Public Administration in Armenia 2025

The Principles of Public Administration

Principle 2. Public policies are coherent and effectively co‑ordinated by the centre of government; decisions are prepared and communicated in a clear and transparent manner.

Principle 3. The government plans and monitors public policies in an effective and inclusive manner, in line with the government fiscal space.

Principle 4. Public policies are developed based on evidence and analysis, following clear and consistent rules for law making; laws and regulations are easily accessible.

Principle 5. All key external and internal stakeholders and the general public are actively consulted during policy development.

Principle 6. Public policies are effectively implemented and evaluated, enhancing policy outcomes and reducing regulatory costs and burdens.

Principle 7. The parliament effectively scrutinises the government policymaking and ensures overall policy and legislative coherence.

The assessment applies the established methodology commonly used for evaluating countries in the process of European Union (EU) accession. However, with regard to the Republic of Armenia, the analysis and recommendations are adapted to account for the political undertakings and binding legal commitments deriving from the Comprehensive and Enhanced Partnership Agreement (CEPA) concluded between Armenia and the EU.  

Several regulatory and institutional changes have been introduced in policy development and co-ordination in Armenia since the last assessment. In September 2025, regulatory changes were introduced to consolidate sector strategy planning and management as well as strengthen linkages with political and financial planning. The guidelines to support the application of new planning and monitoring requirements and procedures have yet to be developed. At the same time, an institutional reform of the regulatory impact assessment (RIA) system established a central RIA oversight function in the OPM and strengthened the role of sponsoring ministries. However, the consistency and quality of analysis accompanying draft regulations has declined, as few laws and regulations are actually subject to RIA. Although stakeholder engagement is carried out, it often takes place at the end of policy development and primarily through written consultation. Transparency of government and parliament decision-making, along with free and easy access to regulations, have remained exemplary. Parliament’s legislative activity has become more robust, as reflected in the reduced use of non-standard proceedings for adoption of laws.

Most of key centre-of-government (CoG) functions are assigned to institutions, primarily to the OPM, but some gaps remain. Responsibility for managing government transitions remains unclear. Internal co-ordination between various units of the OPM is in place, but collaboration remains limited between the OPM and other CoG bodies, such as the MoF and the Ministry of Justice (MoJ), during the preparation of the GAP. The quality control system for draft submissions is established but inconsistently enforced. Government decision-making is transparent, with the administration ensuring that government session agendas and decisions are prepared and published on time.

Armenia has strengthened its efforts in co-ordinating activities related to the implementation of the Comprehensive and Enhanced Partnership Agreement (CEPA). The Inter-Agency Commission, chaired by the Deputy Prime Minister, co-ordinates the implementation of the CEPA and other European Union (EU) related programmes and projects. In 2024, a working group under this Commission headed by the Deputy Prime Minister was established to develop an updated Roadmap for CEPA implementation. Furthermore, work is ongoing to develop the first CEPA Roadmap implementation report since its adoption in 2019. The Office of one of the Deputy Prime Ministers is responsible for overall daily co-ordination, however, no institution is formally assigned responsibility for European integration-related (EI) policy planning and reporting, or for co-ordination of the alignment of national legislation with the EU acquis. While the Inter-Agency Commission ensures political-level steering of EI, no administrative-level co‑ordination body exists. Although guidelines are prepared, the transposition of EU law1 is insufficiently regulated and organised, and key tools and procedures required for effective and evidence-based alignment of legislation with EU laws, such as Tables of Concordance (ToCs), are not institutionalised and implemented in practice. Planning and implementation of official translations is not timely.

Despite improvements in the overall planning system, the quality and coherence of government policy planning and reporting remain low. Only 7% of the objectives in the Medium-Term Expenditure Framework (MTEF) and 11% in the GAP include outcome-level indicators, and just 18% of GAP objectives for 2025 align with MTEF priorities. An even more serious issue is that 83% of draft laws approved in 2024 were developed outside the Government’s legislative plan. Sectoral strategy action plans are often delayed and poorly costed. Monitoring and reporting on government policy plans remain weak. Most central and sectoral strategy reports fail to track and discuss outcomes and progress towards policy objectives.

In 2018, the RIA system underwent reform that assigned the responsibility for conducting impact assessments to the proposing ministry, but RIA has not yet become an effective instrument to inform government regulatory policymaking. The system does not seem to be functioning well, as many important pieces of legislation and many regulations are considered and approved without adequate analysis of impacts and risks. RIA was carried out for only 4% of all primary legislation approved by the Government. Moreover, the quality of the actual RIA reports is weak, making them irrelevant and not used to inform final government decision-making. Challenges exist in both design and management of the whole RIA process, as well as the quality and consistency of RIA implementation and oversight.

Accessibility of legislation and regulations in Armenia is fully and effectively ensured. All legislation is easily accessible free of charge in consolidated format through the online legal registry.

