Update-2025-december-en

LEGAL UPDATE

December 2025

1. On making amendments and supplements to the Tax Code of the Republic of Armenia regarding the permanent establishment of a non-resident
organization or a non-resident individual.

2. On making amendments to the Tax Code of the Republic of Armenia regarding profit tax and deductible income.

1. On making amendments and supplements to the Resolution of the Government of the Republic
of Armenia No. 867 of June 29, 2002 on the issuance of licenses.

3. On making an amendment to the Civil Code of the Republic of Armenia regarding universal insurance.

4. On Amendments to the Law on Insurance and Insurance Activities.

5. Amendments and supplements to the Law on Medicines about to do.

6. On Amendments and Supplements to the Law on Medical Assistance and Service to the Population.

7. On Amendments to the Law on Conciliation.

1. On making amendments and supplements to the Civil Code of the Republic
of Armenia regarding mortgage contracts.

2. On Amendments to the law on state registration of rights to property.

3. On amendments and supplements to the law on cryptoassets.

1. On amending the Law on State Duties regarding goods classified under positions 7214 and
7215 of the EAEU Customs Tariff Code.

2. Law on the Information Systems Regulatory Authority.

3. On making additions and amendments to the Code of the Republic of Armenia on administrative offenses.

3.1. On Amendments and Supplements to the Law "On State Duty".

4. On making additions and amendments to the decisions of the Board of the Central Bank of the Republic of
Armenia No. 117-N of May 2, 2011, No. 323 of December 27, 2013, No. 19-N of February 16, 2016, and No.
332 of November 27, 2012 of the Board of the Central Bank of the Republic of Armenia.

1. On making amendments and additions to the Labor Code of the Republic of Armenia.

2. On establishing the procedure for entering into the digital system employment contracts concluded and continuing until January 1, 2026, as
well as individual legal acts on employment adopted and in force until July 1, 2025, and on making additions and amendments to the Resolution
of the Government of the Republic of Armenia No. 410 of April 10, 2025.

PART I. TAX SECTOR

(This section of legal updates includes legal news related to the tax sector for December 2025)

1. On making amendments and supplements to the Tax Code of the Republic of Armenia regarding the permanent establishment of a non-resident organization or a non-resident individual

Name of the legislative act

Law of the Republic of Armenia No. HO-377-N of 13.11.2025 on Amendments and Supplements to the Tax Code of the Republic of Armenia

https://www.arlis.am/hy/acts/217374

https://www.arlis.am/documentview.aspx?docid=194363

Change status:

The change to the law will take effect on December 4, 2025.

Which legislative act was amended by the adoption of the above-mentioned act:

With the adoption of the above-mentioned act, a change was made to the Tax Code of the Republic of Armenia.

What are the changes about:

TThe amendments relate to the clarification of the concept of a permanent establishment of non-residents in the Tax Code, the clarification of the procedure for taxation of income of employees of non-resident organizations, the simplification of the calculation of income tax, as well as the introduction of fully electronic provision and regulation of certificates confirming residency in the Republic of Armenia.

In particular, the amendments remove construction activities from the grounds for considering them as permanent establishments, establish the taxation of income of employees of non-resident organizations from work performed in the Republic of Armenia, simplify the procedure for calculating income tax payments to the budget, and introduce a procedure for fully electronic provision and validation of the Republic of Armenia residency certificate.

To repeal Part 6 of Article 27 of the Tax Code of the Republic of Armenia (hereinafter referred to as the Code) of October 4, 2016.

Article 27. Permanent establishment of a non-resident organization or non-resident individual

1. A permanent establishment of a non-resident organization or non-resident individual in the Republic of Armenia (hereinafter referred to as a permanent establishment) is considered to be any of the places of activity in the Republic of Armenia specified in this part, registered as a taxpayer with the tax authority in accordance with the procedure established by Chapter 58 of the Code, through which the non-resident organization or non- resident individual carries out entrepreneurial activities in the territory of the Republic of Armenia, regardless of the period of implementation of the activity, except for the case specified in Part 3 of this Article. 6) any place of implementation of construction activities and (or) construction and installation works, as well as provision of supervisory services for the implementation of such works;

To supplement Part 1 of Article 144 of the Code with the following paragraph 5:

Article 144. Sources of income

1. Income from sources in the Republic of Armenia shall be considered to be: 5) income paid to employees hired by a non-resident organization for work performed and/or services provided in the territory of the Republic of Armenia, if the income paid is considered an expense for the permanent establishment of the non-resident organization registered in the Republic of Armenia, regardless of the fact of deducting this expense from gross income, and/or the employees hired by the non-resident organization are involved in the activities of the permanent establishment.

Article 154. Part 1 of the Code shall be amended as follows:

Article 154. Procedure for calculating the amount of income tax payable to the state budget

Old version.

1. Based on the results of the reporting period, tax agents shall pay to the state budget the positive difference between the amounts of income tax calculated at the rate established by Article 150 of the Code in respect of the tax base relating to that period and the sums of temporary disability benefits and maternity benefits actually paid at the expense of the state budget of the Republic of Armenia in the given reporting period, as defined by the Law of the Republic of Armenia “On Temporary Disability and Maternity Benefits”. The benefits established by this part shall be considered deducted from the amounts of income tax calculated in respect of the tax base relating to the reporting period from the 20th of the month following the reporting period of deduction. The amounts of income tax calculated in respect of the tax base relating to the reporting period, as defined by this part, shall also include the amounts of income tax calculated in the cases established by Part 14 of Article 150 of the Code as the tax base for the 12th month following the tax year in which the right to receive income was acquired.

New version.

1. Based on the results of the reporting period, tax agents shall pay to the state budget the amounts of income tax calculated at the rate established by Article 150 of the Code in relation to the tax base relating to that period.

