ARMENIA Trends and Developments Contributed by: Mesrop Manukyan, Anahit Sargsyan, Maria Petrosyan and Ani Avetikyan, MB Legal
MB Legal 37 Hanrapetutyan Street 4th Floor Yerevan 0010 Armenia Tel: +374 41 241244 Email: info@mblegal.am Web: mblegal.am
Overview of the Market The Republic of Armenia has positioned itself as a resilient and rapidly evolving destination for interna - tional investment within the Caucasus region. As we move through 2026, the legal landscape is character - ised by a profound shift towards transparency, digital integration, and alignment with international regula - tory standards. These developments are not merely cosmetic but represent a fundamental restructuring of how business is conducted, regulated, and protected within the jurisdiction. A Regulated Crypto-Assets Framework A brand-new Crypto-Assets Law has brought an entire sector out of legal ambiguity and into a regulat - ed framework. Until mid-2025, there was no licensing framework, no regulatory oversight, and no clear legal basis for the commercial relationships these business - es needed to establish. Banks were frequently reluc - tant to provide services, and clients faced genuine uncertainty about the enforceability of agreements. That changed fundamentally when the Law on Crypto- Assets was adopted, representing the first compre - hensive legal framework for the sector. This legislation establishes a clear licensing regime for service providers and sets out rigorous disclosure requirements for public offerings. The law identifies various kinds of crypto-assets, including asset-refer - enced tokens and electronic money tokens. Issuers must now provide detailed offering documents, which are subject to approval by the Central Bank of Arme - nia. This regulatory clarity is a significant development for fintech companies looking to operate in a stable and legally defined environment.
The framework places a heavy emphasis on consum - er protection and financial stability within the digital asset market. Entities providing crypto-services are now required to maintain specific reserve assets and follow strict internal rules of conduct. There are also robust prohibitions against insider trading and market manipulation to ensure market integrity. For interna - tional firms, these rules provide the necessary legal certainty to treat crypto-assets as a legitimate part of their Armenian operations. Safeguarding the Digital Economy with Cybersecurity Law The Cybersecurity Law, now in force, imposes manda - tory obligations on virtually every business operating in Armenia. This legislation entered into force in 2026, and its scope is deliberately broad to cover all vital economic activities. It identifies critical sectors such as energy, finance, and telecommunications as being essential for the country’s security. Providers operat - ing in these critical information infrastructure sectors must now implement robust security measures and protocols. For international companies, the 72-hour notifica - tion timeline for cyber incidents mirrors requirements under the EU’s GDPR and the NIS2 Directive. This means that organisations already compliant with European cybersecurity standards will find the Arme - nian framework conceptually familiar. The key task for these businesses is to ensure that Armenian subsidi - aries have their own local incident response protocols. The law also emphasises international co-operation and information sharing regarding digital threats.
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