Public and interministerial consultation is required for all legislation, except for strategies, and it is effectively implemented in practice. All legislation adopted by the Government are subject to consultation through the e-consultation portal. Compliance with requirements is high as all laws and strategies are published on the portal for public review. A key issue is the absence of a designated institution responsible for overseeing compliance with the rules on public consultations. Moreover, although ministries generally meet formal requirements for written public consultations, early stakeholder engagement and consultations and other stakeholder engagement tools are rarely used. Interinstitutional consultation with relevant bodies is still not required for ministerial-level secondary legislation, but otherwise procedural rules are appropriate, and compliance is generally high.

Policy implementation and ex post evaluation show significant deficiencies. Legal deadlines for adopting secondary legislation required by new laws range from 6 to 24 months following the adoption. Sector strategy implementation is uneven across sectors, and implementation of objectives is not being tracked. The practice of ex post evaluation remains underdeveloped, and Armenia has yet to establish a comprehensive evaluation framework. The Government does not have a central policy and institution responsible for better regulation. Initiatives aimed at administrative simplification and burden reduction are implemented, but mostly in the service delivery area, as part of digitalisation efforts.

The Parliament has adequate procedures and rules in place to monitor, scrutinise and guide the work of the Government, and lawmaking procedures are fully accessible and transparent. The number of government-sponsored bills adopted through the non-standard proceedings has decreased compared to the previous assessment. Key regulatory management tools, such as RIA and public consultations or legal review by the MoJ, are not utilised to inform parliamentary lawmaking, as the corresponding reports and opinions are not shared with the Parliament. The quality of lawmaking by members of parliament (MPs) is uneven, with variation across proposals, which could be explained by the absence of internal procedures and tools to support consultative and evidence-based lawmaking.

Principle 2: Public policies are coherent and effectively co‑ordinated by the centre of government; decisions are prepared and communicated in a clear and transparent manner.

The regulatory framework for effective central government co-ordination and decision-making is largely in place, and the implementation of key functions related to central quality control, transparency and organisation of government sessions and co-ordination is generally consistent. In practice, some gaps exist in ensuring procedural compliance of proposals and co-ordination of the GAP with central institutions. The procedures and rules for central co-ordination of activities related to EI need further enhancement.

Most key CoG functions and the corresponding institutional responsibilities are formally established, primarily through the Law on Government,2 the Law on Regulatory Legal Acts,3 and the Rules of Procedure (RoP) of the Government.4 Most of the CoG functions are formally assigned to the OPM. They are further elaborated in the Statute of the OPM,5 which allocates specific tasks to the internal departments of the OPM.

However, the function of the co-ordination and facilitation of smooth government transitions following elections is not assigned. The function of verifying the financial affordability of legislative proposals is vaguely regulated. Although the MoF consistently provides such opinions in practice, the RoP of the Government only state that proposers must submit their proposals to all “interested” bodies prior to government deliberation and that the MoF ensures financial examination of strategic documents.6

The RoP of the Government require internal co-ordination of policy proposals within the OPM through regular weekly pre-sessions prior to ministerial committee meetings.7 Evidence submitted to SIGMA confirms that these sessions occur regularly, with the participation of heads of all OPM departments and coverage of all items scheduled for discussions in ministerial committees or government sessions. However, there is no consultation with CoG bodies on the preparation of the five-year GAP and its annual revisions. While internal co-ordination within the OPM primarily takes place at the departmental level, there is no evidence that the OPM co-ordinates the draft GAP with the MoF or the MoJ outside the formal interministerial consultation process.

The rules for submission of policy proposals and the central quality check are in place,8 but the effectiveness of implementation of several CoG functions was found to be inconsistent in practice. The OPM is empowered to reject proposals that are incomplete or of insufficient quality.9 For example, in 2023, the Department for Social Affairs of the OPM rejected 255 out of 777 proposals for these reasons. However, the OPM does not ensure consistent checks of procedural compliance or alignment with government priorities. Although it reported that all draft laws approved by the Government in 2024 underwent procedural review, an examination of samples10 found one law11 lacking the mandatory state expert opinion from the MoJ and review by the OPM’s RIA Department. Additionally, checks on the alignment of proposals with government priorities are not carried out systematically, as evidenced by the sample review.12 On the other hand, financial viability assessments of proposals are conducted regularly by the MoF in practice. Despite these shortcomings, 78% of surveyed public servants agreed that CoG institutions co-ordinate decision-making adequately.