Article 314 of the Code shall be amended as follows:

Article 314. Provision of a certificate of being considered a resident of the Republic of Armenia

1. The tax authority shall confirm the status of a resident of the Republic of Armenia of organizations and individuals by providing electronically a certificate of being considered a resident of the Republic of Armenia in accordance with the form approved by the tax authority and/or by electronically confirming the form of a certificate confirming the fact of residency of the Republic of Armenia established by the legislation of a foreign state. A certificate of residency established by the legislation of a foreign state shall be considered a certificate confirming the fact of residency of the Republic of Armenia if its content corresponds to the content of the certificate of being considered a resident of the Republic of Armenia established by the tax authority.

2. For the purpose of confirming the status of a resident of the Republic of Armenia, the taxpayer shall electronically submit to the tax authority an application for confirmation of the status of a resident of the Republic of Armenia in accordance with the form approved by the tax authority, which shall include the following information:

1) In the case of legal entities registered in the Republic of Armenia and individuals registered as individual entrepreneurs:

a. taxpayer registration number, name, organizational and legal type, name and surname of the individual entrepreneur,

b. The year of approval of the status of a resident of the Republic of Armenia,

c. the name of the country where the certificate of being considered a resident of the Republic of Armenia must be submitted,

d. if necessary, a note confirming the form of the residence certificate prescribed by the legislation of the foreign state, attaching the form of the residence certificate prescribed by the legislation of the foreign state;

2) in the case of individuals (except for the case specified in paragraph 1 of this part):

a. taxpayer registration number, name, surname, passport data, public services number, address of residence or registration,

b. The year of approval of the status of a resident of the Republic of Armenia,

c. the name of the country where the certificate of being considered a resident of the Republic of Armenia must be submitted,

d. a note on the period of actual stay of the individual in the Republic of Armenia for 183 or more days during the tax year or on the location of the center of vital interests in the territory of the Republic of Armenia, attaching a free-form justification for the center of vital interests and copies of supporting documents,

e. if necessary, a note confirming the form of the residence certificate prescribed by the legislation of the foreign state, attaching the form of the residence certificate prescribed by the legislation of the foreign state.

3. The certificate of being considered a resident of the Republic of Armenia shall be provided electronically in the cases specified in point 1 of part 2 of this article immediately after the submission of the application, and in the case specified in point 2 of part 2 of this article, within two working days following the date of submission of the application. In case of rejection of the application for confirmation of the status of a resident of the Republic of Armenia, a notification of rejection shall be submitted electronically within two working days following the date of submission of the application, indicating the reason. The tax authority shall confirm the form of the certificate confirming the fact of residency, as defined by the legislation of a foreign state, electronically within two working days following the date of submission to the tax authority, and in case of rejection, it shall submit a notification of rejection, indicating the reason.

4. An application for confirmation of the status of a resident of the Republic of Armenia shall be rejected if the information and (or) documents necessary for confirmation of residency, as defined in Part 2 of this Article, have not been submitted.

5. The certificate of being considered a resident of the Republic of Armenia includes the following information:

1) taxpayer registration number, name, organizational and legal type, name, surname, passport data, public services number of the individual.

2) The year of establishment of the status of a resident of the Republic of Armenia;

3) the name of the country where the certificate of being considered a resident of the Republic of Armenia must be submitted;

4) a note to ensure the application of the agreement (convention) between the Republic of Armenia and the country of submission of the certificate for the avoidance of double taxation on income and property, if such an agreement (convention) exists in the year of establishment of residency;

5) the corresponding control code and quick response (QR) code generated by the system.

6. Confirmation of the status of a resident of the Republic of Armenia can be carried out for both the current and previous tax years, if the necessary information confirming residency for previous tax years is available. The certificate of being considered a resident of the Republic of Armenia is provided separately by year and country.

7. The certificate of being considered a resident of the Republic of Armenia is provided in Armenian, and if requested by the taxpayer, also in English and Russian.

2. On making amendments to the Tax Code of the Republic of Armenia regarding profit tax and deductible income.

Name of the legislative act

Law of the Republic of Armenia No. HO-471-N of 17.12.2025 on Amending the Tax Code of the Republic of Armenia

https://www.arlis.am/hy/acts/218638

https://www.arlis.am/documentview.aspx?docid=194363

Change status:

The amendment to the law will take effect on December 25, 2025.

Which legislative act was amended by the adoption of the above-mentioned act:

With the adoption of the above-mentioned act, a change was made to the Tax Code of the Republic of Armenia.

What the changes are about:

T

As a result of this amendment to the Law, complex regulations aimed at tax provision and promotion of the universal health insurance system are introduced into the Tax Code of the Republic of Armenia. In particular, first, the Universal Health Insurance Fund is included among the payers of profit tax, as a result of which the latter acquires the status of a payer of profit tax and operates in the general tax field, ensuring the financial transparency and accountability of its activities. In addition, the amendments expand the scope of tax benefits for health insurance premiums paid by employers. If previously only amounts paid for employee health insurance up to a certain amount could be considered as expenses or non-taxable income, now this scope also includes insurance premiums paid for the benefit of individuals or their dependents within the framework of universal health insurance, as defined in the Law on Universal Health Insurance.

Thus, as a result of the amendment to this law, a tax incentive environment is being formed that contributes to the financial stability of universal health insurance, the purpose of which is to encourage the participation of employers and other persons in the system and ensure its effective operation..

To supplement Part 2 of Article 103 of the Tax Code of the Republic of Armenia of October 4, 2016 (hereinafter referred to as the Code) with the following paragraph 6:

Article 103. Profit tax payers

2) Registered in the Republic of Armenia:

6) Universal Health Insurance Fund.

In Article 121, Part 8, Clause 1, Sub-clause “b” of the Code, after the words “in the amount of drams”, add the words “as well as insurance premiums paid for (the benefit of) individuals or their related persons within the framework of universal health insurance, as defined by the Law of the Republic of Armenia “On Universal Health Insurance”.

8. For the purpose of determining the tax base of a resident profit taxpayer and a non-resident profit taxpayer carrying out activities in the Republic of Armenia through a permanent establishment, the following are also considered expenses:

b. in the case of acting as an employer, insurance payments made for the health insurance of its employees, in the amount of up to 10 thousand drams per month of income received for each employee, as well as insurance payments made for (benefits of) individuals or their related persons within the framework of universal health insurance, as defined by the Law of the Republic of Armenia "On Universal Health Insurance".

