Armenia’s Parliament passed amendments to the Law on Police allowing the Ministry of Internal Affairs to access and operate a real-time biometric surveillance network across the country. Taking effect on August 9, 2025, the law grants the Ministry 24/7 access to surveillance cameras installed on public buildings, transport, and parking areas, enhanced with facial recognition technology. While promoted as a public safety measure, the Law raises serious concerns. It lacks clear legal safeguards, public oversight, and proper regulation of artificial intelligence (AI) technologies. As such, it poses a risk to the rights of privacy, freedom of peaceful assembly and non-discrimination principles as enshrined in both Armenia’s Constitution and its international human rights obligations.
Armenia establishes biometric surveillance in public locations
The newly adopted surveillance law in Armenia is the culmination of a multi-stage legislative process that began in 2024, marked by strong public backlash and evolving government strategies. As highlighted in our earlier update on the proposed surveillance law, in the beginning of 2024, the Ministry of Internal Affairs introduced a draft law requiring private businesses to install surveillance cameras and provide 24/7 live access to law enforcement. CSOs and international observers swiftly condemned the proposal as a disproportionate intrusion into personal privacy. Following widespread criticism, the ministry temporarily suspended the initiative.
However, the parliament members introduced another draft law with the same purpose, narrowing the scope of surveillance to state and community-owned buildings and parking lots. In February 2025, Civil Contract MP Hayk Sargsyan presented the draft law, framing it as a necessary measure to quickly respond to crimes and other possible violations of the law, as well as carrying preventive effect on crimes. In early March 2025, the National Assembly passed the amendments to the Law on Police in the second reading, with only members of the ruling party voting in favour.
The new Law empowers the Ministry of Internal Affairs to access real-time feeds from surveillance systems installed in the following locations:
- State and municipal buildings, including schools, hospitals, and cultural institutions,
- Airports and border checkpoints (excluding Defense and Intelligence agencies),
- Public parking areas, including those managed by private contractors,
- Public transportation, including buses and metro systems.
Facial recognition will be integrated into these feeds, enabling automated identification of individuals. According to MP Sargsyan, the system will detect both serious offenders and minor violations, triggering automated administrative penalties.
The law establishes new safeguards, yet biometric surveillance still lacks sufficient protection
Armenia has no legal framework to govern AI use, including facial recognition technologies. There are no standards for assessing risks, protecting rights, or ensuring transparency and accountability in the AI systems. The only legal provision directly addressing biometric surveillance appears in the amended Article 19 of the Law on Police. The draft includes a number of safeguards to ensure the transparent and accountable use of surveillance systems, such as strict identification of authorized personnel, electronic logging of access, mandatory timestamping of downloaded footage, and the introduction of specific liability for violations of these provisions. This marks an improvement over the version previously proposed by the Ministry of Internal Affairs, which did not contain such specific mechanisms. Nevertheless, several problematic provisions remain that could negatively affect the protection of human rights if not complemented by adequate oversight and control mechanisms. Thus, the amended Article 19 of the Law on Police vaguely states that police may “identify individuals through surveillance systems where there is reasonable suspicion” of an offense. This vague language grants wide discretion to law enforcement and opens the door to the use of biometric surveillance for any type of offense. Thus, the system is not limited to serious crimes. It also enables biometric identification for minor administrative violations (such as littering), raising concerns about proportionality and abuse of power. Moreover, the system conflicts with international human rights norms, including ECtHR rulings and EU AI regulations, the Advisory Committee of Convention of the CoE and the UN High Commissioner for Human Rights, which call for strict limits or moratoriums on public-space biometric surveillance.
The Law is especially concerning because it leaves crucial implementation details to be defined by sub-legal acts (for example, ministerial regulations), rather than enshrining protections and oversight mechanisms in primary legislation. This bypasses international best practices and undermines transparency, accountability, and legal certainty
How will this development affect life in Armenia?
The implementation of real-time biometric surveillance may have a significant impact on people in Armenia, potentially creating a chilling effect on public engagement and expression. Public spaces, especially those surrounding government buildings, schools, hospitals, and cultural institutions, will be placed under constant camera monitoring, with facial recognition identifying individuals in real time. These are the very spaces where citizens traditionally gather to express dissent, demand accountability, and exercise their right to peaceful assembly. The report by the Armenian Center for Political Rights identifies that the application of the provision on the use of facial recognition systems will inevitably lead to a number of human rights violations, including violations of the rights to privacy and freedom of peaceful assembly. In practice, this will deter participation in protests, civic campaigns, and even spontaneous public gatherings. Activists, journalists, and opposition groups may avoid organising events near surveilled locations to escape retaliation or stigmatisation.
In summary, while the law introduces a significant expansion of surveillance powers, there is a lack of clear legal, institutional, or ethical safeguards. Its broad scope, the limited oversight, and reliance on somewhat ambiguous legal language could raise concerns about potential challenges to democratic norms. In practice, there is a possibility that the system may become more of a tool for control than protection, potentially discouraging civic engagement and unintentionally amplifying discriminatory practices. Given that the law has not undergone a human rights risk assessment or been reviewed by the Council of Europe’s Venice Commission and the OSCE/ODIHR for expert opinions, its entry into force on August 9, 2025, raises significant concerns. To ensure that the law aligns with international human rights standards and democratic principles, CSOs proposed either to repeal the amended Law, or, alternatively, to postpone its implementation to allow for a thorough review by the OSCE/ODIHR and the Venice Commission. This process is crucial for safeguarding fundamental rights and ensuring that the law does not undermine democratic values. Without such action, Armenia risks institutionalising mass surveillance practices that are incompatible with democratic governance and the rule of law. The CSO Meter 2024 Armenia report’s recommendations on personal data protection safeguards and transparent and accountable measures for surveillance activities can also provide valuable guidance in shaping balanced and protective policies moving forward.