Government decision-making is transparent. Agendas and all supporting materials are consistently published online prior to government sessions.13 Following the sessions, decisions and press releases, including session video records, are also made publicly available.14 However, co-ordination of government communication is weak. There is no central communications calendar to synchronise and co‑ordinate policy announcements and events by various organisations. Additionally, there is no overarching communication strategy, central co-ordination of digital communications or training and guidance on digital media policy. Furthermore, no institution evaluates the impact and effectiveness of government communication.15

The legal framework for risk management is primarily established by the Law on Protection of the Population in Emergency Situations16 and the Law on the Rescue Service.17 These laws assign central co-ordination roles to the Ministry of Internal Affairs and the Rescue Service, which is also responsible for co-ordinating crisis response across the Government. However, these laws do not regulate, for example, the co-ordination of recovery activities or the preparation and regular updating of national risk assessments, which are currently not carried out due to this regulatory gap. A new, comprehensive law addressing the above gaps was adopted by the Parliament on 18 April 2025.18 This law sets out a comprehensive regulatory framework for risk management and defines roles and responsibilities of various institutions at different levels of governance. It specifies bodies that are responsible for co‑ordinating disaster risk reduction, emergency response and early recovery, as well as post-disaster recovery.19 It also introduces mandatory periodic risk assessments, with corresponding reports required to be submitted to the Government each April.20 However, its provisions will only take effect as of 1 January 2027, when the new law officially enters into force.21

The legal and institutional framework for managing the EI process needs further enhancement and streamlining. Overall daily co-ordination of EI process is assigned to the Advisor to the Deputy Prime Minister and the Department of Co-operation and Reforms under the Office of Deputy Prime Minister.22 However, the remaining functions, such as co-ordination of EI policy planning, reporting on EI policy implementation and co-ordination of alignment of national legislation with the EU acquis, lack institutional assignment. A new European Integration Department was established in the Ministry of Foreign Affairs23, but its mandate and division of responsibilities with the Office of the Deputy Prime Minister remain undefined. It is therefore important to clarify and streamline institutional responsibilities to ensure effective and coherent co-ordination of EI-related matters.

Interinstitutional co-ordination of EI is formally established at the political level, through the Inter‑Agency Commission chaired by the Deputy Prime Minister.24 Its members include parliamentary committee chairs, deputy ministers and agency heads. The Commission met several times in 2024 and 2025 to discuss CEPA implementation.

There is no regular review and reporting of the CEPA roadmap.25 Since its adoption in 2019, the CEPA roadmap has been revised once, in 2021.26 In October 2024, a working group composed of representatives from various ministries and agencies was established to prepare the next CEPA roadmap which is in final stages of completion.27 Although the CEPA roadmap has been in place since 2019, no implementation reports were prepared in prior years. The preparation of the first CEPA roadmap report is in progress.

Due to lack of data, it was not possible to assess the consistency of carrying out compliance checks of draft laws which aimed to transpose EU legislation in line with gradual and dynamic approximation defined through CEPA Annexes. Although guidelines on transposing EU legislation and translating the acquis have been prepared, they have not been formally endorsed or widely disseminated. As a result, institutions are generally unaware of their existence.

Principle 3: The government plans and monitors public policies in an effective and inclusive manner, in line with the government fiscal space.

The procedures and requirements for planning documents have been revised twice since the last assessment. However, the quality and alignment of planning documents remain weak. The implementation of government commitments is relatively strong, but most of the draft laws are initiated and approved by the Government outside formal government plans. The reports on implementation of planning documents focus on activities, but do not explain progress towards objectives or outcomes. In addition, the EI plan is not regularly updated, and no annual reports are produced on the EI process.

The policy planning system in Armenia has undergone several significant changes since the baseline measurement. Following the latest amendment in September 202528, the RoP of the Government became the primary document defining the requirements and procedures for policy planning.29 The RoP define the hierarchy and core requirements of strategic planning documents, categorising them into three primary groups: strategies; strategic programmes; and action plans of institutions.30 It outlines the scope, timeframe, approval process, accountability and co-ordination mechanisms for each type of document. The new regulatory framework stipulates that only six high-level strategies for a duration of seven years or more are to be adopted.31 Furthermore, the RoP clarify the interlinkages between strategic planning documents and other central planning instruments, namely the Government Programme, GAP, the MTEF, and the EI plan.32

Furthermore, the RoP of the Government stipulate that the main instrument to operationalise the implementation of the Government Programme is a five-year GAP which is developed within three months of parliamentary approval of the Government Programme and renewed annually.33 Meanwhile, the budgetary legislation,34 the annual Methodological Instruction on the MTEF and Budget,35 and the RoP of the Government36 require that the MTEF and sectoral planning documents reflect the Government’s priorities and its political programme and require the MTEF to take into account adopted strategic documents.

The PED of the OPM together with the MoF remain responsible for co-ordinating government-level policy planning. The PED leads the preparation and compilation of the GAP37, while the MoF oversees the preparation of the MTEF and annual budget. However, the quality of policy information within these planning documents remains insufficient. While both the GAP and the MTEF articulate policy objectives, neither of them consistently define measurable outcomes and indicators. Compared to the previous assessment, no visible improvements have been made, as only 7% of objectives (14 out of 192) in the MTEF for 2025-2027 include outcome-level indicators. For the GAP, the share is only slightly higher at 11% (51 out of 469 objectives). Both documents contain an excessive number of objectives, making realistic implementation challenging.

