Public Administration in Armenia 2025

The Principles of Public Administration

Principle 13. The organisation and management of public administration foster accountability, effectiveness and efficiency.

Principle 14. Responsibilities are clearly distributed between levels of government, embracing the principle of subsidiarity and local autonomy, and facilitating inter‑institutional co‑ordination with effective oversight mechanisms.

Principle 15. Public administration is transparent and open.

Principle 16. The parliament, ombudsperson and supreme audit institution effectively scrutinise public administration.

Principle 17. The right to good administration is upheld through administrative procedure, judicial review and public liability. 

Principle 18. A coherent and comprehensive public sector integrity system minimises the risks of corruption.

Little progress has been recorded since 2018 in the field of organisation and accountability of public administration. The rationality and efficiency of the organisational setup of public administration remains the main source of challenges. The common problem across most policy areas in this domain is absence of clear policy direction and leadership, which affects both the quality of the legislative framework and its enforcement in practice.

The lack of clear policy direction and capacities to deliver long-overdue reform of the organisational setup for public administration have resulted in a fragmented and inconsistent institutional landscape. The possibility to delegate administrative functions to state-controlled bodies of private law is widely exploited to evade the management and accountability regime applicable to state administration (integrity rules, guarantees of open and competitive recruitment of staff and a transparent salary regime). Foundations and state non-commercial organisations are the most common vehicles used for this purpose.

The legal basis for multi-level governance in Armenia is relatively strong, but there is a notable gap between legislation and practice. Legislation is largely in line with European Union (EU) standards, including the principle of subsidiarity, elements of public participation and the possibility to establish inter-municipal co-operation. Municipal amalgamations¹ have increased the size of local units, strengthening their powers to a moderate degree.

On the other hand, despite a constitutional commitment to decentralisation and local self-government, Armenia has made limited progress in strengthening local government autonomy. Municipal amalgamations have increased the size of local units, but not their powers. Key deficits persist in competences, local government capacity, consultation, co-operation, oversight and HRM. In practice, inter-‑municipal co-operation1 has been completely neglected, as have mechanisms for citizen participation. Consultation with communities and their national association prior to state decision making takes place only sporadically on a case-by-case basis. The external oversight system is fragmented, appears to be underperforming, and needs to be systematised. Co-ordination among ministries on matters affecting local government has not been organised, and the development of a comprehensive strategy for local government reform remains pending. Overall, while legal frameworks exist, implementation remains weak.

The quality and clarity of the legislation on access to public information is questionable, with no regulation on re-use of data and no open data portal in place. However, the primary issue lies in the lack of robust oversight in this domain. Even the basic functions of monitoring and analysing administrative practice in handling public information requests are not performed, not to mention more ambitious tasks, such as auditing compliance with transparency rules among public administration bodies.

The oversight institutions (Ombudsperson Institution and Supreme Audit Institution) enjoy relatively strong guarantees of independence and extensive investigatory powers. However, their actual effectiveness in scrutinising public administration remains in question, as neither institution has yet developed reliable mechanisms to monitor implementation of their recommendations.

Thanks to codification of the procedural rights of parties to administrative proceedings and the extensive scope of judicial review of administrative actions and omissions, the right to good administration is generally secured. It should be stressed, however, that there is no central monitoring of efficiency and quality of administrative decision-making. Moreover, data on efficiency in handling cases by the administrative courts are increasingly worrying. No measures were undertaken to reduce the negative impact of the large and rapid influx of minor cases concerning traffic-related offences.

Public integrity and anti-corruption policy stands out as an area where clear strategic direction and strong policy ownership is demonstrated. However, the overall performance in this field is undermined by insufficient coverage of anti-corruption measures, as well as flawed regulation of the sanctions for integrity violations. Furthermore, the legislative framework on public integrity is incomplete, with regulation of lobbying activities still missing.

Overall, the existing legal framework, institutional set-up and related strategies and guidance are mostly in line with the Principles of Public Administration, while implementation practice and the corresponding results leave considerable room for improvement.

1. The Government should review the bodies currently performing functions of public administration in atypical organisational forms (especially foundations, state non-commercial organisations and closed joint-stock companies) with the aim of integrating them into the general regulatory framework for state administration, or at least ensuring greater alignment with the rules of open and merit-based recruitment, transparent salaries and public integrity.