In Article 147, Part 1, Clause 29 of the Code, after the words “in the amount of money”, add the words “as well as insurance premiums paid for (the benefit of) individuals or their related persons within the framework of universal health insurance, as defined by the Law of the Republic of Armenia “On Universal Health Insurance”.

Article 147. Deductible (non-taxable) income (deductions)

1. For the purpose of determining the tax base, the following are considered deductible (non-taxable) income:

29) insurance premiums paid by employers for the health insurance of their employees, in the amount of up to 10 thousand drams per month of income received for each employee, as well as insurance premiums paid for (benefits of) individuals or their related persons within the framework of universal health insurance, as defined by the Law of the Republic of Armenia "On Universal Health Insurance".

PART II: HEALTH SECTOR

(This section of legal updates includes legal news related to the healthcare sector for December 2025)

1. On making amendments and supplements to the Resolution of the Government of the Republic of Armenia No. 867 of June 29, 2002 on the issuance of licenses

Name of the legislative act:

"On Amendments and Supplements to the Decision of the Government of the Republic of Armenia No. 867 of June 29, 2002" Government Decision No. 1645-N of November 20, 2025 https://www.arlis.am/hy/acts/216834

Change status :

This Decision entered into force on December 1, 2025.

Which legislative act was amended by the adoption of the above-mentioned act:

With the adoption of the above-mentioned act, a change was made to the Government Resolution No. 867 of June 29, 2002 " On approving the licensing procedures for the production of medicines, pharmacy activities, the provision of medical care and services by organizations or individual entrepreneurs, the wholesale sale of medicines, the production of medical products, the provision of medical products and the forms of licenses for the implementation of the specified activities in the Republic of Armenia."

What the changes are about:

The changes relate to the introduction of a procedure for the electronic issuance of licenses and inserts for medicines and activities carried out in the medical sector .

In particular, it is stipulated that licenses for the production of medicines, pharmacy activities, medical care and service, wholesale sale of medicines, as well as the production and service of medical products can be issued not only in paper format, but also in electronic format , and the inserts attached to electronic licenses are also provided electronically, with a QR code and the possibility of online verification of validity ..

The following additions and amendments shall be made to the Resolution of the Government of the Republic of Armenia No. 867 of June 29, 2002 “On approving the licensing procedures for the production of medicines, pharmacy activities, the provision of medical care and services by organizations or individual entrepreneurs, the wholesale sale of medicines, the production of medical products, the provision of medical products services in the Republic of Armenia, and the forms of licenses for the implementation of the specified activities”:

After point 5 of the procedure approved by Appendix No. 1, add a new point 5.1 with the following content:

5.1. Licenses for the production of medicines are issued in paper or electronic form. In case of issuing licenses in electronic form (through the generation and rendering of the latter), the forms of licenses may differ from the forms of licenses issued in paper form approved by Appendix N 2 to this decision, while preserving the information specified therein, as well as containing additional information specified in Appendix N 2 for licenses issued in electronic form.

After paragraph 3 of the procedure approved by Appendix No. 3, a new paragraph 3.1 shall be added with the following content:

3.1. Licenses for the implementation of pharmacy activities are issued in paper or electronic form. In the case of issuing licenses in electronic form (through the generation and display of the latter), the forms of licenses may differ from the forms of licenses issued in paper form approved by Appendix N 4 to this decision, while maintaining the information specified therein, as well as containing additional information specified in Appendix N 4 for licenses issued in electronic form.

After point 4 of the procedure approved by Appendix No. 5, a new point 4.1 shall be added with the following content:

4.1. Licenses for the provision of medical care and services are issued in paper or electronic form. In the case of issuing licenses in electronic form (through their generation and display), the license forms may differ from the forms of licenses issued in paper form approved by Appendix N 6 to this decision, while maintaining the information specified therein, as well as containing additional information specified in Appendix N 6 for licenses issued in electronic form.

After paragraph 4 of the procedure approved by Appendix No. 9, a new paragraph 4.1 shall be added with the following content:

4.1. Licenses for the wholesale sale of medicines are issued in paper or electronic form. In the case of issuing licenses in electronic form (through the generation and rendering of the latter), the license forms may differ from the forms of licenses issued in paper form approved by Appendix N 10 to this decision, while preserving the information specified therein, as well as containing additional information specified in Appendix N 10 for licenses issued in electronic form.

After paragraph 7 of the procedure approved by Appendix No. 9, a new paragraph 7.1 shall be added with the following content:

7.1. The insert provided with the licenses for the wholesale sale of medicines issued electronically shall also be provided electronically. In case of issuing the insert electronically, the forms of the insert may differ from the forms of the insert issued in paper form approved in Form N 1 of this Appendix, while preserving the information specified therein, and also containing additional information specified in paragraph 18 of this Appendix, which is provided for inserts issued electronically.

After point 17 of the procedure approved by Appendix No. 9, a new point 18 shall be added with the following content:

18. Electronically issued inserts also contain a quick response code (QR Code) and the following note:

"FOR THE INTELLIGENT: _ _ __-_ _ __-_ _ __-_ _ _ __

This document is issued exclusively electronically. The validity of the document and the download of the electronic original can be carried out by entering the control number or scanning the quick response code (QR Code) on the website of the Unified System for Verifying the Validity of Official Documents of the Republic of Armenia https://verify.e-gov.am .

After paragraph 4 of the procedure approved by Appendix No. 17, a new paragraph 4.1 shall be added with the following content:

4.1. Licenses for the production of medical products are issued in paper or electronic form. In the case of issuing licenses in electronic form (through their generation and display), the license forms may differ from the forms of licenses issued in paper form approved by Appendix N 18 to this decision, while maintaining the information specified therein, as well as containing additional information specified in Appendix N 18 for licenses issued in electronic form.

