ArmInfo. Tigran Jrbashyan, Director of the Ameria management consulting company, raised several issues related to the planned implementation of the IMEI system in Armenia, which will be discussed at an extraordinary session of the RA National Assembly.
"Considering the importance of the proposed regulation and the fact that it affects hundreds of thousands of citizens, mobile operators, and the telephone industry, I believe it would be appropriate to publicly answer a number of fundamental questions before detailed discussions begin in the National Assembly. Knowing the answers to these questions in advance could significantly shorten the duration of parliamentary debates, enhance their professional level, and facilitate more informed decision-making," noted Tigran Jrbashyan.
In particular, he raised the question of whether the introduction of the IMEI state registration system follows from any mandatory act of legislation of the EAEU or the Eurasian Economic Commission? If yes, please provide the number of this act and the relevant provision. If such a mandatory act does not exist, what is the reason for choosing this regulatory model, and why were alternative approaches not chosen, including those used in many European Union countries?
When is state registration of IMEIs planned: upon import or only upon entry into circulation on the Armenian domestic market? If registration is to take place upon import, what regulation is planned for the IMEI of phones that will not be sold on the Armenian domestic market and will subsequently be fully exported or re-exported? Will their IMEIs remain in the Armenian state registry, or is there a mechanism for their removal or deregistration? If phones were imported into the common customs territory of the EAEU through another member state (e.g., Belarus) and then legally transported to Armenia, how will the proposed system work? Is the creation of a unified IMEI registry or a unified data exchange system at the EAEU level planned? If so, at what stage is this process?
According to official statistics, in recent years, significant Some mobile phones imported to Armenia are subsequently exported or re-exported. Can you estimate what percentage of the IMEI of imported devices is ultimately used in Armenia, and what percentage is used outside of Armenia?
Do mobile operators currently technically bind subscribers to the IMEI of a given device upon SIM/eSIM card activation? If so, what additional benefit would the creation of a centralized state IMEI registry provide compared to existing mechanisms?
Are mobile operators in Armenia technically and legally able to use the GSMA device registry system/IMEI database to check the IMEI of devices and block only those listed in international databases as stolen or with an invalid IMEI? If so, has this option been considered as a possible alternative? If, when purchasing a phone from a legitimate seller in Armenia, the buyer's personal data is not linked to the IMEI of the device in the state information system, what is planned for devices that citizens: personally imported into Armenia, purchased from a legal entity registered in another EAEU member state (e.g., Kazakhstan), where all customs and tax procedures have already been legally completed, or subsequently legally transported these devices to Armenia within the EAEU single market? If there is no unified IMEI registry at the EAEU level, and the IMEIs of these devices are not included in the Armenian state registry, how do you plan to ensure their legal circulation on the Armenian domestic market without creating an additional administrative burden for citizens?
If Armenia abandons the state IMEI registration system, could this in any way restrict the legal export and re-export of mobile phones from Armenia to countries with national IMEI registration systems? If so, please provide the legal and technical justification for this connection. I believe that public clarification of these issues is important not only for assessing the content of the bill but also for understanding the problem it actually addresses, what alternatives were discussed, and why this particular regulatory model was chosen," the expert raised questions.
He also noted that if the bill's goals include reducing the shadow market, promoting legitimate trade, and ensuring fair competition, then the question arises: has the Consumer Rights Protection Commission conducted an industry study of the mobile phone market, assessed the competitive structure of the market, the degree of concentration, possible dominant positions, or the risks of monopolization, and presented its official conclusion? "If such a study was conducted, please publish it. If not, how was the impact of the proposed regulation on competition assessed, and how was it substantiated that it will not lead to further market concentration?" Tigran Drbasyan asked the bill's developers.
As a reminder, the Armenian government previously approved a bill establishing a state system for registering and monitoring IMEI codes. According to the document, mobile devices imported into the country by individuals will be required to be registered starting January 1, 2027. In the absence of registration, telecom operators may refuse to connect them to the network. The introduction of the system is accompanied by a state registration fee. For devices manufactured in the current or previous year, the duty will be 3,000 drams, while registration of older phones will be free. At the same time, increased duties will be introduced for the import of multiple new devices by the same person within a year: 100,000 drams for the second and subsequent phones manufactured in 2026 imported by the same person within a year, and 20,000 drams for the second and subsequent phones manufactured in 2025.