2. The Government should consider gradual transfer of key public service responsibilities to local governments.2 This process should be supported by appropriate financial resources and capacity-building measures to ensure effective implementation.

3. The Government, in partnership with local authorities, should support inter-municipal co-operation, including updating the legislation and providing financial and technical incentives to foster collaboration, particularly in smaller or less-capacitated municipalities.

4. The Government and the National Assembly should reform and streamline both internal and external oversight systems over local governments by adopting clear, proportionate, and efficient procedures in legislation.

5. The Government should legally mandate structured and timely consultation with municipalities and their national association.

6. The Government should modernise local government HRM by adopting relevant legal amendments that enhance local discretion, support professionalisation and align with national civil service legislation.

7. The Government should allocate responsibility and the necessary capacities to a body tasked with oversight of the transparency of public administration, promoting proactive transparency and open data, as well as leading the process of improving the legislative framework. This does not have to imply creation of a new institution, but aims to ensure strong policy ownership and clear direction.

8. The oversight institutions (Ombudsperson Institute and Supreme Audit Institution) should considerably improve mechanisms to monitor the responsiveness of public authorities to their recommendations, including databases of all recommendations, with their current implementation status.

9. The Government, in co-operation with governing bodies of the judicial system, should develop targeted measures to mitigate the impact of the rapid increase of workload on administrative courts. This may particularly involve revision of the legislative and procedural framework for handling minor cases (administrative offenses).

10. The Government, in co-operation with the Corruption Prevention Commission, should tighten up the legislation on public integrity and anti-corruption, especially by developing regulation of lobbying activities and extending the coverage of integrity standards to the management of state-controlled foundations, state non-commercial organisations and closed joint-stock companies, as well as improving effectiveness of sanctions for integrity violations.

Principle 13: The organisation and management of public administration foster accountability, effectiveness, and efficiency.

Major problems persist affecting the rationality and efficiency of the structure of central government administration, and there is no clear policy targeting them. The organisational landscape of government administration is particularly complex, with numerous public agencies operating outside the general regime of governance, human resource management (HRM), salaries and public integrity.

The overall picture in the field of organisation of public administration has not changed significantly since the previous assessment, and SIGMA recommendations in this field were not implemented. Lack of progress might be attributed to the absence of clear policy ownership and strategic policy direction in the area of organisation of public administration.

While the relevant framework laws3 establish general rules of organisation and governance of public administration bodies, a large number of classical public agencies remain outside this regime. They operate in various forms of private law, briefly described in the table below. Even some of the core functions of government administration are executed by such bodies. For example, the tasks of the MoJ relating to drafting of the legislation in the field of judicial and legal reforms are performed by the Centre for Legislation Development, a foundation established by the Government, while the official database of normative acts is run by Official Bulletin, a state-owned closed joint stock company (CJSC). Responsibilities in the area of standardisation and metrology are assigned to the body functioning in the form of a CJSC.

Atypical organisational forms make it possible to evade the general framework on recruitment, salaries and public integrity applicable to bodies recognised as part of state administration. This systemic inconsistency was identified by SIGMA during the previous assessment, but no progress has been made in addressing it. Moreover, in the recent period, new institutions of this special type have been created with no clear justification for excluding them from the general framework for public administration bodies.4

In addition, no major improvement was recorded with regard to strengthening ministerial control over the administration in their respective policy domains. All sectoral inspectorates5 remain accountable to the whole Government, not to relevant ministries. Some other single-sector public agencies (e.g. State Revenue Committee or Cadastre Committee) have the same institutional locus. This hinders ministerial capacities to enforce laws and policy priorities.

Another distinctive feature of the government administration is the existence of various committees that are formally subordinated to their respective ministries, but tasked with formulation of policies in the domain of these ministries.6 There is no clear rationale or proven added value for keeping them outside the ministries instead of transforming them into ministerial departments.

The existing mechanisms of governance and supervision of public agencies only promote results-oriented management to some extent. Annual plans of public agencies, prepared according to a uniform model,7 are formally approved by the portfolio ministries, as are financial allocations. However, these plans (and reports) concentrate on adjusting the workload (specific tasks) to the available workforce, rather than setting policy priorities and outcome-oriented targets. They serve more as a tool of HRM than performance management.