After paragraph 6 of the procedure approved by Appendix No. 17, a new paragraph 6.1 shall be added with the following content:

6.1. The insert provided with licenses for the production of medical products issued electronically shall also be provided electronically. In the event of the insert being issued electronically, the forms of the insert may differ from the forms of the insert issued in paper form approved in Form N 1 of this Appendix, while preserving the information specified therein, and also containing additional information provided for inserts issued electronically, as specified in point 17.1 of this Appendix.

After point 17 of the procedure approved by Appendix No. 17, a new point 17.1 shall be added with the following content:

17.1. Electronically issued inserts also contain a quick response code (QR Code) and the following note: "FOR THE INTELLIGENT: _ _ __-_ _ __-_ _ __-_ _ _ __ This document is issued exclusively electronically. The validity of the document and the download of the electronic original can be done by entering the control number or scanning the quick response code (QR Code) on the website of the Unified System for Verification of Official Documents of the Republic of Armenia https://verify.e-gov.am .

After paragraph 4 of the procedure approved by Appendix No. 19, a new paragraph 4.1 shall be added with the following content:

4.1. Licenses for the service of medical products are issued in paper or electronic form. In the case of issuing licenses in electronic form (through the generation and display of the latter), the forms of licenses may differ from the forms of licenses issued in paper form approved by Appendix N 20 to this decision, while preserving the information specified therein, as well as containing additional information specified in Appendix N 20 for licenses issued in electronic form.

After paragraph 5 of the procedure approved by Appendix No. 19, a new paragraph 5.1 shall be added with the following content:

5.1. The insert provided with the licenses for the service of medical products issued electronically shall also be provided electronically. In case of issuing the insert electronically, the forms of the insert may differ from the forms of the insert issued in paper form approved in Form N 1 of this Appendix, while preserving the information specified therein, and also containing additional information provided for inserts issued electronically, as specified in point 14.1 of this Appendix.

After paragraph 14 of the procedure approved by Appendix No. 19, a new paragraph 14.1 shall be added with the following content:

14.1. Electronically issued inserts also contain a quick response code (QR Code) and the following note:

"FOR THE INTELLIGENT: _ _ __-_ _ __-_ _ __-_ _ _ __

2. Law on Universal Health Insurance

Name of the legislative act:

Law HO-459-N on Universal Health Insurance https://www.arlis.am/hy/acts/218650

Change status :

This Law entered into force on December 24, 2025.

What the changes are about:

On December 24, 2025, the Law on Universal Health Insurance was adopted, which A mandatory universal health insurance payment system is being introduced in Armenia , defining who is responsible for paying, how much, and when they must pay.

In particular:

- The scope of insurance premium payers for employees and individual entrepreneurs is defined ,

- Fixed monthly and annual insurance premium rates are introduced, depending on the amount of income ,

- The mechanism and deadlines for calculating and paying payments are established , Stamp duty rates are also changing ,

- And the moment of obtaining the status of an insured person is regulated.

On December 17, 2025, the National Assembly of the Republic of Armenia adopted the Law "On Universal Health Insurance" in its second reading and in full, which defined, in particular, the scope of insurance premium payers, rates, and payment deadlines.

1. Regarding employees being considered as insurance premium payers

The following employees receiving wages from a tax agent (employer) and employers exempt from tax agent obligations are considered to be payers of insurance premiums:

1. Define.

1) The procedure for submitting documents to the Competition and Consumer Protection Commission is in accordance with Appendix 1 .

2) The procedure for classifying cases of the Competition and Consumer Protection Commission by type, in accordance with Appendix 2 .

3) the procedure and conditions for conducting cases and other cases related to administrative proceedings, in accordance with Appendix 3 .

4) the procedure and conditions for maintaining registers of administrative proceedings and other cases, in accordance with Appendix 4 .

5) the procedure and conditions for maintaining registers of administrative and other legal acts, in accordance with Appendix 5 .

6) The procedure for printing, storing and archiving documents of the Competition and Consumer Protection Commission, in accordance with Appendix 6 .

2. To declare invalid the Resolution No. 394-N of the Commission for the Protection of Competition of December 28, 2021 “On the procedure and conditions for submitting documents to the Commission for the Protection of Competition, classifying cases of the Commission for the Protection of Competition by type, maintaining administrative proceedings and other cases, their registration registers, and registers of registration of administrative and other legal acts, as well as establishing the procedure for issuing, storing and archiving documents of the Commission for the Protection of Competition and declaring invalid the Resolution No. 59-N of the State Commission for the Protection of Economic Competition of June 18, 2008”.

3. This decision shall enter into force on the day following the date of its official publication.

4. As of the date of entry into force of this decision, the procedure in force prior to the adoption of this decision shall apply to current legal relations..

PART III: BANKING SECTOR

(This section of legal updates includes legal news related to the banking sector for October 2025)

1. On Amendments and Supplements to the Decision No. 280 of the Board of the Central Bank of the Republic of Armenia of October 7, 2014

Name of the legislative act:

Resolution No. 165-N of September 23, 2025 on Amendments and Supplements to the Decision No. 280 of the Board of the Central Bank of the Republic of Armenia of October 7, 2014 https://www.arlis.am/hy/acts/213886

Change status:

This amendment entered into force on October 7, 2025.

Which legislative act was amended by the adoption of the above-mentioned act:

As a result of the adoption of this Decision, an amendment was made to the Resolution of the Board of the Central Bank of the Republic of Armenia dated October 7, 2014 "On approving the procedure for registering reporting entities, as well as trust managers and persons performing management functions of other similar legal entities, as provided for by the Law of the Republic of Armenia "On Combating Money Laundering and Financing of Terrorism". in decision No. 280-N

What the changes are about:

The amendment concerns the inclusion of trust managers and persons performing management functions of other similar legal entities among those who are required to be registered with the Financial Monitoring Center of the Central Bank of the Republic of Armenia as reporting entities. Previously, the obligation to keep records applied only to reporting entities as defined in the Law on Combating Money Laundering and the Financing of Terrorism. With the new amendment, this scope has been expanded to also include trust managers and persons performing management functions of other similar legal entities, as provided for in Part 2 of Article 9 of the Law.

