ARMENIA Trends and Developments Contributed by: Varoujan Avedikian, Lena Mitichyan, Ani Tchagharyan and Anahit Zakaryan, Andersen Legal
Cybersecurity Law In recent years, the use of information technologies has expanded in the RA. The draft cybersecurity law is designed primarily to ensure the secure operation of information systems and critical information infra - structure (CII) that support the vital services in Arme - nia. The legislation provides essential definitions, includ - ing of cybersecurity, CII and vital services. It further outlines the authorities and functions of the state body responsible for developing and implementing national cybersecurity policy. This authority is instrumental in sector co-ordination and must include the computer emergency response team (CERT) within its organi - sational structure. The law specifies certain rights and responsibilities for service providers, requiring them to implement effective risk management processes. Compliance involves meeting the minimum cybersecurity require - ments established by the RA government for their information systems and CII. This compliance must follow criteria set by both national standards and rec - ognised international standards, such as those from the International Organization for Standardization (ISO) and the Information Systems Audit and Control Association (ISACA). Furthermore, service providers must undergo a cyber - security audit once every two years and are obliged to submit the resulting audit report to the authorised body within one month of its receipt. As an additional control tool, the law introduces a mandatory incident reporting mechanism: service pro - viders are required to immediately notify the author - ised authority of any cyber incident upon discovery, but no later than 24 hours thereafter, following the procedure established by the competent authority. A voluntary notification option is also available for natu - ral persons and legal entities not classified as service providers within the meaning of the law. Following two years of discussion and development, which started in 2023, the National Assembly adopt - ed the legislation in the first reading in October 2025
reporting, while also supporting state oversight of labour law compliance and the recruitment of foreign workers. Overall, these reforms aim to promote transparency and accountability in employment relations, enable both employers and employees to manage contracts online, and allow the government to monitor compli - ance with labour laws effectively. Through this new digital platform, employment contracts will be secure - ly accessible to authorised users anytime and from anywhere. Convertible Notes In 2025, interconnected amendments were made to the Republic of Armenia (RA) Civil Code and RA Law on Joint-Stock Companies, providing for the legal opportunity for exercising debt securities that convert into equity instruments – convertible notes. According to the amendments to the Civil Code, a loan (convertible note) agreement may provide that instead of repayment of the loan, the corporate borrower shall be obliged to distribute to the lender shares of a speci - fied quantity, type and class. It is worth mentioning that the amendments provide for such a possibility both for joint-stock companies and limited liability companies. Unlike limited liability companies, where a unani - mous decision is required to enter into a convertible loan agreement, the charter of a joint stock company may allow such decisions to be adopted by a three- quarters majority vote. Additionally, the charter of the limited liability company may prohibit an increase in charter capital on the account of third-party deposits, in which case execution of the convertible note agree - ment will be impossible. The amendments also regulate the currency issue, stating that convertible notes may be issued in for - eign currency; however, subsequent cash investments into the charter capital of the corporate borrower shall be considered to be made in Armenian drams at the average exchange rate published by the Central Bank of the RA.
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