The Ministry of Justice (MoJ) presented for public consultation draft amendments to the Law on Public Service, aiming to regulate transparency of interactions by public officials that could affect policy making. The draft does not introduce any registration or reporting obligations for CSOs engaged in advocacy and has generally been assessed positively by experts. Nonetheless, there is a risk that the reporting obligation could have a chilling effect on some officials’ willingness to engage with CSOs.
What the amendments change
The initial draft package on transparency of officials’ interactions, which the MoJ shared with anti-corruption CSOs to seek their opinion, proposed amendments to the Constitutional Law on the Rules of Procedure of the National Assembly, Law on Public Service, Law on Local Self-Governance, and other laws, covering officials across executive, legislative, and local self-governance bodies. The drafts set a requirement for officials to report about their communication with individuals or legal entities aimed at law-making, the development of strategic documents, or community development programs. In July 2025, the Ministry of Justice presented the proposed regulations to CSOs at a public discussion, and pledged to take CSOs’ comments into account and revise the package for further consultation. However, in October 2025, the Ministry opened public consultation only for the draft amendments on the Law on Public Service, limiting the scope of legal amendments to high-level officials in the executive branch.
The draft requires the Prime Minister, advisors to the Prime Minister, Deputy Prime Ministers, advisors to Deputy Prime Ministers, ministers, advisors to ministers, and deputy ministers to report about any oral or written, direct or mediated communication with individuals or legal entities aimed at law-making (including normative, local and individual acts) or the development of strategic documents.
The draft law also lists the cases that are exempt from the reporting obligation, including:
- communication with other public officials,
- communication with international actors in the framework of obligations under the international treaties,
- undertaking a legislative initiative through a civic initiative, including communications related to the law submitted for referenda through a civic initiative,
- communications related to gathering or processing information by media representatives,
- communication related to exercise and protection of rights of physical and legal entities.
The proposed amendments are based on the Government's Anti-Corruption Strategy and its 2023-2026 Action Plan, which envisage measures to enhance transparency of interaction with lobbyists and other third parties seeking to influence the legislative process. The need for these regulations is also underscored in the 5th round evaluation report of Armenia by the Council of Europe Group of States against Corruption (GRECO). The report highlights the absence of lobbying rules and recommends establishing clear standards to ensure adequate transparency in the legislative process as an essential condition for building public trust in democratic institutions.
How the proposed amendments could affect CSOs
Experts generally view the proposed amendments as positive steps toward enhancing transparency and preventing corruption. Several CSOs welcomed the initiative to increase transparency around lobbying, though highlighted specific issues that are open to broad interpretation, such as making exception for the communication related to the rights of physical and legal entities,. CSOs also recommend that similar obligations should apply to members of parliament as key actors in the legislative process, as well as to local self-government bodies in relation to community-level norm-making.
Currently, Armenian CSOs are free to participate in policy-making and advocacy without any special status or registration requirement. The draft amendments do not introduce any such obligations for CSOs, nor do they impose additional compliance requirements on advocacy organisations. However, the practical impact of the amendments on officials’ engagement with CSOs remains to be seen. While the regulation would not directly affect CSO advocacy, experts warn that the reporting requirement could have a chilling effect on some of public officials, discouraging them from engaging with CSOs. For example, the broad definition of “communication” can potentially include providing information or expert opinion, and officials may become more cautious in engaging with civil society to seek their expertise or comment on any issue related to policy making. The obligation to report may also discourage their dialogue with CSOs if they avoid publicity, for example, in case of meeting with organisations working on sensitive issues (such as sexual minorities’ rights).
ECNL’s latest briefer provides examples on how to best regulate lobbying whilst making sure it does not limit or negatively impact advocacy activities and the right to participation.
The draft amendments to the Law on Public Service mark an important step towards greater transparency of interactions between public officials and external actors. Further developments can be expected in coming months as the MoJ reviews feedback and prepares the revised package. CSOs are likely to continue advocating for more specific definitions and a comprehensive approach - extending transparency requirements to parliament and local self-government bodies - in line with GRECO recommendations.
The CSO Meter will continue monitoring the law’s adoption and implementation to ensure that the final regulation promotes transparency without discouraging legitimate CSO participation. If implemented inclusively, the initiative could become an important step toward more transparent and corruption-resilient governance in Armenia.