ARMENIA Law and Practice Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
• games of chance; • internet games of chance; • bookmaker activity (including totalisers); and • lotteries. The following outlines the legal status of key sectors. Betting Classified as bookmaker activity. Permitted on the basis of a bookmaker licence and the right to accept bets. Operations may be conducted exclusively through the organiser’s official website and mobile applications indicated in the licence. Bingo Not expressly defined in primary legislation. Likely falls within games of chance or lotteries, depending on structure. Permitted when conducted under an appropriate casino or lottery licence. Casino Permitted both in land-based and online formats, sub- ject to licensing. Licensees must utilise certified gam- ing software and connect to the central monitoring system operated by the authorised state body. Lotteries Regulated under the Law on Lotteries and the Gaming Law. The Gaming Law explicitly prohibits the organi- sation of traditional lotteries (including instant (no- draw), draw-based, and combined formats) via elec- tronic means or internet access within the Republic of Armenia, while land-based lotteries remain permitted. Fantasy Sports Not specifically regulated under existing legislation. Where no monetary stakes or winnings are involved, such activity may fall outside the scope of gambling laws. If linked to real-money wagering, it would likely be considered a game of chance and would require licensing. Social Gaming Generally exempt from the Gaming Law. Intellectual or knowledge-based games organised through audio- visual media or the internet, which award prizes rather than winnings, are unregulated. If such games involve
in-app purchases convertible to monetary value or wagers, they become subject to gambling regulation. Poker Not separately defined in the legislation. Likely con- sidered a game of chance and therefore permitted only under a casino licence. Online poker is subject to the same licensing and monitoring requirements applicable to internet games of chance. Totalisers Recognised as a form of bookmaker activity involv- ing pooled betting on events. Permitted upon licens- ing under the same conditions as other bookmaker operations. 2.2 Land-Based Gambling In Armenia, both land-based and online gambling operate under the same overarching regulatory frame- work, although certain practical distinctions apply. Land-based gambling is physically restricted to des- ignated zones, including: • Tsakhkadzor; • Jermuk; • Sevan; • Meghri; and • specific free economic zones such as Zvartnots Airport in Yerevan. Large-scale projects approved by the government (with investments exceeding AMD40 billion) may also be permitted in other locations. Venues must comply with minimum distance require- ments from sensitive sites, such as schools, hospitals, and cultural centres, and are typically limited in size. Furthermore, all gaming products used must possess the required certification, ensuring compliance with Armenian legal and technical standards.
3. Legislative Framework 3.1 Key Legislation
The gaming sector in Armenia is regulated through a framework of laws and normative legal acts. The
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