IMEI number registration is not linked to the collection or control of citizens' personal data – Armenian government comments
YEREVAN, July 1. /ARKA/. The IMEI registration system is not related to the collection or control of citizens' personal data, the Armenian government stated.
"Armenia plans to introduce an IMEI registration system, the purpose of which is to ensure the legal circulation of mobile phones," the statement reads.
It is noted that the regulation is aimed at reducing the circulation of illegally imported mobile phones, ensuring equal and fair competitive conditions for legitimate importers, protecting consumers from phones with counterfeit or altered IMEI numbers, and introducing a unified mobile phone registration database.
The government also provided clarifications on the opinions and concerns expressed during public discussions.
Opinion: The IMEI registration system applies to all existing phones.
Clarification: The regulation only applies to phones imported after January 1, 2027. The IMEI code of phones already in use will be registered automatically, and their owners will not be required to perform any actions or make any payments.
Opinion: The regulation is already in effect.
Clarification: The system will come into force on January 1, 2027. Individuals and businesses will have ample time to familiarize themselves with the new regulations in advance.
Opinion: Everyone will be required to pay for IMEI code registration.
Clarification: Existing subscribers will not pay anything. If a citizen uses the Armenian mobile network, their phone's IMEI code will be registered automatically. Registration and the corresponding fee will only be mandatory for phones imported after January 1, 2027. If a phone is purchased domestically, the citizen does not register or pay for IMEI registration, as this obligation falls on the legal entity or individual entrepreneur importing it.
Opinion: The duty amount is subject to constant change.
Clarification: The duty amount is clearly established by law. If a citizen imports a phone manufactured in the current or previous year from abroad for the first time in a given calendar year, they must pay 3,000 drams upon registration within 90 days. If the phone is older, they do not register and do not pay the duty.
Opinion: The draft was not submitted for public discussion.
Clarification: The draft was publicly discussed. In February, the draft was published on the e-draft platform. Technical issues were also known, preventing some citizens from leaving comments. However, expert suggestions and opinions were submitted to the responsible agency and discussed as a matter of routine.
Opinion: The IMEI system is a new tool for collecting personal data: it does not comply with the principles of legality of personal data processing.
Clarification: The IMEI system is not linked in any way to personal data. Only the 15-digit IMEI code of the phone will be stored in the database, without any personal data. The IMEI simply confirms that the device was legally imported and is in circulation in Armenia.
Opinion: The state or private companies will be able to use this database for other purposes.
Clarification: The database regulations clearly define the purposes for which the data can be used. Any additional services will be provided only by the database regulations. Access by government agencies, as is currently the case, will be possible only through procedures established by law and based on a court decision. An "other digital service" could, for example, be provided to law enforcement agencies to prevent crimes (such as mobile phone theft).
Opinion: If the database is subject to a cyberattack, all our data will be at risk.
Clarification: Even in the event of a cyberattack, there is no threat of personal data leakage. Personal data will not be stored in the database. Even in the event of a theoretical leak, it will only be possible to see the IMEI numbers, which would be pointless to compromise.
Opinion: Tourists' phones will be blocked after 30 days.
Clarification: There will be no restrictions for tourists. The law does not apply to roaming and other services used by tourists.
Opinion: Implementation of the system could negatively impact mobile internet access, device identification, personal data protection, and market regulation.
Clarification: This will improve market regulation and protect legal imports. IMEI data is already stored in separate databases of mobile operators. The new system simply creates a unified technical registry that will help effectively combat the illegal import and circulation of devices and facilitate the work of telecom operators.
Opinion: This is a system of digital total control.
Clarification: This is a technical regulation, not a tool for citizen control. The IMEI system is designed to ensure the legal circulation of devices and is in no way connected to monitoring communications, movement, or the personal data of citizens.
Opinion: Such systems only operate in non-democratic countries. The EU does not have such a practice.
Clarification: Europe also uses different mechanisms for IMEI regulation. The EU does not have a single, mandatory system for IMEI regulation. However, if a phone's IMEI is blocked in one country, it may not work on cellular networks in other EU countries. However, due to these high technical standards, the use of illegal phones in the EU is practically impossible. In Armenia, given the large volume of illegal phone trafficking and the existence of separate operator databases, there are plans to introduce a unified IMEI registry. Currently, Armenia is one of the few countries where it is impossible to verify phones registered in the international GSMA registry, and the introduction of a unified IMEI registry will help solve this problem.
About the Bill
The bill amending the Law on Electronic Communications, adopted by the Armenian government on June 26, requires mandatory verification of IMEI codes 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. Moreover, an increased duty is imposed on the import of additional telephones within one year: 100,000 drams for a device manufactured in 2026 and 20,000 drams for a telephone manufactured in 2025.