In other words, the essence of the change is that now those persons who perform management functions of trusts or other similar legal entities are also subject to mandatory registration, which stems from the international obligations assumed by Armenia in the field of combating money laundering and terrorist financing and recent legislative amendments.

This change is particularly related to the recent amendments to the Law "On Combating Money Laundering and the Financing of Terrorism", with the aim of ensuring the registration and supervision of all risky entities in this sector.

In paragraph 1 of the Decision No. 280 of the Board of the Central Bank of the Republic of Armenia of October 7, 2014, after the words “reporting entities”, add the words “as well as trust managers and persons performing management functions of other similar legal entities”.

Old version.

This procedure establishes the procedure for registering reporting entities (hereinafter referred to as reporting entities) defined in Article 3, Part 1, Point 4 of the RA Law "On Combating Money Laundering and Financing of Terrorism" in the Financial Monitoring Center of the Central Bank of the Republic of Armenia (hereinafter referred to as the Financial Monitoring Center).

New version.

This procedure establishes the procedure for registering reporting entities defined by Article 3, Part 1, Point 4 of the RA Law "On Combating Money Laundering and Financing of Terrorism" (hereinafter referred to as the reporting entity), as well as trust managers and persons performing management functions of other similar legal entities with the obligation to register based on Article 9, Part 2, in the Financial Monitoring Center of the Central Bank of the Republic of Armenia (hereinafter referred to as the Financial Monitoring Center).

Aiming to establish the procedure for registering trust managers and persons performing management functions of other similar legal entities,

Based on Article 11, Part 1, Paragraph 7 of the Law "On Combating Money Laundering and Financing of Terrorism",

Guided by Part 3 of Article 2, Point "e" of Article 20 of the Law "On the Central Bank of the Republic of Armenia" and Articles 33 and 34 of the Law "On Regulatory Legal Acts", the Board of the Central Bank of the Republic of Armenia

It is decided.

The procedure shall be supplemented with Chapter 4 with the following content:

Chapter 4. Procedure for registering a person performing management functions of a trust manager or other similar legal entity

14. The registration of a person performing management functions of a trust manager or other similar legal entity shall be carried out in accordance with the procedure established by Chapters 2 and 3 of these Regulations.

15. When submitting an application for registration by a person performing management functions of a trust manager or other similar legal entity, the type of activity shall be “management of a trust or other similar legal entity.”:

PART IV. CRYPTOASSETS SECTOR

(This section of legal updates includes legal news related to the crypto-asset sector as of October 2025)

1. Draft Regulation 7/01 on the registration and licensing of a person providing services with crypto assets, the issuance of a permit for the operation of a branch and representative office of a foreign person providing services with crypto assets, the procedure for obtaining prior consent for having a significant participation in the authorized capital of a person providing services with crypto assets

Name of the legislative act:

Draft Regulation 7/01 on the registration and licensing of a person providing services with crypto assets, the issuance of a permit for the operation of a branch and representative office of a foreign person providing services with crypto assets, the procedure for obtaining prior consent for having a significant participation in the authorized capital of a person providing services with crypto assets https://www.cba.am/file_manager/Regulation/Regulation_7.01_CASP_Licensing_Regulation.pdf

Change status :

This Decision entered into force on September 9, 2025.

What the changes are about:

This draft refers to the establishment of a unified legal regulation for the authorization, registration, and licensing of activities of persons providing services with crypto assets, as well as the clarification of the list of documents and information to be submitted by them, the procedure for submission, and the deadlines.

The goal of the project is to ensure the legality, transparency, and controllability of the activities of crypto- asset market participants in the Republic of Armenia by clearly defining the procedures for granting authorization, licensing, registration, and prior consent by the Central Bank.

The project was developed by:

- Based on Article 19, Parts 4 and 8, Article 20, Parts 2 and 4, Article 22, Parts 7 and 8, Article 25, Part 5, Article 26, Part 2, Article 27, Parts 1, 2 and 10, Article 28, Part 3 and Article 94, Part 2 of the Law "On Cryptoassets",

- as well as being guided by Part 3 of Article 2 and Point “e” of Part 1 of Article 20 of the Law “On the Central Bank of the Republic of Armenia”.

The draft defines Regulation 7/01, approved by the Central Bank, which regulates:

- conditions for registration, licensing and operation of persons providing services with crypto assets,

- procedures for granting permits to branches and representative offices of entities providing services with foreign crypto assets,

- The form, content requirements, procedure and deadlines for submission of documents and information submitted to the Central Bank,

- The process of obtaining prior consent for a significant participation in the authorized capital.

Thus, this draft is a regulatory act implemented by the Central Bank, which aims to form a regulatory
framework in the field of crypto-assets that is lawful, controllable, and in line with international standards.

Aiming to establish the procedure for permitting the activities of persons providing services with crypto assets, the list of necessary information and documents, as well as the procedure and deadlines for their submission to the Central Bank,

Based on Article 19, Parts 4 and 8, Article 20, Parts 2 and 4, Article 22, Parts 7 and 8, Article 25, Part 5, Article 26, Part 2, Article 27, Parts 1, 2 and 10, Article 28, Part 3, Article 94, Part 2, of the Law "On Cryptoassets",

Guided by Part 3 of Article 2 and Point “e” of Part 1 of Article 20 of the Law “On the Central Bank of the Republic of Armenia”, the Board of the Central Bank

WHO IS IT?

1. To establish Regulation 7/01 on "Registration and licensing of a person providing services with crypto assets, issuance of a permit for the operation of a branch and representative office of a foreign person providing services with crypto assets, and the procedure for obtaining prior consent for having a significant participation in the authorized capital of a person providing services with crypto assets" in accordance with the Appendix to this decision.

