Under Art. 27 of Law No. ZR-49, personal data may be transferred to another country with the data subject’s consent or where such transfer is necessary for, or arises from, the purposes of processing personal data. Transfers may occur without the Agency’s authorisation if the destination state ensures an adequate level of data protection, either through compliance with ratified international treaties or inclusion in a list published by the competent authority, which the Personal Data Protection Agency (PDPA) must review and update at least annually; as of July 2024, this list includes, among others, all EU Member States and the United States. Transfers to states lacking adequate protection require prior authorisation from the Agency, based on an agreement containing safeguards approved by the Agency as ensuring adequate protection. To obtain such authorisation, the data processor must submit a written application to the PDPA specifying the destination country, recipient details, a description of the personal data, the purposes of processing and transfer, and the relevant contract or draft contract.

Armenia has not joined any agreement with binding commitments to open transfers of data across borders.

Law No. 49-ZR establishes a comprehensive data protection regime in Armenia, applicable to both public and private entities. It imposes obligations on data controllers, such as notifying data processing activities and reporting data breaches, but does not require the appointment of a data protection officer or the conduct of data protection impact assessments. Data subjects are granted only limited rights, and oversight is provided by the Personal Data Protection Agency under the Ministry of Justice. Additionally, several sector-specific laws impose tailored data protection obligations, including the Law on Medical Care and Services to the Population, the Law on Electronic Communications, the Law on Advocacy, the Law on Freedom of Information, the Law on Banking Secrecy, the Law on Circulation of Credit Information and Activities of Credit Bureaus, the Law on Insurance and Insurance Activity, the Law on Combating Money Laundering and Terrorism Financing, the Labour Code, the Code on Administrative Offences, and the Criminal Code.

A basic legal framework on intermediary liability for copyright infringement is absent in Armenia's law and jurisprudence.

A basic legal framework on intermediary liability beyond copyright infringement is absent in Armenia's law and jurisprudence.

It is reported that there is an obligation for passive infrastructure sharing in Armenia to deliver telecom services to end users. It is reported that infrastructure sharing is practised in the mobile sector based on commercial agreements.
According to Art. 25 of Law No. HO-176-N of 2005 on Electronic Communications, dominant operators holding a line facility are required to lease their capacity to other operators on equal and non-discriminatory terms. They must publish information on the location and available capacity of their line facilities and respond to written requests for leasing within 14 days. The law further obliges dominant operators to ensure that all conditions and requirements for the use of a line facility are identical for every operator, thereby preventing preferential treatment. Under Art. 2 of the law, a “line facility” is defined as the part of a public electronic communications network permanently attached to the land or the bottom of a body of water, including, but not limited to, cables, wires, conduits, ducts, radio towers or pole attachments, and the necessary cross-connections.

The government holds a 20% minority stake in Viva Armenia, the country’s major mobile operator. This shareholding originated in 2024, when Fedilco Group Limited, having acquired Viva Armenia from the Russia-based MTS, transferred a 20% stake to the Armenian government as a gift. Although the government has reportedly expressed plans to divest this share, it currently retains ownership.

Armenia mandates functional and accounting separation for operators with significant market power (SMP) in the telecom market.

Armenia is not a signatory of the 1996 World Trade Organization (WTO) Information Technology Agreement (ITA) nor the 2015 expansion (ITA II).

Tendering processes in the country are reportedly characterised by a lack of transparency. Companies consider the efforts of the Competition Protection Commission (CPC) alone to be insufficient to ensure a level playing field, emphasising the need for improvements across other state institutions and authorities that support competition, including those responsible for public procurement. Stakeholders report that the time allowed for preparing bids following the announcement of a tender is often limited, and that documentation requirements, particularly those involving translations, can be burdensome for companies operating outside Armenia.
It is reported that although the law establishes a preference for open tendering in procurement processes, this approach has been used relatively infrequently in recent years, with greater reliance placed on framework agreements and negotiation procedures without prior announcement.

Armenia is a party to the World Trade Organization (WTO) Agreement on Government Procurement (GPA) but its commitments do not cover some services sectors considered most important for digital trade, namely telecommunication services (CPC 752), telecommunication-related services (CPC 754), and computer and related services (CPC 84).

The legal framework regulating foreign investment in Armenia is set out in the Law of the Republic of Armenia on Foreign Investments. Under Art. 6, foreign investments must not be treated less favourably than the property, property rights, and investment activities of citizens, enterprises, institutions, and organisations of Armenia. Art. 6.3 provides that, for national security reasons, the Republic of Armenia may specify areas in which the activities of foreign investors and enterprises with foreign participation are restricted or prohibited. Nevertheless, Armenia is reported to impose few restrictions on foreign control, and foreign nationals face no limitations on acquiring, establishing, or disposing of business interests in the country, while business registration procedures are generally straightforward.

Armenia is a party to the Patent Cooperation Treaty (PCT).

Armenia has a copyright regime under the Law of the Republic of Armenia on Copyright and Related Rights. However, the exceptions do not follow the fair use or fair dealing model, thereby limiting the lawful use of copyrighted works by others. Arts. 22–26 and 36 set out the exceptions, including quotation for research or informational purposes, educational use, private non-commercial reproduction of works (with certain exclusions), and short-term recordings by broadcasting organisations, among others.
It has been reported that a new Law on Copyright has been drafted and submitted for the government’s approval, although the legal text is not publicly available online.

Although Armenian legislation provides protection for intellectual property rights (IPR), enforcement remains challenging. It is reported that Armenia has the highest rate of unlicensed software in the region, with an estimated 79%, followed by the Republic of Moldova (77%) and Belarus (76%). While the Armenian government has made some progress in addressing IPR issues, further strengthening of enforcement mechanisms is reportedly necessary.