Business Analyst Calls on Armenian Authorities to Clarify Legal Basis for Implementing IMEI Registration System
01.07.2026,
14:03
Tigran Jrbashyan, Director of Ameria's Management Consulting Service, called on Armenian authorities to provide legal grounds for implementing a state IMEI registration system.
YEREVAN, July 1. /ARKA/. Tigran Jrbashyan, Director of Ameria's Management Consulting Service, called on Armenian authorities to provide legal grounds for implementing a state IMEI registration system.
He stated that if the implementation of such a system truly stems from EAEU law or a binding act of the Eurasian Economic Commission, the number of that act and the specific provision establishing such an obligation for member states must be provided.
"If such a binding act does not exist, then why was this particular regulatory model chosen?" Jrbashyan asked.
He also did not rule out the possibility that one of the reasons could be the current structure of mobile phone re-exports from Armenia and the fact that a significant portion of these devices subsequently end up in markets where state registration or IMEI control mechanisms are in place, particularly in Russia.
Jrbashyan questioned why alternative regulatory models, including approaches used in most EU countries, were not presented and discussed.
"If such a legal requirement does not exist within the framework of EAEU law or mandatory acts of the EEC, then is it possible that the real goal of the proposed system is not so much the effective regulation of Armenia's domestic market as ensuring the continuity of re-exports from Armenia?" he stated.
He argued that if this version is even partially accurate, society has the right to a clear answer: why should regulation of Armenia's domestic market be based on potential foreign trade requirements, rather than primarily on the interests of citizens, consumers, and the country's domestic market.
Jrbashyan also noted that if one of the main goals of the bill is to prevent the use of stolen devices or phones with counterfeit IMEIs, then it should be explained why a less restrictive option was not considered.
Specifically, the bill calls for mobile operators to check the IMEI numbers of devices connected to the network against international databases and restrict service only to those devices deemed stolen or with invalid identifiers.
About the Bill
The bill amending the Law on Electronic Communications, adopted by the Armenian government on June 26, requires mobile operators to check IMEI codes when providing communications services.
According to the bill, anyone importing a mobile phone manufactured between 2025 and 2026 will be required to register the device, paying a state fee of 3,000 drams. Registration of older phones will be free.
At the same time, an increased fee is imposed for the import of additional phones within one year: 100,000 drams for a device manufactured in 2026 and 20,000 drams for a phone manufactured in 2025.
He stated that if the implementation of such a system truly stems from EAEU law or a binding act of the Eurasian Economic Commission, the number of that act and the specific provision establishing such an obligation for member states must be provided.
"If such a binding act does not exist, then why was this particular regulatory model chosen?" Jrbashyan asked.
He also did not rule out the possibility that one of the reasons could be the current structure of mobile phone re-exports from Armenia and the fact that a significant portion of these devices subsequently end up in markets where state registration or IMEI control mechanisms are in place, particularly in Russia.
Jrbashyan questioned why alternative regulatory models, including approaches used in most EU countries, were not presented and discussed.
"If such a legal requirement does not exist within the framework of EAEU law or mandatory acts of the EEC, then is it possible that the real goal of the proposed system is not so much the effective regulation of Armenia's domestic market as ensuring the continuity of re-exports from Armenia?" he stated.
He argued that if this version is even partially accurate, society has the right to a clear answer: why should regulation of Armenia's domestic market be based on potential foreign trade requirements, rather than primarily on the interests of citizens, consumers, and the country's domestic market.
Jrbashyan also noted that if one of the main goals of the bill is to prevent the use of stolen devices or phones with counterfeit IMEIs, then it should be explained why a less restrictive option was not considered.
Specifically, the bill calls for mobile operators to check the IMEI numbers of devices connected to the network against international databases and restrict service only to those devices deemed stolen or with invalid identifiers.
About the Bill
The bill amending the Law on Electronic Communications, adopted by the Armenian government on June 26, requires mobile operators to check IMEI codes when providing communications services.
According to the bill, anyone importing a mobile phone manufactured between 2025 and 2026 will be required to register the device, paying a state fee of 3,000 drams. Registration of older phones will be free.
At the same time, an increased fee is imposed for the import of additional phones within one year: 100,000 drams for a device manufactured in 2026 and 20,000 drams for a phone manufactured in 2025.