"REGISTRATION AND LICENSING OF A PERSON PROVIDING SERVICES WITH CRYPTOASSETS, ISSUANCE OF A PERMIT FOR THE ACTIVITY OF A BRANCH AND REPRESENTATIVE OF A PERSON PROVIDING SERVICES WITH CRYPTOASSETS IN A FOREIGN COUNTRY, PROCEDURE FOR OBTAINING PRIOR CONSENT TO A SIGNIFICANT PARTICIPATION IN THE AUTHORIZED CAPITAL OF A PERSON PROVIDING SERVICES WITH CRYPTOASSETS"

REGULATION 7/01 CHAPTER 1 GENERAL PROVISIONS

1. This regulation defines:

1) the procedure for registration and licensing of a person providing services with crypto assets, requirements for the content of documents and information,

2) unified form of license for a person providing services with crypto assets,

3) the procedure for issuing a permit for the operation of a branch and representative office of a person providing services with foreign crypto assets, requirements for the content of documents and information,

4) the procedure for obtaining a license or permit for the provision of additional (one or more) services with crypto assets by a person providing services with crypto assets or a branch of a foreign person providing services with crypto assets,

5) the form of the business plan of a person providing services with crypto assets and a branch of a person providing services with foreign crypto assets, as well as the procedure and deadlines for submitting the business plan and any amendments to it,

6) the procedure for informing the Central Bank about the establishment of a branch and representative office of a person providing services with crypto assets,

7) the procedure and conditions for the termination of the activities of a branch or representative office of a person providing services with crypto assets, as well as the temporary suspension of activities,

8) the procedure for obtaining the Central Bank's prior consent for the operation of a branch or representative office of a person providing services with crypto assets outside the territory of the Republic of Armenia,

9) the procedure for obtaining permission to provide services with crypto assets by investment companies, investment fund managers, regulated market operators and central depositories and the procedure for terminating the provision of services with crypto assets,

10) the procedure for revoking or invalidating the license of a person providing services with crypto assets, the permit for the operation of a branch or representative office of a foreign person providing services with crypto assets,

11) the procedure for obtaining prior consent for acquiring a significant stake in the authorized capital of a person providing services with crypto assets,

12) the procedure for submitting information on the beneficial owners of a person providing services with crypto assets and a person providing services with foreign crypto assets,

13) reports and information on interconnected and significant participants regularly submitted by a crypto- asset service provider or a branch of a foreign crypto-asset service provider,

14) requirements for the area of operation of a crypto-asset service provider, a branch of a foreign crypto- asset service provider and a branch of a crypto-asset service provider,

15) the procedure for submitting changes to the documents and information submitted in accordance with this Regulation to the Central Bank.

2. All documents required by this Regulation shall be submitted to the Central Bank electronically, through the CBA-Net system, and in case of impossibility, on an electronic medium and with an accompanying note, except for information protected by the legislation of the Republic of Armenia, which may also be submitted by entering it manually to the Central Bank. Moreover, the documents shall be submitted in Armenian, in Unicode font, in "PDF" format, with the exception of the tables attached to the business plan, which shall be submitted in Excel format.

3. The charters of a person providing services with crypto assets, a branch of a person providing services with foreign crypto assets (amendments, supplements to them) shall be submitted to the Central Bank with an electronic-digital signature provided by the Central Bank.

4. The requirement set forth in paragraph 3 of this Regulation shall apply to newly established entities providing services with crypto assets, as well as newly established branches of entities providing services with foreign crypto assets, from the moment of receiving an electronic digital signature by the Central Bank. Moreover, the entities provided for in this paragraph, when already connected to the CBA-net system and having received the relevant security certificates, shall re-submit the charters registered by the Central Bank to the Central Bank through the CBA-net system in the "PDF" format with an electronic digital signature within three business days after the date of receiving the relevant signature.

5. The documents specified in this Regulation, as well as the documents and information submitted in addition, shall be submitted to the Central Bank with an attached petition (application), signed by the competent management body. In the petition (application) submitted to the Central Bank, with the exception of the petition forms specified in the annexes to this Regulation, the person signing the petition (application) shall indicate that the attached documents and information are reliable and complete and shall be aware that the misrepresentation or omission of any fact may lead to the rejection of the petition (application).

6. In case of submitting the documents specified in this Regulation through a representative, the power of attorney issued to him in accordance with the procedure established by the legislation of the Republic of Armenia shall also be submitted.

7. The file name of the petition (application) submitted electronically must have the following structure: name of the person providing cryptographic services dash type of document dash content of the document (within 12 characters) dash month number in yyyy tt format dot file abbreviation

8. Foreign language documents are submitted with an Armenian translation approved by the competent administrative body or notarized, and in case of a conflict or inconsistency between Armenian and foreign language documents, the Armenian version shall prevail.

9. In case of non-material deficiencies (errors, non-legal inaccuracies, arithmetic errors or other similar omissions) in the documents submitted to the Central Bank in accordance with this Regulation, the Central Bank shall notify the person who submitted the application of the deficiencies through the contact information specified in the petition, and the Central Bank shall make a relevant decision after eliminating these deficiencies. Re-incomplete submission of documents may serve as a basis for rejecting the petition (application).

10. The calculation of the time limits established by the Law "On Cryptoassets" (hereinafter referred to as the Law) for licensing, registration, obtaining prior consent, obtaining a permit, as well as other decisions adopted by the Central Bank in accordance with this Regulation, begins from the moment all required documents are properly submitted to the Central Bank.

11. The information subject to submission in accordance with this Regulation for licensing, registration, obtaining prior consent, obtaining permission or notification, which has previously been submitted to the Central Bank within the framework of this or another process, shall be submitted to the Central Bank again only if it has been amended, in terms of amendments. Moreover, in case the relevant amendments are not submitted in accordance with this point or are submitted only in terms of amendments, the petition (application) shall indicate this, indicating in which process and when the amendments were submitted.

12. If the information submitted in the documents required by this Regulation has changed before the decision is made through the relevant process, the changed document must be submitted to the Central Bank within 3 business days after the change in information.

