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 imposes functional and accounting separation obligations on operators with SMP-equivalent status, referred to in the Law on Electronic Communications as operators holding a “dominant position.” Under Arts. 22–23, the regulator determines which operators or service providers are dominant in the relevant electronic communications markets. Pursuant to Art. 36(2), each dominant operator must maintain separate accounts in a form that enables the regulator to assess compliance with interconnection obligations. In addition, Art. 24 empowers the regulator to require dominant operators or dominant service providers to provide competitive services through fully separated subsidiaries or affiliates, to implement structural separation between dominant and competitive activities, and to adopt other separation safeguards where necessary to protect competition.

Armenia has not appended the World Trade Organization (WTO) Telecom Reference Paper to its schedule of commitments.

The Public Service Regulatory Commission of the Republic of Armenia (PSRC), established under the Law on Public Services Regulation of 2003, serves as the executive authority responsible for supervising and administering telecommunications services. The PSRC is reportedly independent from the government in its decision-making processes.

Section I, Clause 3 of Government Decree No. 1521-N prescribes obligations for the official websites of governmental agencies. Although the provision does not explicitly mandate that such websites be hosted within the territory of the Republic of Armenia, it strongly implies this requirement through several stipulations. Specifically, it designates hosting to be undertaken by state bodies, internet service providers operating within Armenia, or the National Security Service (RA NSS). In addition, the requirement for prior coordination and approval by the RA NSS for both hosting and publication indicates that hosting should remain under the jurisdiction of Armenian authorities. The decree neither references nor provides exceptions for hosting outside the Republic of Armenia.

Section 3 of Decision No. 884‑L stipulates that, where state information systems, data, and information under the control of public administration bodies are hosted in a cloud environment located outside Armenia, a backup copy must be retained within Armenia, using the minimum necessary server infrastructure. In addition, Section 9 of the Annex provides that, when selecting a cloud environment for hosting an official website, preference shall, all other conditions being equal, be given to server infrastructure located within Armenia.

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.

According to Art. 6 of the Law on Patents of the Republic of Armenia, foreign natural persons and organisations enjoy the same rights and bear the same liabilities as citizens and organisations of Armenia, in line with international treaties or the principle of reciprocity.
Under Art. 80.1, those without a permanent residence or an effective industrial or commercial establishment in Armenia must act through a representative before the state-authorised body, unless otherwise provided by international treaties. However, Art. 80.3 allows foreign applicants to proceed without a representative if they provide a postal or electronic address in Armenia for correspondence. If neither a representative nor a local address is provided, the authority grants three months to comply, after which, under Art. 80.5, the application is deemed withdrawn.
Formal registration is reportedly straightforward and clear; the database of registered IPR is public, and applications to register IPR are published online for 2 months for third-party comment.

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 the Personal Data Protection Agency provides oversight 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.

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

It is reported that the Eurasian Economic Union, which includes Armenia, imposed definitive anti-dumping duties on imports of aluminium strip (HS code subheadings 7606.11.91.00, 7606.12.20.09 and 7606.12.92.09) originating in Azerbaijan and China on 24 October 2020. The duty rate applicable to imports from Azerbaijan was set at 16.18%, while the corresponding rate for imports from China was established at 13.14%. On 17 October 2025, the Eurasian Economic Union published a notice extending the application of these definitive duties until 29 June 2026. These products are used to manufacture components for ICT goods, including heat sinks, printed circuit boards (PCBs), charging cables, HDMI cables, and displays.

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.

Pursuant to Section 9 of the Annex to Decision No. 884-L of 14 June 2024 on the Development and Implementation of the “Cloud First” Policy, when selecting a cloud environment for hosting an official website, preference must be given, all other conditions being equal, to server infrastructure located within Armenia.