The rules of internal governance in the ministries moderately support managerial accountability. Deputy ministers, rather than professional managers, are responsible for co-ordinating policy areas, while the heads and deputy heads of subordinate bodies are political appointees. The position of secretary general is relatively strong, with most of the powers relating to internal management of the ministry assigned to this top civil servant. However, in the crucial area of recruitment, the minister retains the power of final signature when hiring the heads of ministerial departments. Furthermore, there are neither clear legal grounds nor practice of delegating the decision-making powers of the secretary general to lower-level officials. This creates an excessive burden for the secretaries general, especially considering that all ministries are relatively large organisations (at least 200 employees). In addition, managerial accountability is not sufficiently promoted through mechanisms of planning and reporting work in the ministries. Responsibility for delivering specific objectives and activities envisaged in the annual plans is not explicitly assigned to specific units of the ministry. The plans focus only on allocation of staff to the relevant tasks.

There is currently no designated central contact point for total quality management, no implementation of TQM tools has been reported. Additionally, no requirements or guidelines for calculating greenhouse gas emissions or other environmental impacts have been identified, and no central government bodies published data about their environmental footprint.

Principle 14: Responsibilities are clearly distributed between levels of government, embracing the principle of subsidiarity and local autonomy, and facilitating inter‑institutional co‑ordination with effective oversight mechanisms.

The institutional framework for local governance has seen some progress, particularly following the adoption of the European Charter of Local Self-Government. A major municipal amalgamation reform reshaped the country's administrative map and created large-scale local governments, minimising fragmentation. Nevertheless, decentralisation has advanced at a slower pace, and the local self-government system is characterised by a moderate scope of competences, the absence of formal and systematic consultation with municipalities, under-utilised inter‑municipal co-operation and citizen participation, and the fragmentation of administrative oversight mechanisms. There are no permanent co‑ordination mechanisms among ministries concerning policies that affect local government, nor is there a comprehensive long-term strategy for local government reform aimed at strengthening the sector.

Armenia’s territorial reform has successfully reduced the number of its municipalities (originally 915) into a streamlined structure of 71,8 laying the groundwork for more effective local governance.9 This consolidated territorial structure eliminated most small-sized municipalities and created larger-scale municipalities, similarly to the Western Balkans (Figure 43.), resulting in an average size of local governments of 37 900 inhabitants.10 It also empowered local governments with more competences. However, significant work remains to strengthen local government capacities and functional responsibilities, enhance financial autonomy, and ensure consultation and co-ordination among levels of governments. Completing the ongoing legal reforms and adopting a comprehensive decentralisation strategy are essential next steps.

The European Charter of Local Self-Government, adopted in 2002, committed to strengthening local governance. Ratification of the Charter was expected to trigger a series of reforms that would strengthen the position of local governments. Armenia gradually accepted all articles of the Charter and in 2013 ratified the Additional Protocol to the Charter on the right to participate in the affairs of a local authority. Despite reforms such as community mergers and laws on citizen participation, the 2020 Council of Europe report highlights five key shortcomings: 1) local governments still lack meaningful autonomy; 2) inter‑municipal co-operation is weak; 3) legal consultation mechanisms are absent; 4) administrative oversight is excessive; and 5) funding remains inadequate.11

This relatively weak performance on decentralisation reform has also been reflected in the study of the Local Autonomy Index (LAI) in Europe, solicited by the European Commission (Figure 44.). In Armenia, the index of local autonomy, which visibly increased in several countries of central and eastern Europe at the beginning of the 21st century, remained stable up to a slight increase after 2015, and it is considerably lower than the average for EU countries.

The Constitution guarantees local self-government as a foundation of democracy, with a dedicated chapter defining the status of local governments and their responsibility to address community issues. 12 However, it does not specify competences of local governments, leaving this to legislation. While the Law on Local Self-Government (LLSG)13 enshrines subsidiarity and allows communities to take on additional tasks, in practice their initiative is constrained by limited resources and state-imposed approvals.

