Media Regulation in Armenia

Armenia's media regulatory landscape is characterized by a developing legal framework with significant gaps in addressing media concentration and ownership transparency. The legal environment is anchored in Armenia’s constitution (amended in 2015) that guarantees freedom of press and prohibition of censorship under Article 42(2), while also establishing anti-monopoly principles and fair market competition rules.The primary legislation governing media includes the Law on Audiovisual Media (adopted August 2020), which regulates television and radio broadcasting, including satellite and cable services. The Law on Mass Media (2004) covers print and online media, though these sectors lack a dedicated regulatory authority. Additional relevant legislation includes the Law on State Registration of Legal Entities, the Law on Protection of Economic Competition, and anti-money laundering laws that define "real beneficiaries."

The Television and Radio Commission (TRC) serves as Armenia's primary media regulatory authority, established by the constitution (Article 196) and governed by the Law on Audiovisual Media. The TRC regulates terrestrial television and radio broadcasting, satellite, and cable audiovisual services, but does not regulate print or online media.

The Commission's responsibilities include:

• Holding tenders for licensing the usage of digital frequency slots
• Allocating broadcasting slots to license holders
• Monitoring compliance with license conditions and legal requirements
• Imposing administrative sanctions for violations of law and license conditions (warnings, fines, license suspension or termination)
• Processing consumer complaints
• Engaging in policy development and legislative initiatives

Composition and Appointment

TRC members are elected by the National Assembly through a secret ballot requiring at least three-fifths of the votes. Given that the parliamentary majority holds three-fifths of seats, the opposition has limited ability to influence commission appointments, raising concerns about political independence.

Members cannot be affiliated with political parties, cannot engage in political activities, and must demonstrate political neutrality in public. They are subject to incompatibility rules similar to those for members of parliament, prohibiting them from holding positions in state bodies, private entities, or engaging in commercial activities (except for scientific, educational, or creative work).

Funding and Resources

The TRC is funded through the state budget. For 2025, the TRC’s budget is approximately 380 million Armenian drams (around one million US dollars). The TRC can supplement this with 30% of fines and state duties collected during the preceding fiscal year. While the law stipulates funding should be sufficient for the commission to fulfill its functions, it does not explicitly reference independence as an objective, a gap noted by the OSCE.

Transparency and Accountability

The TRC publishes annual reports to the National Assembly covering all aspects of its activities, including licensing procedures, administrative proceedings, sanctions imposed, complaint mechanisms, and financial reports. These reports are accessible on the Commission's website. The TRC also issues thematic reports, such as annual financial income reports for audiovisual media entities.

TRC decisions can be appealed to the administrative court system, with further appeals possible to higher courts. This mechanism has proven effective, with numerous court cases challenging TRC decisions on various grounds.

Armenia lacks a comprehensive regulatory framework for addressing media ownership concentration adapted to current industry realities. The legislation does not tackle horizontal, vertical, or cross-media ownership through criteria such as audience share, circulation, turnover, or voting rights.

The Law on Audiovisual Media provides only basic restrictions:

• A single legal or natural person cannot hold more than two broadcasting licenses
• This restriction applies based on territorial coverage (republican-capital, republican- regional, or capital-regional)
• Radio broadcasters are exempt from these limitations
• Foreign capital cannot exceed 50% of shares necessary for decision-making, unless otherwise specified by international treaty

High-ranking officials (president, government members, parliament members, judges, municipal leaders) and their related persons are prohibited from being founders or shareholders of private broadcasting entities. "Related persons" include parents, spouses, children, siblings, and those exercising indirect management or owning more than 20% of shares.

The current framework has significant blind spots:

• No authority to prevent mergers or acquisitions that could adversely affect media pluralism
• No requirement for media owners to notify the TRC of proposed mergers or acquisitions
• No mechanism to assess concentration impact using thresholds for audience share, market power, or revenue
• No provisions for vertical integration or cross-media ownership
• The State Commission for Protection of Economic Competition has not assessed any media mergers, despite having general anti-monopoly powers

In its 2024 annual report, the TRC acknowledged the necessity of improving legislation concerning media ownership and financing, referring to the Council of Europe's Recommendation CM/Rec(2017) on media pluralism and transparency of media ownership. In April 2025, the TRC submitted legislative amendment proposals to the Ministry of High Technologies addressing these gaps, though no details about the political consensus or timeline are yet available.

Armenia has established disclosure requirements through multiple legislative instruments, creating a relatively strong transparency framework compared to media concentration regulation.

