Risks for Citizens and the Telephone Market: 10 Questions from an Expert to Armenian Authorities on the IMEI Registration Project
02.07.2026,
10:58
Tigran Jrbashyan, Director of the Management Consulting Service at Ameria, formulated 10 questions for the authors of the draft law on the state registration of mobile phone IMEI codes.
YEREVAN, July 2. /ARKA/. Tigran Jrbashyan, Director of the Management Consulting Service at Ameria, formulated 10 questions for the authors of the draft law on the state registration of mobile phone IMEI codes.
According to him, the proposed regulation affects hundreds of thousands of citizens, mobile operators, and the telephone market.
On his Facebook page, the analyst asked the authors of the relevant bill to clarify 10 points:
1. Does the implementation of the IMEI registration system follow from Armenia's obligations within the EAEU or the acts of the Eurasian Economic Commission?
2. If there are no such mandatory acts, why was this regulatory model chosen rather than alternative approaches, such as those used in EU countries?
3. When will IMEI registration be carried out—upon import or only when phones are introduced to the Armenian domestic market? What will happen to the IMEI of devices that will not be sold in Armenia and will subsequently be exported or re-exported?
4. How will the system work for phones imported into the EAEU customs area through another country and then legally transferred to Armenia?
5. Is the creation of a unified IMEI registry or data exchange system at the EAEU level planned?
6. What portion of phones imported into Armenia are actually used domestically, and what portion are exported or re-exported?
7. What additional benefit will the creation of a centralized state registry provide if operators already have the technical mechanisms for linking SIM/eSIM devices to devices?
8. Can Armenian operators use the international GSMA Device Registry/IMEI Database to check devices and block only stolen phones or devices with an invalid IMEI?
9. How will the legal circulation of devices imported by citizens or purchased from a legitimate seller in Armenia be ensured if their IMEI is not listed in the Armenian state registry? Jrbashyan also questions whether Armenia's refusal to register IMEIs could restrict the legal export or re-export of mobile phones from Armenia to countries with national IMEI registration systems.
The economist believes that the answers to these questions are important for understanding the problem the bill actually addresses, what alternatives were considered, and why the authorities chose the proposed regulatory model.
About the Bill
The bill amending the Law on Electronic Communications, adopted by the Armenian government on June 26, stipulates 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.
According to him, the proposed regulation affects hundreds of thousands of citizens, mobile operators, and the telephone market.
On his Facebook page, the analyst asked the authors of the relevant bill to clarify 10 points:
1. Does the implementation of the IMEI registration system follow from Armenia's obligations within the EAEU or the acts of the Eurasian Economic Commission?
2. If there are no such mandatory acts, why was this regulatory model chosen rather than alternative approaches, such as those used in EU countries?
3. When will IMEI registration be carried out—upon import or only when phones are introduced to the Armenian domestic market? What will happen to the IMEI of devices that will not be sold in Armenia and will subsequently be exported or re-exported?
4. How will the system work for phones imported into the EAEU customs area through another country and then legally transferred to Armenia?
5. Is the creation of a unified IMEI registry or data exchange system at the EAEU level planned?
6. What portion of phones imported into Armenia are actually used domestically, and what portion are exported or re-exported?
7. What additional benefit will the creation of a centralized state registry provide if operators already have the technical mechanisms for linking SIM/eSIM devices to devices?
8. Can Armenian operators use the international GSMA Device Registry/IMEI Database to check devices and block only stolen phones or devices with an invalid IMEI?
9. How will the legal circulation of devices imported by citizens or purchased from a legitimate seller in Armenia be ensured if their IMEI is not listed in the Armenian state registry? Jrbashyan also questions whether Armenia's refusal to register IMEIs could restrict the legal export or re-export of mobile phones from Armenia to countries with national IMEI registration systems.
The economist believes that the answers to these questions are important for understanding the problem the bill actually addresses, what alternatives were considered, and why the authorities chose the proposed regulatory model.
About the Bill
The bill amending the Law on Electronic Communications, adopted by the Armenian government on June 26, stipulates 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.