Bhutan is not a party to the World Trade Organization (WTO) Agreement on Government Procurement (GPA). In fact, the country is not a member of the WTO.

Pursuant to Section 4 of the Foreign Direct Investment Regulations 2025, foreign direct investment is permitted in all sectors except those enumerated in Schedule III. This schedule encompasses, inter alia, news media and “activities included in the Prohibited List of the Royal Government.” The latter list could not be found online, and therefore, it remains uncertain whether the activities specified in Schedule IV extend to the digital domain.

Section 5 of the Foreign Direct Investment Regulations 2025 distinguishes between: (1) “Priority Sector Activities” in the manufacturing and service sectors listed in Schedules I and II; and (2) “Other Activities” not listed in those Schedules. Under Section 7, for “Other Activities”, the maximum foreign investor shareholding is capped at 74% equity. The limit, therefore, applies to virtually all sectors of the economy. Moreover, there is an explicit cap of 74% for the manufacturing of electronics (schedule I) and for cross-border electronic payments and money transmission services (schedule II).
In addition, the Regulations permit FDI in an existing domestic entity on the same terms and conditions applicable to new entities, subject to the same 74% cap on foreign investor shareholding.

Under Sections 59–60 of the Foreign Direct Investment Rules and Regulations 2025, the FDI process begins with an online registration application for activities open to FDI. Applicants must demonstrate compliance with the prescribed minimum investment thresholds and shareholding structures and submit the required supporting documentation, including corporate documents, investor identification documents, and, where applicable, the curriculum vitae of a local partner.
The application is then subject to administrative review and clearance. Under Sections 77–79, the Department of Industry (DoI) reviews and approves FDI projects and coordinates the required sectoral clearances, while the Invest Bhutan Division is authorised to expedite and approve priority sector proposals within three working days upon receipt of complete documentation. Sections 80–81 provide that proposals must be rejected where they do not meet the approval criteria, fail to comply with the Rules or other applicable laws, or where sectoral clearance is denied. Following approval, Section 84 requires the investor to obtain an online business licence within one month of project approval.
Finally, the Rules include localisation-related constraints on the use of foreign labour. Under Sections 46–47, FDI companies may apply for work permits for foreign professional and non-professional expatriates during the establishment and operational phases only where qualified and experienced Bhutanese personnel are not available, and recruitment must comply with applicable labour and immigration requirements. The Rules also encourage FDI companies to recruit and develop Bhutanese nationals.

Section 5 of the Foreign Direct Investment Regulations 2025 distinguishes between: (1) “Priority Sector Activities” in the manufacturing and service sectors listed in Schedules I and II; and (2) “Other Activities” not listed in those Schedules. In practice, “Other Activities” operates as a residual category covering most sectors. For these activities, the minimum project cost is BTN 50 million (approx. USD 530,000) in the manufacturing sector and BTN 25 million (approx. USD 265,000) in the service sector (Section 7).

Pursuant to Section 6 of the Foreign Direct Investment Regulations 2025, the minimum project cost for priority sector activities is set out in Schedules I and II. Under these Schedules, the minimum project cost for FDI in IT park development activities is BTN 200 million (approx. USD 2,140,000), while in the manufacturing sectors of electronics and electrical equipment, the minimum project cost is BTN 40 million (approx. USD 420,000).

According to Sections 143 and 144 of the Bhutan Information, Communications and Media Act 2018, foreign direct investment (FDI) in the ICT and media sector may be approved by the Cabinet, taking into account all relevant circumstances, including national interest and the prevailing FDI policy. On the basis of a written government policy, the Bhutan InfoComm and Media Authority (BICMA) is then empowered to issue licences permitting the participation of foreign companies in the ICT and media sector, subject to such terms and conditions as it may determine from time to time.
Section 464 of the Act further defines the scope of ICT services. These include: (i) telecommunications services, such as public telephony, telegraphy, facsimile, cellular telephony, and pay-phone/communication services; (ii) broadcasting services, including mobile satellite and subscription broadcasting; (iii) information technology services, such as internet services, webcasting, e-mail, and other electronic services; (iv) Internet Protocol (IP) telephony; (v) digital library and commercial information services; and (vi) network-based information and related specialised professional services provided by electronic means, public switched data, and other similar services.

Armenia has not signed the United Nations (UN) Convention on the Use of Electronic Communications in International Contracts.

Armenia has not adopted national legislation based on or influenced by the United Nations Commission on International Trade Law (UNCITRAL) Model Law on Electronic Commerce.

Armenia has not adopted national legislation based on or influenced by the United Nations Commission on International Trade Law (UNCITRAL) Model Law on Electronic Signatures.

Armenia lacks a comprehensive consumer protection framework specifically applicable to online transactions. The existing regime, established under the Law of the Republic of Armenia on the Protection of Rights of Consumers (2001) and Law on Trade and Services (Chapter 4.1), provides general consumer protection provisions; however, it is reported that these are not comprehensively applicable to the context of online commerce.

Appendix No. 2 to the Decision No. 30 of the Eurasian Economic Commission Board "On Measures of Non-tariff regulation" sets out the Union-wide list of goods restricted for import into the customs territory of the Eurasian Economic Union (EAEU), including Armenia. The list includes, among others, (i) radio-electronic and high-frequency equipment for civilian use—devices for transmitting or receiving voice, images, or data (e.g., headings in HS 8471, 8517–8519, 8521, 8525–8528, 8531, and certain Chapter 90 items); (ii) systems and receivers for technical radio monitoring and for detecting sources of electromagnetic emissions (e.g., HS 8526–8527); and (iii) encryption (cryptographic) means, including computing machines and parts with cryptographic functions, computer devices incorporating encryption, and standalone cryptographic software (selected subheadings of HS 8471/8473 and 8523).
In addition, Armenia’s Decision No. 1524-N of 25 December 2014 approves the national list of goods subject to restrictions and links these categories to the relevant annexes of EAEU Board Decision No. 30 of 21 April 2015. In the Armenian text, section 2.16 covers radio-electronic and/or high-frequency devices for civil use, section 2.17 covers special technical means for obtaining confidential information, and section 2.19 covers encryption or cryptographic means.

Businesses in Armenia reportedly face a lack of clarity in requirements such as import licensing and customs procedures, particularly since the country’s accession to the Eurasian Economic Union (EAEU) and the adoption of the EAEU Customs Code. The unpredictable and inconsistent application of customs rules is perceived as a barrier to trade. Both local and foreign business representatives note that cumbersome, ambiguous legislation, combined with inconsistent implementation, continues to pose significant obstacles to dealings with customs authorities. This situation has historically fostered an environment in which facilitation payments or bribes have been solicited.

Appendix No. 2 to the Decision No. 30 of the Eurasian Economic Commission Board "On Measures of Non-tariff regulation" sets out the Union-wide list of goods restricted for export from the customs territory of the Eurasian Economic Union (EAEU), including Armenia. The list includes, among others, (i) radio-electronic and high-frequency equipment for civilian use—devices for transmitting or receiving voice, images, or data (e.g., headings in HS 8471, 8517–8519, 8521, 8525–8528, 8531, and certain Chapter 90 items); (ii) systems and receivers for technical radio monitoring and for detecting sources of electromagnetic emissions (e.g., HS 8526–8527); and (iii) encryption (cryptographic) means, including computing machines and parts with cryptographic functions, computer devices incorporating encryption, and standalone cryptographic software (selected subheadings of HS 8471/8473 and 8523).