The alignment between central planning documents is weak. Of the 85 objectives in the GAP 2021-2026 with deadlines in 2025, only 15 (18%) align with the priorities identified in the MTEF for 2025-2027. Moreover, none of the 19 draft laws proposed in the sample strategies for adoption in 2025 were included in the GAP for 2025. Among the 127 draft laws approved by the Government in 2024, only 22 (17%) had originated from the GAP.38 The fact that 83% of adopted laws were developed and approved outside any formal plan undermines the relevance of the GAP as a guiding document and weakens overall policy co-ordination.

The quality of sectoral strategies remains a challenge. Of the five reviewed strategies,39 all were found to adequately identify policy objectives, but only three included a sufficiently comprehensive situational analysis with identification of core problems.40 Similarly, only three contained outcome-level indicators for all objectives,41 and only four included target values for those indicators. In one case, the monitoring, reporting and evaluation framework was also missing.42

Action plans, which are essential to operationalise strategic documents, are frequently delayed. For example, the Strategy for Improvement of Demographic Situation 2024-2040, adopted in October 2024, still lacked an action plan as of the end of May 2025. The same applies to the Employment Strategy 2025-2031, adopted in December 2024. Since action plans are necessary to estimate the financial implications of strategies, the adoption of both occurred without clarity on their expected costs or financial feasibility. In general, sectoral strategies rarely include clearly defined funding sources. Several indicate generic sources such as “means not prohibited by law”, making it impossible to estimate the projected financial impact of the measures. Robust costing remains a general challenge, largely due to the absence of methodological guidelines and official guidance, as well as the lack of a standardised template.

The existing quality control of strategic documents has practical gaps. The PED is mandated to assess the quality of strategies,43 and according to the information received, it reviewed all three sectoral strategies adopted in 2024. However, the sample review revealed that one of these strategies did not have a formal written opinion of the PED.44

On a more positive note, the implementation of the Government’s plans is relatively strong. According to the GAP summary annual information,45 81% of the activities planned for 2024 (496 out 613) were fully implemented. The remaining 19% were either partially implemented or not implemented. In terms of legislative output, 56% of draft laws planned for 2024 (14 out of 25) were adopted as scheduled, while 44% (11 out of 25) were carried over to the GAP for 2025. The situation has deteriorated compared to the previous assessment (baseline), when only 2 of the 61 laws initially planned for adoption were carried over to the next GAP. Also, none of the strategies planned for 2024 were adopted in time.

The quality of reporting on planning documents has not improved since the last assessment. In fact, annual reporting on the GAP has deteriorated. Under the RoP of the Government from 2021, consolidated annual reports on GAP implementation are no longer prepared. Instead, the OPM prepares only a brief statistical summary based on annual reports submitted by ministries, indicating the number of activities that were implemented, not implemented or partially implemented.46 These summaries do not include progress toward objectives or indicators, nor do they discuss challenges or suggest corrective measures. This reporting gap stems from the absence of a legal requirement to prepare and publish a comprehensive annual report from the OPM. As a result, anyone seeking a complete picture of implementation must review 16 separate ministerial reports – an approach that is not user-friendly. While these ministerial reports generally cover activity implementation, there is no standardised practice for reporting on outcome achievement. Some reports include this, while others do not, making it impossible to gain a comprehensive picture of government-wide results.

The quality of reports on sectoral strategies is rudimentary. Of the five reviewed reports,47 only three systematically tracked activity implementation,48 and only one provided complete information on outcome progress.49 Others lacked outcome reporting altogether or failed to cover all outcomes.50 None of the reports offered recommendations for more effective implementation or included data on actual budget spending. Apart from frequency, deadlines and co-ordination mechanisms,51 the reporting requirements and guidelines are not sufficiently defined, which was confirmed by the OPM.52 Despite these shortcomings, a significant share of civil servants believe that support is available for planning and reporting.

Reporting on the implementation of EI commitments needs improvement. Although implementing institutions are required to submit quarterly updates to the Inter-Agency Commission,53 there is no provision for the preparation of joint periodic reports. As a result, no such report has been prepared to date.54 Consequently, neither the Government nor the public has a comprehensive overview of the current state of EI efforts.

The publication of government planning documents is formally ensured. The GAP, including all its revisions, as well as all sector strategies are publicly available in the online register of legal acts. The summary report on GAP implementation is not published, although the annual ministerial reports are available online. The MoF website continues to publish regular reports on budget implementation.55 Of the 21 sectoral strategies required to produce annual reports in 2024, 20 reports were prepared and published.56

Principle 4: Public policies are developed based on evidence and analysis, following clear and consistent rules for law making; laws and regulations are easily accessible.

RIA is formally required, but consistency and quality remain weak. A large number of laws do not undergo RIA. Moreover, available analysis in RIAs accompanying draft laws is of inadequate quality. Although a central RIA oversight function was established in the OPM in 2021, it lacks sufficient mandate and coverage. Ministries do not have clear internal rules to ensure consistent and consultative policymaking practices. The stability of new laws is moderate, with some laws revised several times within the same year. Transparency and access to legislation are exemplary, as all legislation is published in consolidated form and is easily accessible to the public.

