Armenian Government Says Every Mobile Phone Must Be Registered Before It Can Connect to Networks, Raising Privacy Concerns

The Armenian government has approved draft legislation that would require virtually every mobile phone in the country to be registered in a centralized national database, saying the measure would help crack down on illegal imports. The proposal has raised concerns among privacy advocates and cybersecurity experts over the collection and storage of personal data.

The proposed amendments to the Law on Electronic Communications and related legislation were approved during the government's June 25 meeting. If adopted by parliament, the system would require all mobile devices to be registered through a centralized IMEI database before they can legally operate on Armenia's mobile networks.

Government officials argue that the measure is designed to eliminate the circulation of illegally imported, counterfeit, or tampered mobile phones, reduce tax evasion, improve market transparency, and strengthen public security.

According to the explanatory note accompanying the bill, Armenia currently lacks an effective mechanism for monitoring IMEI numbers, allowing devices with undeclared or altered identification codes to enter the market. Authorities say the resulting shadow economy has caused significant tax losses, distorted fair competition, and created security risks.

High-Tech Industry Minister Mkhitar Hayrapetyan said the new system would allow individuals to register their mobile phones online, simplifying the process for consumers while improving oversight.

Prime Minister Nikol Pashinyan described the initiative as a long-overdue effort to dismantle what he called Armenia's largest shadow market.

"The mobile phone market is the largest shadow market, and despite everything we do, it continues to operate," Pashinyan said during the cabinet meeting. "In the Republic of Armenia, no phone that cannot be verified as having been legally imported will function."

He said similar systems are already used in many countries and argued that Armenia must adopt "standardized and civilized solutions" to combat illegal trade.

Under the proposed legislation, every mobile device would be registered upon legal importation. The bill would also prohibit IMEI cloning or alteration and prevent devices that have not cleared customs procedures from being activated on Armenian mobile networks.

What the Database Would Contain

An IMEI is a unique 15-digit identification number assigned to every device capable of connecting to a mobile network, including smartphones, tablets with SIM functionality, smartwatches, and similar devices.

However, the proposed registry would extend beyond simply storing device identification numbers.

According to the draft legislation, the database would also contain information identifying each device's user, linking every registered IMEI to its owner.

The proposal has prompted criticism from Armenia's digital rights community, with organizations including dpHub and CyberHub submitting comments during the public consultation process.

Gevorg Hayrapetyan, a personal data protection expert at dpHub, argues that the legislation effectively creates a centralized database containing sensitive personal information rather than merely a registry of mobile devices.

"When we talk about an IMEI database, we should understand that this would be a comprehensive database containing personal information about individuals, where every device's IMEI is linked to its user," Hayrapetyan told Factor.am. "It would include information identifying the owner, such as name, surname, passport details, identification data, and more."

Hayrapetyan argues that the legislation fails to clearly define why such personal information must be collected and retained.

Under internationally recognized data protection principles, he noted, personal data should only be processed for specific, clearly defined, and lawful purposes. He contends that several objectives outlined in the draft are either overly broad or insufficiently justified.

He also questioned whether the proposal satisfies the principle of proportionality.

"If the goal is simply to verify whether a mobile phone was legally imported, then once that verification is completed, retaining personal information indefinitely no longer appears necessary to achieve that objective," he said.

Another provision has also raised concern among privacy advocates. The draft allows the database administrator to use the registry for providing "other digital services," without defining what those services may include.

According to Hayrapetyan, the vague language could permit future uses of personal data beyond the purposes initially presented to the public.

Cybersecurity specialists have also expressed concern about the concentration of sensitive information within a single government-managed database.

Arthur Papyan, founder of CyberHub, argues that the system would significantly expand the state's ability to monitor mobile phone usage.

According to Papyan, authorities would potentially be able to determine who is connected to mobile networks, which device they are using, and when those connections occur.

He also warned that centralizing information about virtually every mobile device and its owner could itself become a cybersecurity vulnerability.

"If this database is ever hacked—and there is no such thing as a completely secure system—everyone's security would be at risk," Papyan wrote.

Papyan also questioned government claims that the registry would improve efforts to recover stolen phones, arguing that victims have historically received little assistance despite providing IMEI numbers to law enforcement.

Government Signals Openness to Revisions

Responding to the criticism, High-Tech Industry Minister

invited representatives of both dpHub and CyberHub to participate in further discussions on the draft legislation.

Meanwhile, Member of Parliament Babken Tunyan said parliament could organize a public hearing within the next two weeks to examine the proposal and address concerns raised by civil society and technology experts.

The legislation is expected to receive its first parliamentary reading in September.

The draft legislation was prepared by Armenia's Information Systems Agency Foundation in cooperation with the Ministry of High-Tech Industry, the State Revenue Committee, and the country's mobile network operators.

The proposal was first published for public consultation in February 2026.

If approved by parliament, Armenia plans to launch the nationwide IMEI registration system on January 1, 2027.

The proposal has sparked a broader public debate over how governments can combat illegal trade and strengthen digital security while safeguarding citizens' privacy and ensuring that expanded technological oversight is accompanied by robust legal protections and transparency.

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