Armenia

Key priorities to improve the civil society environment:

1. The Ministry of Finance provides a definition of “grant” in accordance with the best international practices and following consultation with CSOs and does not treat grant projects or other non-profit activities as economic activities;  
2. The government (particularly the Ministry of Finance) and the National Assembly create a more favourable tax environment to improve the possibilities for CSOs to seek funding and in-kind support from diverse sources, including individual and business donations and direct entrepreneurship activities;  
3. The National Assembly establishes mechanisms for mandatory public consultations on draft legislation produced by members of the National Assembly and for CSO engagement in both the early stages of legal drafts and during the final revisions of the drafts received by the government (including through engagement at the level of Standing Committees);
4. State bodies utilise and expand the pre-existing and new institutional mechanisms of participation to ensure meaningful participation, including through: (a) engaging CSOs in the early stages of policy development; (b) addressing the drawbacks of the e-draft platform and providing statistics on participation activities and the incorporation of comments on this platform; (c) providing sufficient time for consultations and organising more frequent face-to-face consultations, including in the regions; and (d) considering and incorporating well-founded and evidence-based suggestions to the maximum possible extent;
5. The government and public officials uphold freedom of expression standards, promote a culture of open and respectful public dialogue, and ensure responsible communication toward the media, refraining from intolerance towards diverse or critical opinions as well as from statements that may incite hostility or undermine public trust in journalists and media;
6. The government introduces stronger safeguards against unlawful surveillance and breaches of privacy, ensuring independent oversight and transparent investigations of violations; and
7. The state provides adequate protection for CSOs, including through: (a) adopting anti-discrimination laws and establishing an anti-discrimination body; (b) taking legislative and practical measures against SLAPPs in line with the Council of Europe’s recommendations adopted in April 2024; (c) issuing public statements in support of CSOs that are targeted by third parties; and (d) ensuring proper investigation of attacks against CSOs and activists within a reasonable timeframe. 

Ongoing action - Advancing public participation:

1. Transparency International Anticorruption Center advocates to increase legal avenues for public participation in the early stages of policymaking. This can significantly improve participation, and thus also the quality of policymaking in Armenia, and serve as inspiration for actions in other countries. Advocacy towards this reform received financial support from the CSO Meter Action Pooled Fund.
2. Supporting the financial sustainability of organisations as a key pillar for lasting civic action. In Armenia, NGO Center pursues expanding the incentives for charity, through tax benefits and public benefit status. Supporting philanthropy and domestic giving will be a key step to help Armenian CSOs become less dependent on funding from abroad.

Past achievements:  

CSO Meter monitoring and recommendations have already delivered the following results:

• Expanding CSOs’ role in public interest litigation (2025): CSO Meter Hub member Law Development & Protection Foundation (LDPF) has advocated as part of the project to expand the Actio Popularis principle to allow CSOs to represent public interest in court.  
• Progressive law on volunteering (2023): CSOs, including CSO Meter core partner, Transparency International Anticorruption Center (TIAC) successfully blocked restrictive provisions in different draft versions of the law. The law adopted integrates CSO Meter recommendations to protect and encourage volunteerism. This means that CSOs can harness the power of volunteer work to achieve their missions and volunteers can also enjoy essential protections of their rights.  
• Strengthening public participation for better policies (2023-2024): The government incorporated CSO Meter Recommendations on decision-making participation into the 2023 amendments to the Public Administration Reform strategy, adding a new fifth pillar on participatory governance. This pillar outlines steps to strengthen public participation, including creating a monitoring mechanism and advancing online and offline participatory tools. Based on the amended PAR strategy and Open Government Partnership Action Plan 2022-2024, a dedicated department at the Office of the Prime Minister was created, to institutionalise open government principles and support civil society development. Drawing on comparative good practices on the functions and responsibilities of similar departments in other countries identified by TIAC and ECNL, the department aims to ensure participation of CSOs in decision making. This will ultimately unlock access to expertise and localised knowledge, leading to more informed policies and better solutions.  
• Transparent rules for state funding for CSOs introduced (2019-2021): The majority of TIAC suggestions were integrated into the procedure of allocating state grants and subsidies to legal entities. These rules ensure transparency and accountability, particularly in the selection process and regarding conflict of interest and the tasks of the grant selection committee. TIAC, consulting with other CSOs, provided expertise to the Ministry of Finance, helping set up standardised grant documentation (templates, announcements) and effective use of the new electronic platform.  These changes support transparent access to public funding for civil society.
• Proportionate reporting rules for CSOs ensured (2018-2020): TIAC, alongside other CSOs and with ECNL’s support, successfully advocated for reporting rules for CSOs in Armenia that align with international standards. Initial legislative proposals of the government required public organisations and foundations to disclose sensitive details like donor names, board members, staff, and volunteers. Thanks to the efforts of CSOs, the final law amendments ensure annual reporting that promotes transparency without compromising privacy or creating unnecessary burdens. This reform strengthens CSO accountability while safeguarding the space for civil society to operate freely and effectively. 