Although the PAR Strategy emphasises the importance of evidence-based policymaking and participatory governance,57 there is no whole-of-government policy in this area. Nor is there a dedicated government institution assigned to lead the Government’s better regulation agenda.58

At the ministerial level, there are no clearly established internal rules that govern when and how policy preparation takes place. The existing regulatory framework covers only procedures involving external stakeholders (e.g. other ministries, the OPM and non-state actors). Nevertheless, 82% of public servants agree that the quality of internal ministerial co-ordination during policymaking is satisfactory.59

The RoP of the Government stipulate that only government members can formally submit draft decisions for adoption.60 In practice, draft legislation is occasionally prepared and submitted by heads of agencies subordinated to the Government in areas that are typically within the ministerial policy responsibilities.61

Basic analysis of the impacts of draft laws and regulations are required by the RoP of the Government and are consistently provided in the explanatory memorandum.62 This document must include an analysis of the policy problem, the rationale for government intervention and the objectives pursued. The administration reported that memoranda were prepared for all laws adopted in 2024, and a review of five sample cases63 confirmed their consistent preparation. However, the situation is less robust regarding financial impact assessments. Although such assessments are also formally required64 and reportedly prepared for all draft laws, the sample review showed some deficiencies. Financial assessments of draft legislation often lack the necessary detail to support informed decision-making. In several instances, assessments are either omitted entirely65 or limited to aggregate figures without accompanying justification or calculations, as noted by the MoF in its opinions.

Since the last assessment, institutional changes in the RIA system introduced a previously absent central quality oversight mandate within the OPM and reinforced the responsibilities of line ministries in the RIA process. The current RIA system requires that short impact assessments be conducted by the proposing ministry and in-depth assessments be conducted by six sectorial ministries. The RIA Department established within the OPM in 2019 is responsible for quality review of RIAs and co-ordinates the planning of RIAs. However, significant challenges persist as regards the consistency and quality of RIA.

Although RIA is formally required, it applies only to draft regulations with "significant impacts on the business environment or the conditions of activities of individuals”.66 In 2024, RIA was not conducted for draft laws with significant impact, the list of which (around 30 laws) was prepared at the end of 2023 by the RIA Department, based on proposals from line ministries. As a result, only 4% of draft laws approved in 2024 (5 out of 125) were accompanied by an RIA report, and all were so-called short RIAs.

The quality of completed RIAs remains low. Although RIA reports contain situational analysis and objectives, they lack a thorough problem definition and provide little justification for government intervention. Evidence, data and statistics are largely absent. One contributing factor is the design of the official RIA template, which fragments the problem description across multiple sections (problem definition, causes, consequences, magnitude, stakeholders, urgency and trends), thereby hindering a coherent analysis.

In practice, identification and comparison of policy options are almost non-existent. Although the RIA framework requires consideration of alternatives, all sample RIAs presented only the status quo and the chosen policy solution. This occurred even in cases where such analysis would have been highly relevant (e.g. in legislation concerning social assistance or shadow employment). Qualitative analysis of impacts is rudimentary, while quantification and monetisation of costs and benefits are absent.67 There is no requirement to provide or practice of providing clear monitoring and evaluation mechanisms.

Progress in improving RIA quality is further constrained by weak oversight. The RIA Department of the OPM is responsible for reviewing all RIA reports.68 However, current regulations do not grant this department sufficient authority or mandate. The RIA Department does not automatically receive all draft regulations or all RIA reports, as it depends on whether the responsible policy department within the OPM decides to share them. For example, in 2024, the RIA Department did not receive one of five RIAs for review.69 Furthermore, a positive opinion from the RIA Department is not required for the draft to be submitted for government consideration. The department is not required to issue an opinion when no objections are raised. Hence, there were two cases in 2024 when a draft law and RIA report did not have formal assessment and an opinion from the RIA Department, despite shortcomings.70 Oversight is, therefore, not only weakly regulated, but also inconsistently applied in practice.

Legal drafting is regulated by nomo-technical rules adopted by the Parliament.71 Quality control responsibilities are shared between the Legal Acts Expertise Agency of the MoJ and, once a draft is submitted to Government for approval, the Legal Department of the OPM. While the authorities reported that all draft laws approved in 2024 underwent legal quality review, and that in 2024 the Legal Acts Expertise Agency provided around 5 000 official opinions,72 the review of samples confirmed that a state legal expert opinion was missing for one draft law.73

Overall, civil servants are satisfied with guidance and support provided by central institutions in policy analysis and legal drafting. Practical guidance materials are available to assist implementation of RIA.74 Furthermore, 75% of public servants report satisfaction with the quality and availability of central guidance and support for RIA, and 78% feel they have sufficient guidance and support when drafting legal acts.75

The stability of legislation is low, as the share of newly adopted laws amended within a year is 22%. In 2023, nine new laws were adopted, of which two were amended within 12 months.76 Some laws are subject to excessive revisions. For example, the Law on Medical Assistance and Services to the Population was amended five times in 2024 alone.

