Business Analyst: Fighting the Shadow Phone Market Shouldn't Start with Monitoring Citizens' IMEIs
06.07.2026,
10:31
The IMEI system proposed in Armenia, billed as a tool for reducing the shadow market, requires a comparative assessment of alternative solutions and an explanation of why this particular approach was chosen.
YEREVAN, July 4. /ARKA/. The IMEI system proposed in Armenia, billed as a tool for reducing the shadow market, requires a comparative assessment of alternative solutions and an explanation of why this particular approach was chosen. This was stated by Tigran Jrbashyan, Director of Management Consulting at Ameria.
According to him, the key problem with the shadow phone market is not the use of phones by citizens, but the illegal import and sale of devices.
"The primary focus of control should be trade turnover, not the device of each individual," Jrbashyan noted on social media.
He noted that international experience also offers other tools: digital product labeling, traceability from importer to final sale, automatic linking of fiscal receipts to products, as well as risk-based tax and customs controls.
In the case of stolen devices, he said, operators' Equipment Identity Register systems and the international GSMA Device Registry could be effective mechanisms.
Dzhrbashyan noted that this approach would allow for the control of legal imports, reduce opportunities for VAT evasion, ensure traceability of goods, and combat stolen devices without creating a system of mandatory state registration of all IMEI numbers.
The expert emphasized that the fight against the shadow market should not be limited to strengthening controls alone. It must be accompanied by the development of competition, consumer protection, and the increased attractiveness of official sales channels.
He added that if official sellers offer competitive prices, high-quality warranty and post-warranty service, and effective consumer protection, citizens' interest in purchasing phones through unofficial channels will naturally decline.
Dzhrbashyan noted that the best results are achieved not through restrictions alone, but by creating an environment in which buying a phone legally is more profitable and safer.
"If the primary goal of the proposed IMEI system is truly to reduce the shadow market, society has the right to see a comparative assessment of alternative solutions and the rationale for rejecting them before choosing a more restrictive model," the expert concluded.
About the Bill
The Armenian government has approved draft amendments to the Law on Electronic Communications, which stipulate mandatory verification of IMEI codes by mobile operators when providing communications services.
According to the draft, citizens importing a mobile phone manufactured in 2025-2026 into Armenia will be required to register the device by paying a state fee of 3,000 drams. Registration of older phones will be free.
A higher 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.
Expert Assessment
Experts expressed concerns about the proposed IMEI registration system.
Information security expert Artur Papyan stated that the initiative carries the risk of excessive data concentration on users and their devices.
Tigran Jrbashyan, Director of Management Consulting at Ameria, in turn, called on the authorities to present the economic and legal justification for the chosen regulatory model and clarify whether alternative approaches were considered.
According to him, the key problem with the shadow phone market is not the use of phones by citizens, but the illegal import and sale of devices.
"The primary focus of control should be trade turnover, not the device of each individual," Jrbashyan noted on social media.
He noted that international experience also offers other tools: digital product labeling, traceability from importer to final sale, automatic linking of fiscal receipts to products, as well as risk-based tax and customs controls.
In the case of stolen devices, he said, operators' Equipment Identity Register systems and the international GSMA Device Registry could be effective mechanisms.
Dzhrbashyan noted that this approach would allow for the control of legal imports, reduce opportunities for VAT evasion, ensure traceability of goods, and combat stolen devices without creating a system of mandatory state registration of all IMEI numbers.
The expert emphasized that the fight against the shadow market should not be limited to strengthening controls alone. It must be accompanied by the development of competition, consumer protection, and the increased attractiveness of official sales channels.
He added that if official sellers offer competitive prices, high-quality warranty and post-warranty service, and effective consumer protection, citizens' interest in purchasing phones through unofficial channels will naturally decline.
Dzhrbashyan noted that the best results are achieved not through restrictions alone, but by creating an environment in which buying a phone legally is more profitable and safer.
"If the primary goal of the proposed IMEI system is truly to reduce the shadow market, society has the right to see a comparative assessment of alternative solutions and the rationale for rejecting them before choosing a more restrictive model," the expert concluded.
About the Bill
The Armenian government has approved draft amendments to the Law on Electronic Communications, which stipulate mandatory verification of IMEI codes by mobile operators when providing communications services.
According to the draft, citizens importing a mobile phone manufactured in 2025-2026 into Armenia will be required to register the device by paying a state fee of 3,000 drams. Registration of older phones will be free.
A higher 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.
Expert Assessment
Experts expressed concerns about the proposed IMEI registration system.
Information security expert Artur Papyan stated that the initiative carries the risk of excessive data concentration on users and their devices.
Tigran Jrbashyan, Director of Management Consulting at Ameria, in turn, called on the authorities to present the economic and legal justification for the chosen regulatory model and clarify whether alternative approaches were considered.