Country context and important trends relevant to the civil society environment:

The political environment in Armenia in 2025 was shaped by continued threats to the country by Azerbaijan’s political leadership, with negotiations around a peace agreement taking place in parallel. Furthermore, the political landscape was impacted by rising tensions ahead of the 2026 elections, along with the lingering effects of the Nagorno-Karabakh war, which were all happening in the broader context of geopolitical shifts, including shifting foreign policy priorities of the European Union (the EU) and United States of America (the U.S), heightened instability in the Middle East, democracy backsliding in neighbouring Georgia, and the continued war in Ukraine. 

In 2025, Armenia took several steps to develop its foreign policy agenda towards strengthening its relations with the EU and the U.S.. In early 2025, following a citizen legislative initiative, the National Assembly adopted the Law on Initiating the Process of Armenia’s Accession to the European Union, reflecting the government’s political will as well as being a strategic move towards integrating Armenia with the wider EU. In parallel, based on EU visa liberalisation negotiations, which commenced in September 2024, and following significant progress made by the Armenian government, the Visa Liberalisation Action Plan was handed over by the EU to the Armenian government in early November 2025. For civil society organisations (CSOs), this move created new opportunities to engage in EU-driven reform processes and policy dialogues, while at the same time placed additional pressure on the government to align policies and legislation with the more demanding European standards. 

Public trust towards the government continues to decline. A poll conducted by the International Republican Institute in June-July 2025 found that 49% of respondents believe that Armenia was headed in the “wrong direction”, compared to 36% who think it is moving in the right direction, while 61% mentioned that they do not trust any political figure. This distrust towards state institutions is closely linked with the high level of polarisation and disinformation that persists in Armenian society, along with the high level of hateful rhetoric. For CSOs, this social polarisation and the related political tensions demand careful balancing, as they face a new wave of public pressure and stigmatisation both for voicing criticism and for engaging in collaboration initiatives with government actors. 

External funding trends have further deepened the vulnerabilities of Armenian civil society. Cuts in foreign aid, particularly from the U.S., have heavily affected many CSOs. This has forced programme closures and left many organisations having to survive by sharply reducing the scope of their operations, meaning that they are now often unable to cover basic costs such as the rent of office spaces. This funding crisis has underscored the sector’s dependence on external support and has highlighted the remaining gaps in financial sustainability. Despite repeated appeals by CSOs and media organisations for government support, no substantive response was provided by the government. 

Key developments and priorities in the civil society environment

The overall score for the CSO environment in Armenia remained unchanged in 2025 as compared to 2024 (4.8 out of 7). The top three areas with the highest scores also remained consistent and include Freedom of Association (5.7), Access to Funding (5.3) and Freedom of Peaceful Assembly (5.2). As was the case in 2024, the areas with the lowest scores are State-CSO Cooperation (4.0) and State Support (4.1), followed by State Duty to Protect (4.5) and Digital Rights (4.4). Three areas – Freedom of Expression, Right to Privacy, and Digital Rights – registered score decreases compared to 2024. 

In Freedom of Expression, the decrease in the overall area score (4.8 in 2025 from 4.9 in 2024) was a result of practice score decline (4.2 in 2025 from 4.3 in 2024) due to several challenges Armenia faced such as the highly-polarised political climate which was marked by verbal attacks, smear campaigns and occasional physical violence against journalists. High levels of disinformation and hate speech remain a concern, with allegations that law enforcement apply the provisions on hate speech and public calls to incite violence in a disproportionate and selective manner, primarily to protect officials. At the same time, both negative and positive legislative developments were observed in this area, including the establishment of a foundation supporting audiovisual broadcasters and a reduction in the minimal number of public broadcasters. Furthermore, several draft laws were developed which have the aim of updating defamation rules, extending liability to include online content and strengthening the oversight of broadcasters. Meanwhile, the government, in collaboration with CSOs, implemented initiatives to improve media literacy and tackle disinformation under the National Concept of the Struggle against Disinformation and established a Strategic Communication Department in the Prime Minister’s Office.