The current legal framework77 for publishing legislation is exemplary. The requirements for publication that took full effect on 1 July 2019 require mandatory consolidation of laws and their publication in the online legal registry.78 The regulation establishes clear timelines and ensures that all primary and secondary legislation is accessible to the public free of charge and in consolidated form. The online legal registry allows for user-friendly search by type, sector, date of adoption, date of entering into force, adopting authority etc.

The regulatory framework for evidence-based transposition of EU law remains underdeveloped. EI ‑related draft laws are subject to the same requirements for impact assessment and consultations as domestic legislation. However, key procedural elements are missing. The use of ToCs is not required, nor is a dedicated government institution designated to co-ordinate planning and monitoring of alignment with the EU acquis. The Legal Acts Expertise Agency of the MoJ is responsible for verifying compliance with EU law,79 but SIGMA was unable to assess the effectiveness of this function due to the lack of data on EI-related laws.

Although guidance for planning and implementing EU law transposition exists, these handbooks and methodologies80 are neither formally approved by competent authorities nor widely disseminated across government bodies. Consequently, awareness of their existence is limited. Furthermore, timely access to official translations of EU directives remains an issue. According to the CEPA roadmap, 21 EU directives and related regulations are scheduled for transposition in 2025. By May 2025, 14 have been translated into Armenian, while 7 (including 5 directives, 1 Commission decision and 1 regulation) had not been translated.

Principle 5: All key external and internal stakeholders and the general public are actively consulted during policy development.

Mandatory public consultation is required for laws and regulations, except for strategies, and is effectively conducted. However, the institution responsible for overseeing compliance with the rules on public consultation has not been assigned. Interministerial consultations are well regulated and applied consistently in practice for legislation and strategic documents.

The relevant legislation mandates public consultations for all draft laws,81 secondary legislation adopted by the Government and ministries,82 but not for strategies.83 The minimum period for written consultations is 15 days. This requirement is effectively enforced in practice, as the online consultation portal84 is technically configured to prevent shorter time frames. The legislation also requires the lead ministry to submit a written report on the outcomes of the public consultation to both the Government and the public. An amended version of the legislative or strategic document, reflecting the results of the consultation process, must also be published on the consultation portal.

The legal framework does not require that all relevant supporting materials, such as RIA reports or other analytical documents, be published alongside draft legislation. Their publication is left entirely to the discretion of the institution conducting the consultation.85

No institution is tasked with systematically reviewing compliance with consultation requirements. As part of its procedural review of materials submitted for government consideration, the OPM merely checks whether two formal documents – a consultation note and a report – are attached. The substantive quality or completeness of these materials is not reviewed.

Despite these shortcomings, 71% of public servants report satisfaction with the available support, advice and guidance on the consultation process.

While ministries largely comply with formal requirements, early engagement of stakeholders during problem analysis and the identification of policy alternatives remains rare. Non-state actors report that consultations are often held only at the final stage of the process, once the draft texts have already been prepared. Public consultation is mostly carried out though the e-consultation online platform, with limited use of other tools of engagement (such as meetings, roundtables or co-operation), as confirmed by analysis of sample laws and strategies.86 There is also still no practice of issuing advance notice of upcoming consultations, which would allow stakeholders to allocate sufficient time to provide high-quality input. Furthermore, providing supporting analytical documentation alongside draft laws is neither required nor practiced, although such information, if available in good quality, could enhance stakeholders’ understanding of the problem and lead to more constructive feedback.

The legally required 15-day minimum consultation period is consistently respected (in all ten reviewed samples), largely thanks to the technical constraints of the online platform. Ministries also regularly prepare formal responses to submitted comments, which are published both on the consultation portal and on the Government website.87 However, evidence was not sufficient to confirm that relevant analysis (e.g. an RIA report) is provided for interministerial consultation along with the draft laws.

Compliance with public consultation requirements is high. Nearly all draft laws (99%) and all strategies adopted by the Government in 2024 were subject to public review and consultation through the e‑consultation platform.88

Only 25% of surveyed citizens agree that the government consults and involves stakeholders from the private sector and civil society when developing new legislation or other policy documents, which is below the average rate of Western Balkan administrations in 2024 (32%).

The legislation also requires interministerial consultations with all relevant bodies for draft legislation and government-adopted strategies.89 However, such consultations are still not required for ministerial-level secondary legislation. Since the last SIGMA assessment, the minimum deadline for interinstitutional responses has been amended from five working days to seven calendar days, which may, in certain instances, result in shorter actual available time.90 For documents exceeding ten pages, the deadline has been extended to ten calendar days. The explicit obligation to consult the MoF has been removed, and now it is only mandatory to consult the MoJ. A lack of response from an institution within the prescribed deadline continues to be interpreted as agreement. The MoJ remains the only institution required to issue a formal opinion on constitutional compliance and legal drafting quality.