Local government competences are classified into two main types: their own powers and those delegated by the state. Similarly, the responsibilities of communities are divided into mandatory and voluntary tasks concerning local public affairs.14 However, there is no clear definition of local authorities’ competences and delegated powers, which may cause central and local governments to perform overlapping tasks, as well as a lack of accountability. Most local services are managed by the central level. All local governments share the same competences. The scope of actually performed functions varies significantly across municipalities in accordance with their fiscal capacities. Thus, poorer municipalities rely on the deconcentrated bodies of the central government for service provision.15

Compared to other European countries, communities in Armenia appear to have a rather moderate range of responsibilities according to the legal framework (Table 5)

Notably, local self-government is not responsible for schools (except Yerevan) and hospitals and is usually incapable of offering a wide spectrum of social services. Some communities are responsible for water and wastewater management in their area, or/and for primary healthcare. Except for regulation, communities are responsible for waste management and also for parts of the transport system and preschool education. According to legislation, communities have some responsibilities for social assistance, cultural and recreational activities, environmental protection, urban development and construction supervision, but a significant segment of local governments is in reality not capable of coping with the corresponding tasks.

In 2023, the Prime Minister signed the resolution on Approving the Concept of Decentralisation of Powers in the Republic of Armenia. It stipulates that the strategy for decentralisation of powers and the programme of measures arising from it will be developed by 2026. Work on elaborating a draft law to amend the LLSG began on 20 March 2024.

Even though amalgamations significantly increased the average size of municipalities, communities in Armenia display considerable differences in size and capacity. Inter-municipal co-operation is referenced in both the Constitution and the LLSG.16 In 2018, a special law was adopted on Intercommunity Associations. Currently, 23 communities participate in inter-municipal co‑operation projects within the framework of a programme for democratic development funded by the Council of Europe, but there is neither a national policy nor financial incentives to support inter-municipal co‑operation.17 This is expected to change, and a new legal framework is already underway, which will be integrated as a special Chapter (No. 12. Inter-community and cross-border co-operation) in a new LLSG.

Legislation grants local governments the formal right to organise their administrative structures. However, in practice, any changes to staffing levels, structure or salary scales must be approved by the MTAI, limiting local organisational autonomy.18 As of January 2025, approximately 5 500 employees worked in community service, with fluctuations linked to amalgamations and budgetary constraints. The Communities Association of Armenia has highlighted increased workloads and the need to improve professional capacity. While the draft revision of the LLSG proposes reducing state approvals, the current institutional framework remains fragmented.

Supervision of local governments is fragmented across various inspectorates, ministries and regional administrations.19 While regional authorities annually review 30% of municipalities, ministries conduct four to five inspections per community each year. A national oversight body under the Office of the Prime Minister has been created, with a draft law expanding its mandate to assess the legality and effectiveness of local decisions, including oversight of state budget transfers (which represent 4% of the national budget).

Internal control and performance of the community administration and its staff is legally entrusted to the Community Leader20 and the Secretary of Staff21, with the latter playing the main professional management role and reporting to the Council of Elders. External oversight is primarily carried out by regional governors under the MTAI. While their role includes legal and organisational supervision, they also apply expediency control, an approach that is controversial in decentralised systems because it allows central authorities to overrule local decisions based on policy preference rather than legality, undermining local autonomy. Governors can refer municipal acts to court for annulment via the MTAI, but only after giving communities 20 days to revise the decision. In certain cases, such as a prolonged lack of quorum, the powers of the Council of Elders may be terminated. Conversely, communities have the right to seek judicial protection if they believe oversight powers have been exceeded.

The MTAI holds overall responsibility for local governance, although its expanding portfolio has diluted its focus. While its Local Government Policy Division consults municipalities on draft laws, other ministries engage only irregularly. Mandatory consultation with local governments is not legally required – aside from community mergers or divisions – and municipal input rarely influences final decisions.

Participation of local government associations in state co-ordination bodies is limited and informal. There is no institutional mechanism to align central government policies with local governance. Concerning finance, the MTAI is responsible for co-ordinating with the Ministry of Foreign Affairs concerning the ordinary transfers from the state budget to the Communities, and the subventions for co‑funded municipal projects are allocated by a board chaired by the Deputy Prime Minister. A new version of the LLSG, currently under discussion, is expected to address many of these systemic gaps and scattered steering of local government issues.

