troy Townsend, head of development for anti-racism charity Kick It Out, questions whether UEFA is "brave enough" to go further and ban teams from competitions and feels players could take matters into their own hands if the issue does not improve.
"What I would like is stadium closures, expulsions from competitions, federations held accountable for not just the players but the supporters in their care," Townsend told Press Association Sport.
"Whether they're brave enough or not I will question that all day. But I think the first time that happens (tournament expulsion) will send a massive message out that this is not acceptable any more.
"At some point I do believe there will be a time when, if this continues, we will get to a stage where players will take the matter into their own hands and managers will do what is right for those players at that moment in time and consider the fact that maybe it's not worth it just for three points."
Napoli manager Carlo Ancelotti said he would take his players off the pitch the next time they were subject to abuse after Kalidou Koulibaly was targeted during a game with Inter Milan last year.
But asked if he should have taken his players off on Monday, England head coach Gareth Southgate said: "I'm not 100 per cent certain that that would be what the players would want.
"There would be a mix of views, in terms of when we've discussed the topic in the past, how the players would like it to be dealt with. And they just want to play football."
With points and ultimately qualification for major championships on the line, Townsend admits walking off the pitch will not be easy for players or managers.
"Whoever it is it will be a massive decision for anybody," he added. "Carlo Ancelotti said the next time it happens I will take the players off. That should be a threat to all the governing bodies who treat racism with disdain.
"And hopefully by taking the players off they are not penalised by the system which says you must complete a game of football and then tell us about the incident afterwards.
"You have to have a certain kind of mentality to go through with your convictions. If we continue to see things like Monday night, I don't think we're a million miles away from that."
Townsend praised the way Southgate and his players both handled the situation and spoke about it afterwards, partly a result of workshops Kick It Out has conducted with various England squads and staff members in recent years.
"People might think why would you prepare them for being racially abused and it's for incidents like last night," he added. "It's for incidents like winning the U-17 World Cup but then being racially abused after that tournament.
"I'm confident that our international players know how to deal with the situation, know what to expect when they're travelling abroad.
"Unfortunately we're having to prepare our players for the worst away from the playing side of it because back in 2011, when the Under-21s were out in Serbia, they were not prepared and the raw emotions that came out of that kind of incident has benefited us in terms of how we deal with it going forward."
UEFA, the Football Association and the Fare network are hosting an "Equal Game Conference" at Wembley on April 2-3 and Townsend is now trying to change his plans in order to be able to attend.
"I want to be in the room when people are putting their hands up and saying 'What happened last week? What are you going to do about the racial abuse that exists in our game?'
"I want to see people being uncomfortable in their response because it's an opportunity for people to really get into UEFA and say if you want a fair game, you need to up your game. "