The Armenian Parliament has adopted amendments to the Law on Audiovisual Media aimed at clarifying rules on prohibited audio-visual content, related sanctions, and responsibilities of the oversight body. According to the government, these amendments seek to improve legal clarity, ensure equal competitive conditions for network operators, broadcasters and distributors, and reduce the dissemination of harmful content. Among other provisions, the amendments prohibit foreign audiovisual programmes from disseminating content that may influence or interfere with Armenia’s domestic political developments. While the reform is presented as a step towards enhanced legal clarity and protection of the information space, concerns were raised about expanded state oversight and potential risks to freedom of expression.
Amendments seek to address legal gaps and emerging information risks
The Law on Audiovisual Media has been in force since 2020 and defines the legal framework for the audiovisual sector, regulating licensing, authorisation procedures, and the rights and obligations of media service providers, broadcasters, distributors, and network operators. According to the government, the amendments were prompted by gaps and ambiguities identified in the law’s practical application, particularly regarding prohibited content and enforcement mechanisms. In addition, some provisions were shaped by concerns over growing hybrid interference and attempts to influence public opinion and domestic political life ahead of the upcoming parliamentary elections in Armenia in June 2026.
In 2025, the Ministry of High-Tech Industry in cooperation with the sectoral stakeholders developed amendments to address these shortcomings and risks. The draft amendments were published at the e-draft platform for public consultation, where stakeholders raised concerns regarding potential risks of misinterpretation and arbitrary application, as well as the expanded powers to be granted to the Commission on Television and Radio (CTR) - an independent regulatory state body in the field of audiovisual media broadcasting.
Following several revisions, the National Assembly adopted the amendments on 16th of April 2026. Overall, the final package of the amendments focuses on three major directions:
- Introduction of more detailed rules on prohibited content: Authorities noted that the original provision - prohibiting calls to unlawful actions - was not sufficiently precise, leading to inconsistent enforcement and frequent legal disputes. The amendments, therefore, seek to set out clearer rules on the types of content that may not be disseminated through audiovisual media in Armenia. The prohibited categories include content that promotes the violent overthrow of the constitutional order; advocates war; contains propaganda of violence or cruelty; incites hatred or discrimination; distributes pornographic material; encourages criminal or illegal acts; or promotes criminal subculture.
- Regulation of foreign programmes to reduce risks of external influence in domestic political processes: The new rules apply to foreign content broadcast via public multiplexes and cable networks and prohibit the dissemination of content that interferes with Armenia’s domestic political life. Earlier, the regulatory body lacked adequate legal mechanisms to respond to such foreign influence. Under the new regulations, CTR may initiate administrative proceedings in cases of suspected violations, request relevant records from broadcasters, and, where a violation is documented, require the suspension of the broadcast of the foreign programme. The new provisions require network operators to present notification to the CTR with information on the foreign programmes to be broadcast and get confirmation by the regulatory authority before starting the broadcasting.
- Expanded powers of the regulatory body: The amendments grant stronger enforcement tools to CTR, allowing it to suspend or terminate the licences of network operators in cases of violations. Regulatory requirements applied to local channels operating in public multiplex will now extend to network operators, providing the CTR with authority to sanction them.
Concerns persist regarding risks to freedom of expression
Civil society organisations (CSOs) and media experts acknowledge the need to address the legislative gaps and tackle external influence, particularly in the light of intensifying information threats and media manipulations. However, the experts highlight risks associated with the breadth and ambiguity of certain provisions. Key concerns include:
- The potential for arbitrary interpretation of prohibited content, as broadly worded provisions lacking clear definitions and criteria make them open to discretionary interpretation.
- certain categories, such as propaganda for violence or criminal subculture, remain unclear, requiring reference to other laws to interpret them.
- New powers granted to the CTR could create room for discretionary interference.
Opposition parliament members have criticised the amendments, warning that they may enable censorship and undue state interference in the media environment due to vague formulations.
Overall, the amendments represent a comprehensive attempt to modernise Armenia’s audiovisual media regulation. However, the scope and depth of the proposed changes suggest that their practical implications will significantly depend on implementation, interpretation, and the safeguards applied in practice.
The reform may have mixed implications for civil society and public discourse
The proposed amendments may have both direct and indirect implications for CSOs, particularly those engaged in media monitoring, freedom of expression, and public advocacy. On the one hand, clearer rules on harmful content and stronger safeguards against harmful content could support CSO efforts in promoting responsible and ethical media practices and countering disinformation. On the other hand, increased regulatory powers and oversight along with vague content restrictions may affect CSOs’ ability to disseminate critical viewpoints, or engage freely in public debate through audiovisual platforms.
Implementing measures will be key to ensure balanced application
In the upcoming months the government is expected to adopt relevant by-law regulations, including standards for preventing abuse during the distribution of audiovisual programmes. The content and quality of these by-laws will be critical in determining how the amendments are applied in practice. Ensuring that these rules are sufficiently precise and aligned with international freedom of expression standards will be essential to minimise risks of arbitrary enforcement. CSOs are expected to play an important role in monitoring implementation, assessing potential effects on freedom of expression and media pluralism, and advocating for balanced and transparent application of the law in line with democratic standards.