The Constitution guarantees political autonomy through direct elections of local councils for five years.22 Smaller communities (under 4 000 voters) use majority voting, while larger ones use proportional representation, with the council electing the community head.23 Although the legal framework provides for several mechanisms for citizen participation, such as local referendums and public hearings,24 these instruments appear to be out of practice; no referendums have occurred in the past four years.25

On the SIGMA Survey of Citizens on public administration 2025 in Armenia, conducted in March-April 2025, 50.42% of respondents reported high or moderately high trust in local government. At the same time, 46.49% of respondents indicated that the central government interferes too much in matters that should be handled by local authorities.26 This highlights both relatively strong public confidence in local governance and growing concerns about excessive central oversight.

Principle 15: Public administration is transparent and open.

Deficits of the legislative framework and institutional setup, along with absence of oversight of compliance with transparency standards, remain the major challenges to securing an effective right of access to public information. Lack of strong policy ownership and direction hinders progress in this field.

The right of access to public information is secured by the Law on Freedom of Information (LFI),27 which is not fully compatible with international standards in the field. As confirmed also by the Council of Europe’s assessment28 of the implementation of the Tromso Convention,29 the LFI lacks sufficient clarity in defining the information subject to disclosure, as well as the bodies that fall under the transparency regime.

In particular, the information subject to disclosure is defined as “data on a person, subject, fact, circumstance, event, reality, matter received and formed as prescribed by the legislation, irrespective of the form of possession or tangible media thereof (text documents, electronic documents audio and video recordings, photographic films, drawings, schemes, notes, maps)”.30 This definition does not fully cover all information recorded in any form, drawn up or received and held by public authorities, as it is confined to information "received and formed as prescribed by the legislation". It may serve as a ground for restricting access to information obtained or held by the public bodies without explicit authorisation in the law.

What is even more problematic, the LFI fails to ensure sufficient subjective coverage of the transparency requirements. The scope of this law extends to state and local self-government bodies, state institutions and organisations financed from public budgets, as well as public interest organisations and their officials. Public interest organisations are further defined as non-governmental organisations that have a monopoly or a leading role in the goods market, as well as those providing services to the public in the spheres of health, sport, education, culture, social security, transport, communication and communal services.31 This definition does not explicitly and clearly guarantee that all bodies exercising public authority are considered as information holders. Moreover, this definition does not ensure that all atypical forms of public administration mentioned under Principle 13 are included.

Finally, while the catalogue of legitimate restrictions in access to information remains largely compatible with international standards, limiting access to “data requiring restriction of accessibility, conditioned by professional activity (medical and notarial secrecy, attorney-client privilege)”32 raises some concerns. It is clear that various types of professional secrecy deserve protection. However, this formulation is too vague and extensive, opening the possibility to restrict access to information beyond professional secrecy. It should be also noted that amendments made in 2023 to the Law on State Secrets may serve as additional grounds for excessive limitations in access to information. The amendments introduced the notion of “information of limited distribution” that is not classified as a state secret but still might be restricted in access, based on some additional grounds not listed in the LFI.33

In practice, it should be noted, however, that some important datasets (e.g. public statistics, procurement data, company and real estate registers, and results of the elections) are already available online. Citizens may also access consolidated versions of the legislation, as well as basic planning documents of the Government.

However, the overall picture of openness and transparency in practice is less optimistic. There is no open data portal in place and no access to real-time and dynamic data in basic domains (air quality data, live weather data, transport and traffic information). It needs to be also underlined that the LFI and other acts fail to regulate re-use of public information. SIGMA’s review of websites of all ministries reveals problems with access to major planning and reporting documents, as well as to information on individual salaries of senior managers. According to the SIGMA Survey of Citizens on public administration 2025, the majority of citizens feel that the Government sometimes intentionally withholds important information from the public that it could safely release.

There is no central monitoring of performance of public institutions in the field of transparency. Some basic statistical data on processing public information requests have to be published on the websites of public authorities, but not all authorities comply with this obligation,34 and these data are not subject to aggregation and analysis. There is no body actively monitoring the situation in the field and promoting high standards of transparency of public institutions and no analysis of judicial practice in handling appeals against restricting access to information. Therefore, it is not clear whether the courts ensure fast and effective review of administrative actions in this field.

