Cyber Law at Armenia

Armenia has been actively enhancing its cyber law framework to address emerging digital challenges, focusing on cybersecurity, data protection, and international cooperation.

Key Developments in Armenia's Cyber Law

1. Draft Law on Cybersecurity (2025): In March 2025, Armenia introduced a draft "On Cybersecurity" law aimed at establishing a comprehensive legal framework to safeguard the country's digital infrastructure. The draft law emphasizes public-private partnerships, outlining responsibilities for both sectors to enhance cybersecurity hygiene and protect critical information systems. It also includes provisions for incident reporting and response mechanisms. 

2. Personal Data Protection and Classification: Armenia's Law on Personal Data Protection classifies data into categories such as biometric data, sensitive personal information, and publicly available data. Processing of sensitive data requires explicit consent from individuals, and cross-border data transfers are regulated to ensure adequate protection. The law mandates notification to the Personal Data Protection Agency before processing sensitive data, ensuring transparency and accountability. 

3. National Cybersecurity Strategy: The Armenian government has adopted a National Cybersecurity Strategy to protect the country from cyber threats. This strategy promotes coordination among state, private sector, and civil society efforts, aiming to secure critical information infrastructures and enhance resilience against cyber incidents. It also advocates for the establishment of a Cybersecurity Center to centralize and streamline cybersecurity efforts. 

4. International Cooperation: In November 2023, Armenia signed the Second Additional Protocol to the Council of Europe's Convention on Cybercrime. This protocol facilitates international cooperation in cybercrime investigations, allowing direct requests to service providers for subscriber information and domain name registration details. It also establishes safeguards for personal data protection during such cooperative efforts. 

5. Surveillance Legislation Concerns: A proposed surveillance bill in Armenia has raised international concerns regarding privacy rights. The bill mandates extensive video surveillance in public and private spaces, potentially leading to continuous processing of personal data. Critics, including Armenia's Data Protection Agency and the UN High Commissioner for Human Rights, argue that such measures could infringe upon individuals' right to privacy and may not be proportionate to the intended public safety objectives. 

Conclusion

Armenia is proactively developing its cyber law landscape to address the complexities of the digital age. While advancements in cybersecurity and data protection are commendable, ongoing vigilance is necessary to balance security measures with the protection of individual privacy rights.

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