13. In the cases specified in this Regulation, ratings issued by international rating organizations shall be applied according to the following principle, unless otherwise provided by this Regulation:

1) if the organization has a rating issued by only one rating organization specified in this Regulation, then only that rating shall be taken as the basis,

2) if the organization has two different ratings issued by different rating organizations specified in this Regulation, then the lowest rating shall be taken as the basis,

3) if the organization has three or more ratings issued by different rating organizations specified in this Regulation, then the lowest rating of the two highest ratings shall be taken as the basis.

14. The financial statements required by this Regulation must be prepared:

1) in accordance with the standards set forth in the Law on Accounting, or

2) in the case of foreign legal entities, in accordance with International Financial Reporting Standards or other internationally recognized standards.

15. The Central Bank may request additional information and clarifications regarding points requiring clarification and interpretation of the information and reports required by this Regulation, as well as for specific analytical or supervisory purposes.

16. In case of suspension of the period for consideration of an application, petition or any other petition by the Central Bank in accordance with the Law, the period for consideration from the moment of the decision to resume the consideration shall not exceed the number of days resulting from the difference between the days prior to the suspension and the period set for consideration.

17. In case of payment of the authorized capital or increase of the authorized capital for the first time through a savings account opened at the Central Bank, an application for opening a savings account shall be submitted to the Central Bank in accordance with Appendix 9 of this Regulation, as well as a receipt for payment for opening a savings account.

2. Draft Regulation 7/02 on "Minimum limits of total capital of persons providing services with crypto assets, calculation procedure, elements participating in the calculation and deducted from the calculation"

Name of the legislative act :

Draft Regulation 7/02 on "Minimum limits of total capital of persons providing services with crypto assets, calculation procedure, elements participating in the calculation and deducted from the calculation"

https://www.cba.am/file_manager/Regulation/Regulation_7.02_Prudential%20Requirements_On_CASPs.pdf

What is the project about:

This draft concerns the establishment of minimum limits for the total capital of persons providing services with crypto assets and the procedure for their calculation, the purpose of which is to ensure their financial stability, solvency and protection of the interests of clients, as well as to contribute to the efficient and secure operation of the crypto assets market.

The draft establishes the rules according to which persons providing services with crypto assets are required to maintain minimum levels of total capital, with the aim of preventing the negative impact of possible financial losses during their activities on both themselves and other market participants.

The draft was developed based on Article 24, Part 2, Clause 5 and Article 44, Part 2 of the Law "On Cryptoassets", as well as guided by Article 2, Part 3 and Article 20, Part 1, Clause "e" of the Law "On the Central Bank of the Republic of Armenia". The draft envisages approving Regulation 7/02, “Minimum limits of total capital of persons providing services with crypto assets, calculation procedure, elements participating in the calculation and deducted from the calculation”, which defines: legal and economic standards for minimum total capital, capital calculation methodology, elements included in capital and excluded from the calculation, Procedure for assessing violation of the minimum capital requirement. Thus, this draft is a normative act adopted by the Central Bank, the purpose of which is to create a financially stable and responsible regulatory environment in the crypto-asset market, strengthening the credibility of the system and reducing systemic risks.

Add a new sentence to Part 7 with the following content:

Aiming to establish minimum total capital limits for persons providing services with crypto-assets in order to absorb potential losses related to their activities, ensure their financial stability, protect the interests of clients and, in general, ensure the normal functioning of the crypto-asset market,

Based on Article 24, Part 2, Clause 5, Article 44, Part 2 of the Law "On Cryptoassets",

Guided by Part 3 of Article 2 and Point “e” of Part 1 of Article 20 of the Law “On the Central Bank of the Republic of Armenia”, the Board of the Central Bank of the Republic of Armenia

DECIDES:

1. To approve Regulation 7/02 on “Minimum limits of the total capital of persons providing services with crypto assets, the procedure for calculation, elements participating in the calculation and deducted from the calculation” in accordance with the appendix to this decision. 2. This decision shall enter into force on the tenth day following the date of official publication. 2 ANNEX 2 Resolution of the Board of the Central Bank of the Republic of Armenia for 2025

REGULATION 7/02 "MINIMUM LIMITS OF TOTAL CAPITAL OF PERSONS PROVIDING SERVICES WITH CRYPTOASSETS, CALCULATION PROCEDURE, ELEMENTS PARTICIPATING IN THE CALCULATION AND DEDUCTIBLE FROM THE CALCULATION"

CHAPTER 1. SUBJECT OF REGULATION

1. This Regulation establishes the minimum limits of the total capital of persons providing services with crypto assets operating in the territory of the Republic of Armenia, the calculation procedure, the elements participating in the calculation and deducted from the calculation, and the amount of violation of the minimum total capital standard.

2. This regulation does not apply to branches of entities providing services with foreign crypto assets.

CHAPTER 2. BASIC CONCEPTS

3. The terms used in this regulation have the following meanings:

1) "fixed costs" - costs that do not change depending on the volume of services provided by a person providing crypto-asset services,

2) "average daily calculation of the month" - the sum of daily values during the month, relative to the number of days in the month,

3) "annual average daily calculation" - the sum of daily values during the year, relative to the number of days in the year.

4) “trading portfolio” means a portfolio of assets or other financial instruments that may include only those assets or other financial instruments whose sale or full hedging is not restricted in any way by legal (including based on instructions of the Central Bank of the Republic of Armenia), contractual or other grounds. An asset or other financial instrument may be included in the trading portfolio if it is carried at fair value through profit or loss, and the person providing services with crypto-assets has acquired it for the purpose of reselling in the short term, generating income from short-term price fluctuations, generating income from the difference in prices in the markets, or hedging the risks arising from instruments that meet the three aforementioned purposes.