Persistent shortcomings in the legislation and the enforcement of transparency standards demonstrate a lack of policy ownership and direction. Recent developments serve as good illustration of this problem. Instead of revising the LFI, the Government decided to develop a parallel draft Law on Public Information (prepared by the Ministry of High-Tech Industry) regulating the same subject (access to public information), but providing a separate procedure for access and additional regulation on proactive transparency. It is not clear what the relationship will be between the two laws, and regulating the same matter in two separate laws will result in numerous practical challenges.35

Principle 16: The parliament, ombudsperson and supreme audit institution effectively scrutinise public administration.

Although guarantees of the independence of the oversight institutions (Ombudsperson Institution and Supreme Audit Institution) are established in the legislation, their effectiveness in holding public administration accountable and eradicating maladministration cannot be reliably evaluated, as neither body has in place a comprehensive system for tracking implementation of their recommendations.

Formal independence of oversight institutions is enshrined in the legislative framework36, recognised through international accreditation37 , and accompanied by an extensive mandate and clearly identified investigative powers of these bodies. However, some detailed aspects of the status of these institutions are not regulated in full accordance with international standards. The limit on staff numbers, along with the classification of job positions for the Ombudsperson Institution (but not for the SAI), is subject to approval of the Prime Minister38 which constitutes a clear and explicit violation of the required HRM autonomy of this body.

Furthermore, enforceability of the investigative powers of the Ombudsperson is questionable, as is the right to obtain responses to their recommendations. The body which receives the recommendation is obliged to inform the Ombudsperson in writing on the measures undertaken within the shortest possible time, but no later than within 30 days. In the case of lack of response, the Ombudsperson may publish through mass media special information on the authority and the specific official who did not respond to the recommendation or who failed to implement the measures envisaged by the recommendation. It may also report to the superior body. However, apart from this "public shaming" tool, there are no other measures ensuring enforceability of the obligation of public authorities to provide a response, such as disciplinary measures for responsible officials. On the other hand, it should be stressed that the Ombudsperson Institution did not report any major obstacles in performing its mandate.

Bearing in mind these gaps in the legislative framework, it should be emphasised that the major problem of the Ombudsperson Institution is the lack of a fully-fledged mechanism to assess its effectiveness in scrutinising the Government and tackling maladministration. There is no system providing comprehensive data on status of recommendations in individual cases, e.g. progress in implementation, reasons of non-compliance, necessary further actions and timelines. The Ombudsperson does not generate statistical summary of the implementation of recommendations in individual cases. Implementation of systemic recommendations formulated in the annual reports of the Ombudsperson is evaluated without any methodological guidance and criteria. The institution is at an early stage of developing a more advanced system for tracking implementation of systemic recommendations. More detailed data are available only for recommendations issued by the Ombudsperson in their capacity for the National Preventive Mechanism, and those data demonstrate a low level of responsiveness from public authorities.39

Citizens’ perceptions of the capacities of the Ombudsperson Institution to scrutinise the government correspond with the above-described challenges. The majority of the population is concerned about the effectiveness of this body, and fewer than half of the respondents to the SIGMA Survey of Citizens on public administration 2025 consider it to be independent and trustworthy.

The SAI is in the process of developing a system for tracking implementation of its recommendations, but as for the Ombudsperson Institution, no data are currently available on the number of recommendations issued, implemented and rejected or ignored by the public authorities. In the assessed period, the SAI also faced challenges of another nature. It has been encountering significant delays and constraints in accessing the premises, documents and information necessary to conduct audits. Recent amendments to the Law on the Audit Chamber are expected to solve these problems. To conduct its audits, the SAI is now granted free and open online access to documents and necessary databases maintained by the Republic of Armenia and local self-government bodies. Furthermore, it can now access legally protected information relevant to the audit of public property.

Good co-operation is established between the Ombudsperson and the Parliament. The annual report of the Ombudsperson is presented in plenary session of the legislature, and representatives of the Ombudsperson Institution regularly participate in the meetings of relevant parliamentary committees. The Institution is also active in the legislative process. In 2024, it analysed over 170 legislative proposals and provided nearly 226 comments or suggestions. According to the Ombudsperson, two-thirds of these recommendations were accepted.

Principle 17: The right to good administration is upheld through administrative procedure, judicial review and public liability.

Minimum standards of good administrative behaviour are secured in the legislation regulating administrative procedures. However, there is no central monitoring of performance of public authorities in handling administrative matters, and no adequate measures to sanction administrative wrongdoing.

