Expert: Comprehensive analysis of mobile phone market necessary before introducing IMEI registration system
30.06.2026,
12:34
Before implementing a state registration system for mobile phone IMEI codes, a comprehensive analysis of the market structure is necessary, stated Tigran Jrbashyan, Director of the Management Consulting Service at Ameria.
YEREVAN, June 30. /ARKA/. Before implementing a state registration system for mobile phone IMEI codes, a comprehensive analysis of the market structure is necessary, stated Tigran Jrbashyan, Director of the Management Consulting Service at Ameria.
In his publication dedicated to the IMEI regulation bill currently under discussion, the expert noted that any new government regulation should be based on a public and evidence-based analysis.
According to him, the key question is which market the state intends to regulate.
Jrbashyan noted that the structure of the mobile phone market in Armenia has changed significantly over the past three years. According to official data from the World Trade Organization (WTO), smartphone imports in 2024 amounted to approximately $760 million, or 4.5% of the country's total imports, while exports reached $675 million, corresponding to 5.2% of Armenia's total exports.
"These figures show that import and export volumes are already comparable, indicating a significant change in the market structure," the expert noted.
According to him, regardless of how desirable or sustainable such a market model is in the long term, government regulation should be based on the actual market structure, not on a desired one.
In this regard, Jrbashyan questions whether a comprehensive market analysis was conducted before the drafting of the bill on the implementation of the state IMEI registration system. Specifically, was the share of imported phones intended for domestic consumption determined, versus the share of devices imported for subsequent export or re-export, and how the proposed regulation would differentiate these commodity flows.
Furthermore, the expert questions how the effectiveness of the proposed regulation was assessed in the context of a significantly changed market structure.
According to Jrbashyan, one of the fundamental principles of modern regulatory policy is that high-quality regulation begins not with the selection of a regulatory instrument, but with a comprehensive analysis of the market structure and the problem requiring government intervention.
In this regard, he believes that if a market analysis and Regulatory Impact Assessment (RIA) have indeed been conducted, their publication will facilitate professional discussion and strengthen the rationale for the proposed changes.
About the Bill
The bill amending the Law on Electronic Communications, adopted by the Armenian government on June 26, stipulates mandatory IMEI code verification by mobile operators when providing communications services.
According to the bill, 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.
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.
In his publication dedicated to the IMEI regulation bill currently under discussion, the expert noted that any new government regulation should be based on a public and evidence-based analysis.
According to him, the key question is which market the state intends to regulate.
Jrbashyan noted that the structure of the mobile phone market in Armenia has changed significantly over the past three years. According to official data from the World Trade Organization (WTO), smartphone imports in 2024 amounted to approximately $760 million, or 4.5% of the country's total imports, while exports reached $675 million, corresponding to 5.2% of Armenia's total exports.
"These figures show that import and export volumes are already comparable, indicating a significant change in the market structure," the expert noted.
According to him, regardless of how desirable or sustainable such a market model is in the long term, government regulation should be based on the actual market structure, not on a desired one.
In this regard, Jrbashyan questions whether a comprehensive market analysis was conducted before the drafting of the bill on the implementation of the state IMEI registration system. Specifically, was the share of imported phones intended for domestic consumption determined, versus the share of devices imported for subsequent export or re-export, and how the proposed regulation would differentiate these commodity flows.
Furthermore, the expert questions how the effectiveness of the proposed regulation was assessed in the context of a significantly changed market structure.
According to Jrbashyan, one of the fundamental principles of modern regulatory policy is that high-quality regulation begins not with the selection of a regulatory instrument, but with a comprehensive analysis of the market structure and the problem requiring government intervention.
In this regard, he believes that if a market analysis and Regulatory Impact Assessment (RIA) have indeed been conducted, their publication will facilitate professional discussion and strengthen the rationale for the proposed changes.
About the Bill
The bill amending the Law on Electronic Communications, adopted by the Armenian government on June 26, stipulates mandatory IMEI code verification by mobile operators when providing communications services.
According to the bill, 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.
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.