4. Other concepts used in these Regulations have the meaning assigned to them in the Law of the Republic of Armenia “On Cryptoassets” (hereinafter referred to as the Law) and in the normative legal acts adopted on the basis of the Law and in the legislation of the Republic of Armenia. ( ... )

3. Draft Regulation 7/05 on establishing the procedure for registering persons providing services with crypto assets and heads of branches of persons providing services with foreign crypto assets

Name of the legislative act :

Draft Regulation 7/05 on the procedure for registering persons providing services with crypto assets and heads of branches of persons providing services with foreign crypto assets

https://www.cba.am/file_manager/Regulation/Regulation_7.05_Registration_of_CASP_managers.pdf

What is the project about:

This draft refers to the establishment of a unified procedure for registering persons providing services with crypto assets and heads of branches of persons providing services with foreign crypto assets, which provides for the clarification of the list of heads subject to registration, the procedures for registration, refusal of registration and deregistration.

The goal of the project is to ensure that the management of organizations providing services with crypto assets meets high standards of professionalism, integrity, and responsibility, contributing to market stability and strengthening the trust of investors and customers.

The draft was developed based on Part 2 of Article 34, Article 87 and Part 3 of Article 93 of the Law "On Cryptoassets", as well as guided by Part 3 of Article 2 and Point "e" of Part 1 of Article 20 of the Law "On the Central Bank of the Republic of Armenia".

The draft envisages approving Regulation 7/05, “Regulations on the Registration of Persons Providing Crypto- Asset Services and Heads of Branches of Persons Providing Foreign Crypto-Asset Services,” which stipulates:

- list of managers subject to registration,

- the grounds and procedure for registering and refusing registration of managers,

- the grounds and procedure for deregistration,

- the form, content and deadlines for submitting documents regarding managers,

- Procedure for the implementation of information verification and control functions by the Central Bank.

Thus, this draft is a regulatory legal act of the Central Bank, which aims to form a crypto-asset market with a management team that meets high professional and ethical standards, ensuring effective management, proper risk control, and reliable market operations.

In order to establish the list of managers subject to registration of a person providing services with crypto assets, the procedure for registering, refusing registration and deregistering managers,

Based on Article 34, Part 2, Article 87, Part 3 of Article 93 of the Law "On Cryptoassets",

Guided by Part 3 of Article 2 and Point "e" of Part 1 of Article 20 of the Law "On the Central Bank of the Republic of Armenia", the Board of the Central Bank of the Republic of Armenia WHO IS IT? 1. To establish Regulation 7/05 “Regulation on the Procedure for Registration of Persons Providing Crypto- Asset Services and Heads of Branches of Persons Providing Foreign Crypto-Asset Services” in accordance with the Appendix to this Decision. 2. This Decision shall enter into force on the tenth day following the date of its official publication.

"REGISTRATION PROCEDURE FOR PERSONS PROVIDING SERVICES WITH CRYPTOASSETS, HEADS OF BRANCHES OF PERSONS PROVIDING SERVICES WITH FOREIGN CRYPTOASSETS" REGULATION 7/05 CHAPTER 1 GENERAL PROVISIONS

1. This Regulation establishes the list of managers of entities providing services with crypto assets, branches of entities providing services with foreign crypto assets, subject to registration with the Central Bank, and the procedure for registering, refusing registration, and deregistering managers.

2. The information specified in this Regulation on the registration of managers of a crypto-asset service provider, a branch of a foreign crypto-asset service provider or changes in their composition shall be submitted to the Central Bank through the system provided by the Central Bank on the website https://www.cba.am/hy/registration-of-managers/, by entering the data online in Armenian and attaching other documents required by this Regulation in the field specified in the system, through the login data (name and password) provided by the Central Bank to the responsible employee authorized to approve the petitions of the managers of the branch of the given crypto-asset service provider, foreign crypto-asset service provider.

3. Applications for registration of managers of a crypto-asset service provider or a branch of a foreign crypto- asset service provider applying for a license or branch operation, and other documents required by this regulation within the framework of this process, shall be submitted in electronic format, with references on managers being submitted in Excel format, and other documents required by this regulation in PDF format.

4. The documents specified in this Regulation, as well as the documents and information submitted in addition, shall be submitted to the Central Bank with an attached petition (application), signed by the competent management body. In the petition (application) submitted to the Central Bank, with the exception of the petition forms specified in the annexes to this Regulation, the person signing the petition (application) shall state that the attached documents and information are reliable and complete and shall be aware that any misrepresentation or omission of any fact may result in the rejection of the petition (application).

5. In case of submitting the documents specified in this Regulation through a representative, the power of attorney issued to him in accordance with the procedure prescribed by the legislation of the Republic of Armenia shall also be submitted.

6. The file name of the petition (application) submitted electronically must have the following structure: encrypted data service dash Document type dash Document header dash Month number: ooooh dot File name of the person providing the file (within 12 characters) abbreviation in tt format

7. Foreign language documents are submitted with an Armenian translation approved by the competent administrative body or notarized, and in case of a conflict or inconsistency between Armenian and foreign language documents, the Armenian version shall prevail.

8. In case of non-material deficiencies (errors, non-legal inaccuracies, arithmetic errors or other similar omissions) in the documents submitted to the Central Bank in accordance with these Regulations, the Central Bank shall notify the person who submitted the application of the deficiencies and the Central Bank shall make a relevant decision after eliminating these deficiencies. Re-submission of incomplete documents may serve as a basis for rejection of the petition (application).

9. The calculation of the time limits set by the Law "On Cryptoassets" for the registration of managers specified in this Regulation begins from the moment all required documents are properly submitted to the Central Bank.

10. If the information submitted in the documents required by this Regulation has changed before the decision is made through the relevant process, the changed document must be submitted to the Central Bank within 3 business days after the information change occurs.

11. The Central Bank may request additional information and clarifications regarding points requiring clarification and interpretation of the information and reports required by this Regulation, as well as for specific analytical or supervisory purposes.

What the changes are about:

The decision concerns the list of a number of goods subject to marking with identification means in the Republic of Armenia and the deadlines for introducing marking, the rules for marking goods subject to marking with identification means in accordance with the Basic Technological Organizational Model of the System for Marking Goods with Identification Means in the Eurasian Economic Union (hereinafter referred to as the Basic Model), approved by the Council of the Eurasian Economic Commission on March 5, 2021.