ARMENIA Law and Practice Contributed by: Aram Orbelyan, Narine Beglaryan, Artur Hovhannisyan, Lilit Karapetyan, Sarkis Knyazyan and Shushanik Stepanyan, Concern Dialog
8.3 Role and Authority of the Data Protection Agency The Personal Data Protection Agency of the Republic of Armenia is part of the Ministry of Justice of Arme - nia. However, the Data Protection Law declares that the Agency operates independently. Among other authorities listed under the law, the Agency is entitled to do the following: • apply administrative sanctions prescribed by law in the case of violation of the requirements of the Data Protection Law; • require the blocking, suspension or termination of the processing of personal data violating the requirements of the Data Protection Law; • require the rectification, modification, blocking or destruction of personal data; • prohibit completely or partially the processing of personal data; • recognise electronic systems for processing the personal data of legal persons as having an adequate level of protection and include them in the register; • ensure the protection of rights of the data subject; and • consider applications of natural persons regarding the processing of personal data and deliver deci - sions within the scope of its powers. As of 20 May 2025, the draft of the new Law on Invest - ments has passed its first reading. After this draft law passes its second reading and is signed by the Presi - dent, it will enter into force one month after its pub - lication. This new law intends to grant protection to invest - ments made by both local and foreign investors, except for certain portfolio investments. Local invest - ments, however, will be protected under this new law only if the investment is made after the law enters into force and meets certain criteria defined under the law. This new law will apply to foreign investments made 9. Looking Forward 9.1 Upcoming Legal Reforms Draft Law on Investments
prior to its entry into force, unless the old law grants more favourable conditions and the foreign inves - tor chooses to remain under the old Law on Foreign Investments. The National Treatment regime for foreign investment will be retained, while the Most Favoured Nation regime will be added. The possibility of restricting investment in certain busi - ness operation areas for defined purposes is intro - duced. Currently, Armenia is at the stage of discus - sions and drafting with regard to FDI screening, and this new provision is possibly linked to the expected legislative developments. Law on Cybersecurity and Other Related Laws and Sub-Legislative Normative Legal Acts On 4 December 2025, the National Assembly, upon second reading, adopted the new laws of the Republic of Armenia “On Cybersecurity” and “On the Regula - tion of Information Systems”, as well as a number of other normative legal acts aimed at regulating cyber - security. The Law of the Republic of Armenia “On the Regu - lation of Information Systems” entered into force on 26 December 2025, while the Law of the Republic of Armenia “On Cybersecurity” (hereinafter referred to as the Law) entered into force on 4 January 2026. The Law stipulates that the provisions defining the obligations of economic operators shall enter into force with respect to those obligations only after the entry into force of subordinate normative legal acts establishing detailed requirements concerning such obligations. However, the rule set forth in Article 27 of the Law of the Republic of Armenia “On Norma - tive Legal Acts” must be highlighted as it specifically states that, where the implementation of a norm is conditional upon the adoption of another normative legal act, such norm shall not apply until the said other normative legal act enters into force. Currently, the legal framework regarding cybersecurity is at the stage of development, and it is expected that by the end of 2025 Armenia will have adopted all rel -
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