ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
1. Introduction 1.1 Current Outlook and Recent Changes In 2024, the National Assembly of Armenia adopted the Law on the Regulation of Gaming Activities (known as the “Gaming Law”), which entered into force on 1 January 2025. The Law introduced the principles of responsible gambling and fair play, as well as geo- blocking mechanisms designed to prevent Armenian residents from participating in foreign gambling plat- forms. Furthermore, the Gaming Law stipulated that a register of restricted domains be maintained and shared with the Central Bank of Armenia to block related financial transactions. Gaming organisers are also required to host their online resources under the “.am” domain, a meas- ure aimed at enhancing regulatory control. Although these reforms are expected to improve supervision and compliance, their practical effect has yet to be fully observed due to the Law’s recent entry into force. Enforcement of consumer protection has intensified in parallel. In 2024, the Competition and Consumer Protection Commission (CCPC) imposed a landmark sanction on major online gaming activity organisers for unfair competition, including misleading advertis- ing practices targeting both users and non-users. Separately, the National Assembly adopted the Law on Crypto Assets on 29 May 2025 (effective 4 July 2025), while legislative work continues on a new Cybersecurity Law. Neither instrument introduces gambling-specific regulations. Institutionally, responsibility for developing and imple- menting state policy in the field of gaming activities has been transferred from the Ministry of Finance to the Ministry of Economy, which now serves as the principal authority exercising state oversight over the sector. The Operator A major structural innovation in Armenia’s reformed gaming regulatory framework is the introduction of the Operator, a distinct entity entrusted with wide- ranging technical, administrative, and monitoring functions. Operating under a model comparable to
public–private partnership (PPP) structures, the Oper- ator acts as an intermediary between the state and gaming organisers, facilitating operational oversight while remaining separate from the direct conduct of gaming activities. Its responsibilities include admin- istering the issuance, renewal, and suspension of operational certificates; certifying gaming products or validating international conformity certificates; ensuring the integration of gaming systems with the central monitoring centre; setting service fees within government-approved caps; and proposing technical standards and responsible gaming practices to the competent authorities. The Operator also conducts market monitoring, analyses risks, and provides rec- ommendations to the regulatory authorities regarding industry developments, regulatory improvements, and player protection mechanisms. The Government Resolution No 1149-N (“On the Pro- cedure for Conducting the Competition for Selecting the Operator of Gaming Regulation, the Procedure for Participation in the Selection Process through a Consortium, the Procedure for Concluding a Contract with the Operator, and the Grounds for Declaring the Competition Void”) provides detailed rules governing the selection and contracting of the Operator. It estab- lishes transparent criteria for participation, allows for consortium-based applications, and defines proce- dural safeguards for competition and contract con- clusion. Through this framework, Armenia has insti- tutionalised a hybrid model in which the Operator serves as a regulated partner of the state, managing certification, monitoring, and data access functions, while the government retains strategic and regulatory control over the gaming sector.
2. Jurisdictional Overview 2.1 Online Gambling
The regulatory framework in Armenia is generally licence-based and permissive, allowing both land- based and online operations subject to regulatory oversight by the competent governmental authority. The legislation distinguishes between the following regulated categories:
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