Government decisions that expropriate property for projects that override public interest affect people’s property rights and livelihoods. That is why civil society has long pushed for stronger safeguards, more transparency and more meaningful consultation before such decisions are taken. The adoption of implementing rules for public consultations in property expropriation procedures marks an important step in this direction and putting Armenia's recent legislative reforms on participatory decision-making into practice. On 18 June 2026, the Government adopted Decision No. 880-N, which entered into force on 20 June 2026 and amended the Government Decision on the Organisation and conduct of public consultations.
The Government Decision amends the general rules on public consultations and introduces a specific procedure for draft government decisions declaring overriding public interest for property expropriation. This decision follows the February 2026 amendments to the Law on Expropriation for Overriding Public Interest Purposes, which introduced mandatory public consultations before such decisions are adopted - a reform secured through sustained civil society advocacy.
What changes with the amendments?
In addition to the online publication of draft expropriation decisions, changes include:
- Holding public hearings has now become mandatory,
- Documents substantiating both the existence of overriding public interest and the purpose of the proposed expropriation have to be published. These include urban planning, investment or other development programmes, maps, site plans and other relevant supporting materials.
- Notification requirements are strengthened, announcements have to be published through multiple official channels and ensure that affected property owners, possessors and holders of property rights are invited to participate in public hearings.
Civil society kept pushing for strong safeguards in expropriation processes
The adopted framework reflects the impact of sustained civil society advocacy during the consultation process. Following the publication of the draft decision in May 2026, a coalition of CSOs submitted detailed recommendations aimed at strengthening meaningful public participation. These recommendations were also discussed with the Ministry of Justice at a dedicated meeting.
Several proposals were incorporated into the final decision. In particular, the Government introduced an obligation to publish supporting documentation together with the draft decision including urban planning, investment or other programmes, and where available, maps, site plans, and other materials containing relevant information on the areas subject to designation as overriding public interest. CSOs had recommended introducing a clear obligation for the competent authority to consider and respond, with reasoned justifications, not only to written but also to oral submissions made during public hearings. The adopted decision specifically reflects this recommendation by explicitly requiring that both written and oral comments are included in the summary record and are subject to acceptance or rejection with justification. These changes improve transparency and strengthen participants’ ability to engage with the evidence underpinning proposed expropriation decisions. At the same time, several key recommendations were not adopted. The final decision does not introduce public participation at the pre-draft stage, when the existence and justification of overriding public interest are first assessed, nor does it require authorities to present and discuss alternative options, including less intrusive solutions or options that would not require expropriation, before preparing a draft decision. As a result, while the new framework establishes important procedural safeguards, its effectiveness in ensuring meaningful participation will largely depend on implementation in practice.
Next steps
The adoption of Government Decision No. 880-N completes an important phase of reforms and provides the procedural framework necessary for implementing mandatory public consultations.
The next stage will be practical implementation. CSOs are expected to monitor whether public consultations are conducted in an inclusive, timely and transparent manner and whether comments submitted during the consultation process genuinely influence government decisions. Continued monitoring will also be important to assess whether additional legislative or regulatory improvements are needed to ensure effective public participation and stronger protection of property rights.