Along with draft laws and regulations, ministries are required to submit a summary report on the interministerial consultations conducted, detailing all the comments received and explanations of how they were addressed. Any partially accepted or rejected proposals must be accompanied by a justification.91

In practice, as noted in the 2019 baseline assessment, compliance with procedural rules is generally high. Consultations on draft laws and strategies are usually carried out within the prescribed duration and include consultations with relevant bodies.92 Ministries also consistently prepare and submit to the Government an interministerial summary report presenting all comments received and explaining their resolution in a structured table.

However, it is unclear whether supporting documents, such as RIA reports, are included in draft law packages during interministerial consultations.93

The top administrative interministerial conflict-resolution mechanism ceased to exist in 2021, following the revision of the RoP of the Government, which removed reference to special meetings convened by the Prime Minister, the Deputy Prime Ministers and senior staff of the OPM. Since then, only political-level Ministerial Committees chaired by the Deputy Prime Ministers and composed of ministers serve as the formal forum for interministerial dialogue and conflict resolution. As a result, 61% of public servants reported that differences of opinion between different line ministries are mostly resolved at the political level.94 Pre-sessions organised for OPM staff are held regularly and precede Ministerial Committees and Government sessions, but they are attended exclusively by the staff of the OPM.

Principle 6: Public policies are effectively implemented and evaluated, enhancing policy outcomes and reducing regulatory costs and burdens.

Weaknesses are observed in the implementation of sectoral policy documents and how results are monitored and reported, especially regarding tracking progress toward policy objectives. A significant share of laws enter into force without the required secondary legislation, which poses serious risks to effective implementation. Limited efforts are being made to introduce policy evaluation. Initiatives to reduce administrative burdens are implemented, but mostly in the area of service digitalisation.

Policy monitoring and implementation have significant deficiencies. Based on the information provided in strategy reports,95 69% of their planned activities had been implemented. However, there are significant differences across sectors. For example, the Judicial Reform Strategy performed strongly, with 91% of planned activities completed in 2023, while the Education Development National Programme showed weaker results, with just a 37% implementation rate. The achievement of strategic objectives and outcome-level targets is, on the other hand, neither adequately nor consistently monitored. There are no clear guidelines for ministries on how to report on implementation of central and sector planning documents or how to track implementation of activities and objectives. The same pattern is evident in annual reports submitted by ministries, which, like their annual work plans, remain focused on outputs rather than outcome-level objectives and targets.

Furthermore, significant delays persist in the adoption of secondary legislation necessary for the implementation of laws. Of the 53 bylaws required under 9 new laws adopted in 2023, only 23 (43%) were enacted within the legally required timeframe before the new regulatory regime introduced by primary legislation entered into force.96 The legal deadlines for adopting secondary legislation usually range from 6 to 24 months following adoption of the law.

There is no functioning policy evaluation framework in place. Over the past few years, several institutions have been assigned evaluation-related tasks, but their roles remain fragmented. The PED of the OPM is responsible for providing methodological guidance and support for carrying out studies on implementation of strategic documents.97 In 2024, the MoF established the Programme Evaluation and Internal Audit Policy Department to co-ordinate and conduct evaluations of budgetary programmes.98 Furthermore, the RoP of the Government foresee that the Deputy Prime Minister will co-ordinate strategy evaluation work.99 In the absence of evaluation policy, requirements, criteria and guidance, there is no clarity on how policies are to be selected and evaluated or how responsible institutions are to co-ordinate and conduct evaluations. No institution has been designated to lead or co-ordinate the evaluation of legislation. As a result, evaluation of laws or strategies are not conducted.

Although the RIA Department of the OPM is formally assigned to co-ordinate administrative simplification efforts,100 in practice the Information Systems Agency of Armenia is steering administrative simplification as part of the digital transformation of public services, including the creation of working groups with different ministries and agencies for adopting a life-events approach in service delivery. Analysis of administrative burdens during the development of new legislation is only partially in place. It is currently limited to the impact on businesses,101 with no obligation to assess burdens on citizens.

The Central Inspection Bureau in Armenia plays a co-ordinating and oversight role, and sectoral inspections are responsible for planning and executing inspections within their respective domains. Inspection authorities are not required to co-ordinate their activities to avoid duplication or reduce burdens on businesses, and there is no co-ordination of annual inspection plans before they are approved. This stems from a dominant institutional tradition that prioritises inspectorates’ autonomy over co-ordinated oversight. There is no statutory limit on the cumulative number of inspections or inspection days across all inspectorates for businesses. Limits are established only for individual inspectorates – up to 15 days per inspection, extendable to 25 days.102

The law requires a risk-based approach to inspection planning stipulating that 70% of entities inspected annually should be from the high-risk category and no more than 5% from the low-risk group.103 A review of three annual inspection plans (Labour, Food and Environment) confirmed that such an approach is followed in practice.