The Law on the Fundamentals of Administration and Administrative Procedure40 provides basic guarantees of the right to good administrative behaviour that are also applicable in the specific procedures analysed by SIGMA. In particular, the parties of the procedures are provided with the right of access to files. There are detailed standards for the content of the administrative acts, requiring authorities to provide the legal basis and both the factual and legal justification for the decisions. The right to appeal against administrative acts, including against inaction of the administration is guaranteed.

However, the framework law on administrative procedure falls short in promoting more advanced and modern solutions contributing to good administration. In the administrative services SIGMA analysed, the once-only principle is not explicitly articulated and not implemented through specific procedural arrangements. There are no regulations enabling electronic submissions in administrative proceedings.

There is no body with general responsibility for monitoring administrative procedures and fostering their efficiency. Some basic statistical data on individual procedures are available, but only for procedures conducted by a single authority. For example, data on processing applications for work permits for foreigners are available because these cases are handled exclusively by a specialised public agency, the Migration and Citizenship Service.

Constitutional principles of the right to compensation for administrative wrongdoing are safeguarded by two parallel procedures for seeking compensation. Relevant regulations of this matter are provided in the Civil Code and the Law on the Fundamentals of Administration and Administrative Procedure, the latter governing matters relating to compensation for damages by administrative bodies.

The regulations of the Civil Code lack sufficient clarity in terms of a crucial aspect of the procedure, determining the illegality of the administrative action or omission providing grounds for seeking compensation. There is no clear guidance on whether a final court decision repealing an administrative act constitutes sufficient grounds for lodging a public liability claim.

The procedure regulated in the Law on the Fundamentals of Administration and Administrative Procedure provides more specific criteria and more detailed procedural guidelines. It requires the party to first submit the claim first to the administrative body that caused the damage, before initiating the judicial proceedings.

Lack of monitoring of administrative and judicial practice in public liability cases hinders the assessment of the situation in this field. While there is some evidence of functioning of the liability regime in judicial practice, the procedural effectiveness and impact of it on eradicating maladministration cannot be reliably evaluated.

Effective and fair handling of administrative judicial disputes

While an extensive right to judicial review of administrative actions and omissions is formally guaranteed, in practice, the escalating efficiency issues in the administrative courts of first and second instance have had a negative impact on ensuring access to administrative justice.

The single first-instance Administrative Court (AC) is accessible for challenging both administrative actions and omissions. Although access to administrative justice is not hindered for most applicants by court fees set at moderate levels compared to the average salary in the country, the legislation does not enable individual exemptions from court fees based on the material situation of the applicant.

The right to legal aid is guaranteed, including the right to seek professional advice in the preparation of claims, applications, complaints and other legal procedural documents, and also the right to legal representation before the court. Furthermore, applicants are reimbursed for their costs if they win the case against the public administration.

The AC has a broad mandate to issue various types of decisions, ranging from declaring the administrative act invalid in whole or in part, declaring the decision to refuse adoption of the requested administrative act by the administrative body invalid and obliging the administrative body to adopt that administrative act, to obligating public authorities to perform certain actions or refrain from performing them. Decisions of the first instance court may be appealed to the higher court without procedural restrictions.

Basic organisational and technical preconditions for smooth functioning of administrative justice are provided, including sufficient personnel supporting judges. Each administrative judge is assisted by one clerk and one legal assistant. Annual training programmes are adopted by the Justice Academy, and contain modules are addressed to the administrative judges. The electronic case management system is at a basic level of development, enabling registration of all events in cases, searching for cases or checking the current workload of an individual judge However, the system does not contain all documents of the cases, does not generate alerts relating to deadlines and necessary actions of the court, and does not support formulation of judicial decisions. Furthermore, it does not serve as a source of data for preparation of the regular reports on the judicial performance.41

The main challenge for the administrative justice system is ensuring the right of citizens to have their cases resolved in a reasonable time, especially considering both first- and second-instance courts. In 2022, the AC needed 292 days (on average), which was the exact median for all Council of Europe countries.42 However, due to a large influx of new cases in the following years (an increase of over 130%), the current disposition time in the first-instance courts clearly exceeds the European median. The situation is worse in the Administrative Court of Appeal. In 2022, the disposition time in the court was already nearly double the European median. In 2024, it reached nearly 15 months. Considering historical data since 2012 from the European Commission for the Efficiency of Justice (CEPEJ), the current performance of Armenia’s administrative courts is at an all-time low.

