The new legislative package proposed by the Ministry of High Technology Industry aims to
- establish a unified data policy,
- reduce cybersecurity risks coming from digitalisation of government services, and
- set up a regulatory body to implement consistent data protection mechanisms for national security.
The draft law on public information has been under discussion since December 2023 and continuously improved by the Ministry, including based on the recommendations submitted by civil society.
In particular, the first version of the legislative package proposed to regulate access to information and public data under one law. CSOs criticised this first draft and called for data policy to be regulated in a separate law, to avoid undermining Armenia’s existing achievements in access to information.
Following last year’s discussions between the Government and civil society, on May 06, 2025 the Ministry of High Technology Industry in collaboration with Information Systems Agency of Armenia (organisation that supports the Government to digitalise public services) released revised drafts of the laws on public information and on cybersecurity, aiming to create a more organised and secure digital environment for government operations. The Ministry justifies the importance of this legislative package by seeking to better protect personal information, streamline digital services across agencies, and strengthen national security in the face of growing cyber threats. In addition, the package includes a new draft Law on the Information Systems’ Regulatory Body, which suggests to establish an independent body to effectively implement the state strategies.
Enhancing data management and protection against cyber threats
Electronic governance in Armenia dates back to 1990s. The first initiatives to launch electronic services began in 2008, when www.egov.am system was launched incorporating more than 20 online services. Despite this initiative and progress, digitalisation of state services remains uneven and with no unified methodology applied across different government institutions. In addition to the inconsistent development of electronic governance among ministries, another key challenge is the lack of data synchronisation across state agencies. This hinders efficient service delivery.
To address these issues, the Ministry of High Technology Industry suggests new regulations through the Law on Public Information. These include setting up unified data collection principles across various state institutions, and applying “one-time” data collection approach, meaning that once the user submits the data, it can be accessed and synchronised by relevant state institutions to improve service delivery. Additionally, the draft law promotes an “open data” approach in government-provided data, requiring the government agencies to proactively publish non-classified information once a year.
In parallel to the advancement of electronic governance systems, several challenges have emerged, including the growing risk of cyberattacks, the need for preventive measures, and implementation of mitigation strategies. Currently, each government body runs its own cybersecurity measures and protocols. The absence of a unified and comprehensive state policy leaves the system vulnerable to cyberattacks.
To fill this gap, the Ministry of High Technology Industry drafted a new Law on Cybersecurity proposing to develop a nationwide cybersecurity framework to
- identify cybersecurity threats and categorise them,
- define response measures and protocols for various scenarios, including emergencies and military situations,
- establish clear roles and responsibility framework for state bodies, as well as
- increase public awareness and education in cybersecurity and cyber literacy.
To oversee and enforce these reforms, the Ministry proposes to establish an independent regulatory body. The Body will regulate data management practices, set cybersecurity standards, and promote cybersecurity awareness among the public.
The proposed legislative package on public information and cybersecurity derives from the commitments under Armenia’s 2022-2024 Open Government Partnership Action Plan.
CSOs raise concerns over contradictions and gaps
The CSO Meter country report from 2024 points out that despite legal guarantees and the Law on Freedom of Information, state bodies frequently delay requests for information, with some responses being incomplete or lacking detail. Proactive disclosure of information by state bodies in practice is also often not compliant with the legal requirements.
The new version of the Law on Public Information aims to promote data publication in line with “open data” principles and go a step further by requiring that the data be accessible to people with disabilities, ensuring greater inclusion. The new legislative package addresses several concerns raised by CSOs during the earlier stages of the law development. Particularly, it more clearly differentiates the law on Freedom of Information from legislation related to digitalisation. The revised law also outlines responsibility framework of the regulatory body, including the oversight of digital data, requirements for data collection and digital services. While many other points voiced by CSOs have been improved, some issues still remain. For instance, Freedom of Information Center of Armenia highlights a contradiction between the draft law’s Article 6 and Article 10 of the current Law on Freedom of Information. The draft allows charging reasonable fees for providing digital access to information, while the existing law clearly states that electronic information should be provided free of charge. The recommendation is to align the draft with the current legislation and ensure that any potential fees do not exceed actual delivery costs to maintain proportionality and compliance with freedom of information standards.
Additionally, Article 7 of the new law introduces new rules on proactive disclosure, shortening the deadline for mandatory publication from 10 days to 5 working days. However, this contradicts Article 7 of the current law.
The draft also gives the government the power to identify what information must be disclosed, which should instead be defined by law to avoid instability and arbitrary restrictions. The terminology used is unclear, leading to confusion about whether this refers to already mandated disclosures or new categories of information. The article needs clarification to avoid overlap and contradictions.
How will the reforms improve daily life of citizens and civil society?
With the “one-time” data submission and synchronised information systems, a citizen would no longer need to run from office to office—data would be shared securely across agencies, making services faster, more efficient, and less frustrating. In real life, it’s about reducing bureaucracy, saving time, and making public institutions more responsive and accountable to citizens.
Additionally, media outlets and civil society will benefit from statistical data that will be proactively published by state agencies, facilitating their data collection and monitoring activities.
Monitoring how the laws will be implemented in practice is essential
At this stage, the new legislative package appears to be an improved version of the previous laws. However, considering the findings from CSO Meter reports, which underscore that legal regulations often fail to be effectively and fully implemented in practice, particularly in the area of open data provision, it is important for CSOs to actively monitor the implementation of these laws. Currently, state institutions face challenges in properly disclosing the required information in accordance with the Law on Freedom to Information. In conclusion, support may be needed for the law implementation stage, including capacity building support for public servants to help them collect, analyse and publish data in accordance with the new requirements.