Disclosure Requirements for Audiovisual Media

Under Article 19 of the Law on Audiovisual Media, broadcasters must:

• Publish annual income reports on their websites by May 1 each year
• Disclose founders, owners, and shareholders, including real beneficiaries
• Submit detailed breakdown reports of annual revenues to the TRC
• Report legitimate income sources (advertising, airtime, sponsorship, content sales, subscription fees, founder contributions)

The TRC can impose administrative sanctions for failure to provide accurate and complete reports, including warnings, fines, or license suspension/termination. Annual reports show that entities have been sanctioned for failing to provide financial breakdown reports, though no sanctions have been recorded specifically for failing to disclose ownership information.

State Register Requirements

The Law on State Registration of Legal Entities requires all media companies to disclose substantial information about owners and real beneficiaries in the State Register, which is largely accessible to the public. Since 2021, all business entities must disclose real beneficiaries—defined as individuals exercising actual control or owning 20% or more of voting shares.

Providing false information about real owners or beneficiaries to the State Register is criminalized under Article 294 of the Criminal Code. However, the State Register does not have investigative or verification capacity to proactively detect false declarations, limiting the practical enforcement of these disclosure requirements.

Print and Online Media

The Law on Mass Media requires print and online outlets to publish limited information about operating entities on their platforms, including company name, address, and state registration number.

Article 12 of the Law on Mass Media obligates print and online media to publish annual financial reports by March 31, disclosing gross income and the share of donations. However, there is no regulatory authority monitoring compliance with this requirement for print and online media sectors. The law does not establish fines or other legal consequences for non-compliance, creating a significant enforcement gap. Their reporting is not monitored by any regulatory body.

Independence Concerns: While the TRC has constitutional guarantees of independence and formal protections against political interference, the appointment mechanism—requiring three-fifths of National Assembly votes—effectively allows the parliamentary majority to control all Commission seats without input from the opposition.

No Regulation of Digital Media: The Law on Audiovisual Media does not cover cable TV and satellite services that primarily distribute internet content (such as YouTube). Online and digital media operate without sector-specific regulation or a dedicated regulatory authority, representing a significant gap as media consumption increasingly shifts online.

Net Neutrality: Armenia currently has no legal framework addressing net neutrality. A 2014 Government Decree on Internet Principles, which included net neutrality provisions, was invalidated in 2022. The Law on Electronic Communication contains no express reference to net neutrality principles.

State Advertising and Subsidies: The audiovisual media legislation does not address state advertising allocation or define monitoring mechanisms for identifying non-transparent allocation of public funds. There is no media subsidization fund or framework for ensuring fair distribution of state advertising proportionate to audience share.

Limited Enforcement: While sanctions exist for non-compliance with disclosure requirements, the TRC lacks proactive tools to prevent problematic mergers or acquisitions. No cases have been reported in recent years where the Commission refused licenses or intervened to prevent excessive ownership concentration. The decisional practice suggests limited use of available enforcement mechanisms in the ownership concentration domain.

The most meaningful change in recent years was the adoption of the current Law on Audiovisual Media in August 2020, replacing the former Law on Television and Radio. This updated legislation introduced the multiplexing framework for spectrum allocation and slightly modified cross-ownership restrictions.

In its 2024 annual report, the TRC acknowledged the necessity of improving legislation concerning media ownership and financing of audiovisual media entities, referring to the Council of Europe's Recommendation CM/Rec(2017) on media pluralism and transparency of media ownership. In April 2025, the Commission submitted a comprehensive policy paper to the Ministry of High Technologies proposing legislative amendments to address critical gaps in the audiovisual media law.

The proposal seeks to incorporate effective media ownership concentration prevention norms in accordance with Council of Europe standards. Specifically, it would establish:

• Regulations for horizontal, vertical, and cross-media ownership
• Clear criteria for determining ownership and control, including proprietary, financial, and voting strength thresholds
• Authority for the TRC to prevent media mergers or acquisitions that could adversely affect media pluralism
• Requirements for media owners to notify the TRC of proposed mergers or acquisitions
• Power for the regulator to assess the impact of concentration on media pluralism and diversity, and to make binding decisions or recommendations about whether proposed transactions should be authorized

However, there is not yet political consensus on these amendments, though the proposal aligns with the government's broader anti-corruption policy agenda. Implementation depends on political will and parliamentary action.

LEGAL ASSESSMENT MEDIA OWNERSHIP MONITOR ARMENIA

This legal context assessment reveals that while Armenia has established basic frameworks for media regulation and ownership transparency, significant gaps remain—particularly regarding media concentration prevention, digital media regulation, and ensuring the independence of regulatory bodies from political influence.