In these circumstances, the absence of an effective procedure to seek compensation for excessive length of the judicial proceedings is becoming particularly problematic, as is the lack of a clear plan to tackle the efficiency issues. The reasons for the current challenges, including the significant increase in the number of cases, are well known and have been previously identified within the system. The bulk of the new workload involves complaints against sanctions for traffic-related offences. During previous SIGMA assessments, the courts faced exactly the same challenges, which then were mitigated by a one-off amnesty for some traffic-related administrative offences. An amnesty introduced in 2018 temporarily solved the problem, but these kinds of incidental measures cannot be considered effective in longer run.

Principle 18: A coherent and comprehensive public sector integrity system minimises the risks of corruption.

Efforts towards public integrity are supported by extensive legislation and a strategic framework. However, in addition to the lack of regulation on lobbying activities, the effectiveness of the public integrity system is hampered by insufficient coverage of the obligations and restrictions aiming to prevent corruption. Some people in positions with increased risk of corruption in state administration, as well as managers of state non-commercial organisations, state-controlled foundations and companies, are not subject to crucial public integrity mechanisms, such as declarations of assets and income.

The basic legislative pillars of the anti-corruption system are in place, except for regulation of lobbying activities. This system includes regulation of all types of corruption-related offences, rules for processing whistleblowers’ reports, standards on assets and income declarations, and rules on managing conflicts of interest, accepting gifts and benefits by public officials, as well as post-employment restrictions applicable to former public officials.

Thanks to wide access to statistical data on investigating and prosecuting corruption-related offences, the practice in this area can be monitored, with the exception of disciplinary liability in the public service, where data on practice are not aggregated at the central level. However, the coverage of public integrity requirements and some qualitative shortcomings of the regulatory framework pose a continuous challenge.

First of all, the subjective scope of various anti-corruption measures does not cover all key public managers. For example, the obligation to submit asset declarations does not apply to the leadership of foundations, state non-commercial organisations or closed joint-stock companies controlled by the state and performing administrative functions. Only recently, the Law on Public Service was amended43 to open some possibility to demand declarations of assets and income, interest and expenditure from the heads of the state non‑commercial organisations and foundations established by the state, as well as companies controlled by the state. However, they were not obligated to submit declarations upon taking the relevant positions and leaving them or on an annual basis. According to the revised Law on Public Service, the Corruption Prevention Commission (CPC) can request submission of a so-called situational declaration on an ad hoc basis, based on the grounds indicated in Article 25.1 of the Law on the Corruption Prevention Commission. So far, no cases of application of this procedure have been reported.

Furthermore, even within the state administration bodies generally included in the public integrity system, not all public employees in high-risk positions are required to submit declarations. For example, not all the members of evaluation committees in public procurements conducted by public authorities are subject to this obligation. Only members who are in top positions in the institution (e.g. secretary general, minister) are required to report on their material status.

The CPC developed some mechanisms for risk-based selection of declarations for verification. On an annual basis, it determines the group of positions or types of public authorities that should be prioritised in analysis of declarations. However, more detailed methodology and criteria for identifying public officials with higher corruption risks is not in place.

Gaps and inconsistencies affect the system of sanctioning violations of public integrity rules. Sanctions for breaches of conflict-of-interest and post-employment rules do not apply to persons holding political office. Moreover, the mechanism of sanctioning other officials for violation of post-employment rules is not effective. The Law on Public Service stipulates that failure to comply with these rules shall entail disciplinary liability. However, this sanction is not effective in the case of officials who are no longer in the public service.

There is a good awareness among key actors in this field (especially the MOJ and the CPC) of the current shortcomings, with clear intention to fix them. The fifth Anti-Corruption Strategy, adopted in 2023 along with a corresponding Action Plan (2023-2026), also demonstrates strong policy ownership and a commitment to improving the public integrity infrastructure. However, in addition to the above-discussed problems, implementation of the strategy also faces challenges. In 2024, only slightly more than half of the planned actions were fully implemented.