In Right to Privacy, privacy breaches and leaked wiretaps highlighted systemic gaps in protecting against unlawful data processing and a lack of effective prevention and accountability mechanisms, leading to lower area scores (from 4.9 in 2024 to 4.8 in 2025). The need for better oversight and accountability mechanisms for surveillance activities also remains a major practical problem. In this context, amendments expanding police access to public surveillance cameras have been viewed as risky. On the positive side, the plans to establish an independent personal data protection authority and a draft package of the Law on Public Information and Law on Cybersecurity, along with amendments to the Law on the Protection of Personal Data, provide a more solid foundation for future improvements in personal data protection.

These legislative reforms are also relevant to Digital Rights which provide the possibility of strengthening cybersecurity under the coordination of a new independent body. However, the amendments expanding government access to surveillance systems negatively affected the law score of the area, resulting in a decline of the overall area score (from 4.5 in 2024 to 4.4 in 2025). In practice, the enforcement of safeguards governing surveillance technology remains weak, and CSOs, journalists, and activists continue to face spyware, phishing, and DDoS attacks. At the same time, the government continues to expand the digitalisation of services, media literacy efforts, and internet access, with many CSOs playing a key role in media education and fact-checking.

In State-CSO Cooperation, the Law score improved (from 4.3 in 2024 to 4.4 in 2025) due to the establishment of a department on participatory and open governance and the introduction of new regulations aimed at improving public participation and state-CSO cooperation. However, the area score remained the same (overall score 4.0), the lowest of all CSO Meter areas, reflecting the absence of any overarching policy or strategy on CSOs. Amendments to the Law on the Public Council led to the relaunch of this constitutional advisory body after years of inactivity and the initiation of a process aiming to establish a Fact-Finding Commission under its structure. Although there are numerous national and local level consultative bodies and groups, many remain inactive, lack accountability and/or operate irregularly. A new regulation adopted in September 2025 is expected to ensure that public councils meet with regularity, have regional representation and introduce proper feedback mechanisms.

The scores of other areas of the CSO Meter remained unchanged in 2025. Legislation and practice in Freedom of Association (overall area score 5.7) are generally supportive of CSOs, with sample registration documents allowing public organisations to register more quickly. The lack of online registration for CSOs and the administrative and financial burdens associated with the disclosure requirements for their ultimate beneficial owners (UBOs) remain the main challenges in this area. 

In Equal Treatment (overall area score 4.9), the key challenges are that there are more favourable conditions for businesses compared to CSOs in the registration and taxation of economic activities and there is selective engagement of CSOs by decision makers. Although the legislation provides opportunities for CSOs to seek funding from various sources, a major issue of Access to Funding (overall area score 5.3) remains the lack of incentives for funding diversification, which is exacerbated by a significant reduction of donor support in 2025. Moreover, the interpretation of grant projects as “service delivery” which is subject to charging VAT remains a persistent concern.

In Freedom of Peaceful Assembly (overall area score 5.2), the Law on Police Guards and new by-law standards introduced clearer rules regarding the use of force and required police training, which might potentially improve the policing of assemblies. Fewer large assemblies occurred in 2025, and most were unhindered. However, policing was often excessive relative to the number of protesters. At the same time, weak accountability for past violations by police against protesters continues to raise concerns. 

In Right to Participation in Decision-Making (overall area score 4.9), positive developments include the establishment of a dedicated government department and new regulations to strengthen participation frameworks. However, the lack of institutional mechanisms for participation in the early stages of decision-making and for engagement with the National Assembly, as well as continuing problems with access to information remain the most significant challenges. The draft Law on Public Information, pending parliament approval, could expand the disclosure of information and improve open data availability, though practical challenges remain substantial. 

The continuing lack of effective protection for CSOs working in sensitive areas and pressure on environmental activists through strategic litigation against public participation (SLAPPs), are the main challenges in State Duty to Protect (overall area score 4.5). The progress on extending the right of a public organisation to represent public interests in the court remains limited.

Finally, in State Support (overall area score 4.1) the key challenges remain unchanged from previous years, with the most significant gap being the absence of an encouraging tax environment for both CSOs and donors. A case of a secret funding allocation raised new concerns on state funding fairness and transparency, while local level support remains largely discretionary. The modernised electronic platform for state procurements, which will cover the administration of state grants, is still a work in progress. 

Video story

Why was collaboration through the CSO Meter essential to create more transparent state funding procedures? Find out more from Anush Hakobyan, Transparency International Anti-Corruption Center (Armenia):