As part of the broader digitalisation of public services and modernisation of state-managed platforms, the Government introduced the requirement of electronic ID for logins to online public consultations. Decreasing accessibility, the new rules may also discourage people from participating, particularly on sensitive issues.
New rules replace email registration with mandatory identification
In June 2026, the government amended the procedure for organising and conducting public consultations on draft normative legal acts. Under the amendment, individuals and legal entities will no longer be able to submit proposals on draft acts published on the unified e-draft website through simple registration by name and email. Instead, users will be required to log in through the “YES EM” national identification platform in order to submit comments.
The decision provides a short transitional period: users who had already registered in the system may access the platform either through “YES EM” or by using their email address and password for one month after the entry into force. After 5 July 2026, however, access to the system for submitting proposals will be possible only through the “YES EM” platform, which requires stricter identification through electronic ID data.
The government justifies the amendment by referring to the modernisation of electronic governance tools and the need to ensure secure access to online public service systems through strong identification mechanisms. The change is also linked to the Government Programme for 2021–2026, which includes commitments to improve the quality of public services through modern and advanced technologies. From this perspective, the amendment is presented as part of a broader effort to unify and strengthen digital access to state-managed platforms.
Strict identification may create barriers to participation
While digitalisation of public services can improve efficiency and secure access to state platforms, applying strict identification requirements to public consultations raises concerns from the perspective of civic participation. The e-draft platform is not a service-delivery system in the narrow sense, but a public participation tool that should enable citizens, CSOs, experts, businesses and other stakeholders to provide feedback on draft legal acts.
The new approach may create practical barriers for individuals who do not yet have the necessary electronic identification tools or who face difficulties using digital identification systems. Although Armenia’s universal income declaration requirement has increased the need for citizens to obtain electronic identification, not all citizens currently have such tools or are equally able to use them. This may be particularly relevant for older persons, people in rural communities, and citizens with limited digital skills or access to technology.
The requirement for strict identification also raises concerns from the perspective of open civic participation. Public consultation platforms often serve as spaces where citizens can express concerns, criticism or alternative views on draft laws and policies. In some cases, participants may prefer not to publicly disclose their full identity, especially when commenting on sensitive issues or criticising draft regulations proposed by state bodies. While transparency is important, public consultation platforms should not impose stricter identification than is necessary for the purpose of collecting public feedback. This could reduce the diversity of feedback submitted through the platform and weaken the role of e-draft as an inclusive tool for public participation.
International practice favours accessible and flexible participation channels
OECD guidelines for citizen participation emphasise that participation mechanisms, including digital tools, should be accessible, inclusive and designed to facilitate public input. The Council of Europe Guidelines for civil participation in political decision-making also stress that at all stages of decision-making all appropriate information should be presented in clear and easily understandable language and in an appropriate and accessible format, without undue administrative obstacles. In several countries, including Croatia, Serbia and North Macedonia, as well as at the EU level through the Have Your Say portal, participation in public consultations generally relies on flexible online registration or login options, including email or social media accounts. In Croatia, additional identification options are available, including through digital ID, but these are not mandatory and remain a matter of user choice.
By contrast, Armenia’s new approach creates a more restrictive model than many comparable consultation platforms and may unnecessarily narrow the circle of participants. The e-draft platform has been one of the main online channels for CSOs and citizens to comment on draft laws and government decisions. Any change to its access rules should therefore be assessed not only from the perspective of technical security, but also in terms of its impact on participation, inclusiveness and civic space.
Mandatory identification may reduce the accessibility of consultations and undermine the principle that all interested persons should be able to contribute to policymaking, as well as have a chilling effect on citizens and CSOs wishing to submit critical or sensitive comments.
Next steps should focus on maintaining accessible and inclusive participation
CSOs are expected to monitor the practical impact of the amendment on public consultation processes, including whether the new login requirement reduces participation on the e-draft platform or creates technical and administrative barriers for users. Particular attention should be paid to the participation of citizens from regional communities, vulnerable groups, and informal initiatives. Continued advocacy will be needed to ensure that digitalisation of public consultations strengthens, rather than restricts, citizens’ ability to participate in law-making.
CSOs can also advocate the government to revise the approach by allowing multiple login options, including email-based registration, while keeping “YES EM” as an optional secure identification tool. This would better balance digital security with the principles of openness, accessibility and meaningful participation. Ensuring broad and inclusive access to public consultations would help strengthen participatory policy-making and preserve the e-draft platform as an effective channel for public input.