There is no single point of contact for inspection-related guidance. Businesses lack a unified online portal, helpdesk or call centre to seek advice on inspections or their rights and compliance obligations. Nonetheless, legislation mandates inspectorates to publish inspection checklists, which are used during inspections and help inform stakeholders of expectations.104 For example, the Health and Labour Inspectorate has published 48 such checklists on its official website.105

Elements of international regulatory co-operation are applied, but not consistently. The review of sample draft laws shows that ministries in some cases refer to international and regional best practices.106 In 2024, Armenia ratified six international agreements that provide opportunities for aligning regulations and standards with those of other jurisdictions, thus contributing to a less burdensome regulatory framework by eliminating duplicate requirements, introducing mutual recognition mechanisms and enhancing co‑operation in enforcement.

Principle 7: The Parliament effectively scrutinises government policymaking and ensures overall policy and legislative coherence.

Government representatives regularly take part in the parliamentary discussions, but co-ordination of the legislative agenda between the Government and the Parliament is weak. The share of government-sponsored laws adopted through non-standard proceedings has dropped since the last assessment. Supporting documents for government-initiated laws are not shared with the Parliament, and consultation between the Parliament and Government on MP-sponsored laws is not consistently conducted. The work of the Parliament is commendably transparent.

The right of the Parliament and its committees to debate, scrutinise, amend and oversee the implementation of government policies and programmes remains guaranteed by the Constitution and the RoP of the Parliament.107

Government representatives regularly participate in committee and plenary sessions of the Parliament.108 Although the RoP of the Parliament allow the Council of the Parliament to invite government representatives to meetings where legislative agendas are discussed,109 such participation does not occur in practice. Nor are there any other formal meetings between government and parliamentary officials to co-ordinate legislative planning.

Legislative work planning in the Parliament is done with limited input from the Government. The Government is not obliged to formally share its legislative work plan (which is in the GAP) with the Parliament, and in practice it is not done. The plan, including its revisions, is available online through the legislative database. Nevertheless, due to the significant discrepancy between the GAP and actual Government legislative output, the Parliament cannot reliably base its planning on the GAP. In 2024, only 17% of draft laws adopted by the Government (22 out of 127) were included in the Government’s original legislative plan.

When deliberating on legislation, the Parliament does not have access to all documentation that was provided to the Government during its own decision-making process. This poses a risk to informed parliamentary lawmaking. For instance, the Government is not required to submit the public consultation report, the interministerial consultation report or the RIA report to the Parliament, despite these being mandatory components for internal government deliberations. Under the current framework,110 the Government is only obliged to submit the explanatory note and a statement on budgetary implications. In the past, the RIA report was submitted to the Parliament, but the rules and practice have changed.

The timeliness of parliamentary processing of government-sponsored draft laws could not be assessed, as required data was not provided for assessment. But the share of government-sponsored laws compared to MP-sponsored laws in the total number of all approved laws by the Parliament in 2024 is 88%, which generally aligns with the practices of the Western Balkans and the EU.

The share of government-sponsored laws adopted through non-standard proceedings has declined since the last assessment. In 2024, 21% of government-sponsored laws were processes under urgent or shortened procedure (96 out of 454 government-sponsored laws) which is below the Western Balkan average in 2023. This number includes ratification of international treaties which, according to the RoP of the Parliament,111 are debated and adopted in one reading, thus shortening the time available for deliberation.

The rules governing urgent procedures do not allow the Parliament to make decisions regarding deliberation procedure. The Constitution has transferred the authority to determine whether a draft law is to be treated as urgent from the Parliament to the Government.112 Consequently, all draft laws deemed urgent by government decision must automatically be processed under the urgent procedure. Government requests are neither considered individually nor subject to parliamentary approval. This represents a highly unusual constitutional arrangement, whereby the Parliament does not retain control over its own procedures.

Draft laws initiated by MPs are subject to the same nomo-technical rules as for government drafts, but the requirements for mandatory supporting documents are different. MPs are not obliged to provide assessments of potential budgetary impacts.113 Additionally, the legislative framework does not require MPs to consult affected stakeholders.114 However, analysis of MP-sponsored laws shows that consultations do occur in practice by engaging various non-state actors and government institutions during the drafting process.115

The analytical quality of MP-sponsored laws varies. While some draft laws are supported by clear and well-structured justifications,116 others lack sufficient clarity, detail or justification of the proposed provisions. Nevertheless, every MP-sponsored law must be submitted to the Government for comment.117 In 2024, 62 such laws were adopted, with the Government providing formal written opinions on 55 of them.

The work of the Parliament is highly transparent. Its website118 publishes and regularly updates the legislative calendar, along with information on the status of each individual draft law. It also provides the latest versions of all registered draft laws and their amendments, as well as relevant committee reports, opinions and supplementary materials. Furthermore, it includes overall and individual voting results and publishes the conclusions of committee meetings. However, annual reports on parliamentary legislative activity are not produced. Despite the overall good level of openness and transparency of Parliament’s legislative activity, only 31% of citizens believe that the legislative process in Parliament is open and transparent to the public, which is lower than in the Western Balkans.

There is no formal requirement for regular ex post review of the implementation of laws under the parliamentary rules. Accordingly, no ex post reviews of laws or policies were conducted by the Parliament in 2024.