Why? 

Armenia lacks reliable audience measurement data across all media sectors, preventing meaningful analysis of market concentration. The absence of standardized metrics not only makes it impossible to determine whether the top four media owners control significant audience shares, but critically impairs regulators' ability to identify, mitigate, and resolve concentration risks. According to the methodology, the lack of audience data in any market always constitutes a high risk.

TV MARKET: MISSING DATA (HIGH RISK)

Armenia's sole television ratings provider, Admospher LLC, offers disputed data that industry participants widely reject. A 2022 international audit by 3M3A found that Admospher's system failed to meet international standards. Controversy over the company's methodology and suspected market connections dating to 2016 renders its measurements unsuitable for concentration analysis. A new system from Inditronics Media Private Limited is expected to begin operations in November-December 2025, but until then, reliable television audience data remains unavailable, indicating a high risk to media pluralism in the television market.

PRINT MARKET: MISSING DATA (HIGH RISK)

No industry-standard audience measurement system exists for radio broadcasting in Armenia. While general surveys may ask respondents about radio consumption, these do not constitute the systematic audience metrics necessary for concentration analysis.

RADIO MARKET: MISSING DATA (HIGH RISK)
No industry-standard audience measurement system exists for radio broadcasting in Armenia. While general surveys may ask respondents about radio consumption, these do not constitute the systematic audience metrics necessary for concentration analysis.

PRINT MARKET: MISSING DATA (HIGH RISK)

Print media operates without any established readership measurement system. Circulation figures, where available, do not provide audience reach data, making concentration assessment impossible, hence the risk is high.

ONLINE MARKET: MISSING DATA (HIGH RISK)

Digital platforms lack standardized audience measurement. While individual outlets may have website analytics, no comprehensive cross-platform system tracks online news consumption. Internews conducts periodic surveys on media trust and consumption, but these survey snapshots cannot substitute for the continuous, systematic tracking required for industry-standard audience measurement.

The absence of reliable audience data across all media sectors represents a fundamental transparency deficit in Armenia's media market. This gap prevents stakeholders from understanding market dynamics and potential risks to media pluralism.

Why? 

Comprehensive market revenue data for 2024 is not publicly available in Armenia. Of the 39 media companies analyzed in the MOM Team sample, only 17 provided financial revenues for 2024, representing less than 44% of the sample. Media companies frequently operate multiple outlets across different platforms, yet financial revenues are not reported on an outlet-specific basis, making horizontal calculation of market shares difficult.

The 17 companies that provided 2024 financial data operate primarily across television and online platforms (Public TV, Armenia TV, A TV, TV 5, Kentron TV), with limited representation from radio (Public Radio, Kiss FM, Radio Aurora) and print media (Azg, Past, and 168 zham). Online media shows particularly poor transparency, with only four outlets providing revenue figures. The National Network Foundation provided financial data for the foundation, not for ReOpen Media, as ReOpen only began operations in 2025 and its first financial report is expected in 2026. “Aravot” LLC submitted a consolidated report covering both its print and online media outlets.

This incomplete financial dataset prevents the calculation of horizontal market concentration using standard metrics such as the Top4 (CR4) index, which requires revenue information across a sufficient market sample. The companies that have provided financial data for 2024 are:

However, the 2023 Television and Radio Commission report enables assessment of broadcast market concentration. In television, the top four players control 92.5% of market share, with Public Television commanding 60.6%, Armenia TV 19.1%, Shant TV 7.8%, and Kentron TV 4.9%. 

Excluding the Public Broadcaster, private television concentration remains extremely high at 88.7%, with Armenia TV alone controlling nearly half the private market.This concentration level significantly limits media pluralism and creates a market dominated by a small number of players.

Public Radio dominates the market with over half of total market share, resulting in high concentration levels. The top 4 players in the radio market had a market share of 82.3%.

The private radio market shows somewhat more balanced distribution compared to television, though concentration remains high. The top four private radio operators control nearly three-quarters of the market.

These 2023 figures indicate high market concentration in both television and radio sectors. The dependency on earlier data and the absence of 2024 information means current concentration levels cannot be definitively assessed, though no evidence suggests the market structure has fundamentally changed. Without financial data from the majority of 2024 market participants, it is impossible to determine current dominant positions or calculate combined market shares.

According to MOM methodology, when a country provides audience data but lacks revenue information, market share analysis is excluded and findings rely solely on audience data. However, Armenia lacks both audience measurement data (as detailed in Indicator D.1) and comprehensive revenue data for 2024. While Armenian law mandates financial disclosure for all media sectors—the Law on Audiovisual Media requires broadcasters to report revenues to the Television and Radio Commission, and the Law on Mass Media requires print and online outlets to publish annual financial reports—compliance remains inconsistent. The audiovisual sector benefits from regulatory oversight by the Television and Radio Commission, but print and online media operate without any supervising or regulatory body to monitor financial disclosure requirements, resulting in widespread non-compliance and data gaps across all media markets. 

SOURCES:

2023 Annual turnover of entities operating in the field of audiovisual media and regulated by the Commission, Television and Radio Commission

Law on Audiovisual Media of Armenia (2020), Article 19

Law on Mass Media of Armenia (2004)

Law on State Registration of Legal Entities, State Enrollment of Designated Unites, Institutions and Individual Entrepreneurs of Legal Entities (2001)

Legal Assessment Media Ownership Monitor 2025

Why?

Armenia's regulatory framework for preventing horizontal media ownership concentration shows significant gaps across media sectors. While television benefits from sector-specific safeguards under the Law on Audiovisual Media, these protections are undermined by the absence of substantive concentration measurement criteria. Other platforms rely solely on general competition law that has never been applied to media concentration cases.

Absence of Concentration Measurement Criteria

A fundamental weakness across all sectors is the lack of defined benchmarks for measuring media concentration. The Audiovisual Media Law defines concentration primarily through cross-ownership—limiting the number of licenses a single entity can hold—but fails to establish criteria based on audience share, circulation, turnover/revenue, share capital, or voting rights. This means regulators cannot assess whether license holders control dominant market positions. Article 18 prevents an entity from owning more than two television licenses, but provides no mechanism to determine if those two licenses collectively reach 80% of viewers or only 5%. The Television and Radio Commission lacks authority to assess concentration based on market impact metrics, rendering the regulatory framework incapable of identifying actual threats to media pluralism beyond simple license counting.

The Law on Protection of Economic Competition defines "concentration of entities" through various mechanisms, including mergers, acquisitions of assets or shares, and establishment of control, with a threshold identifying concentration when an entity acquires 20% of capital shares or assets. However, these provisions have never been applied to media entities, and they do not account for media-specific pluralism concerns such as audience reach or influence over public opinion.

Television (3/4): The Law on Audiovisual Media establishes thresholds through Article 18, which prohibits any single person from holding more than two broadcasting licenses with territorial restrictions preventing simultaneous control of republican and capital coverage, or republican and regional coverage, or capital and regional coverage. The Television and Radio Commission monitors compliance and possesses sanctioning powers, including warnings, fines, license suspension, or termination. However, TRC annual reports from 2020-2024 show no broadcaster has been sanctioned for ownership violations. More critically, without audience measurement data or criteria for assessing market dominance beyond license numbers, the Commission cannot determine if concentration threatens pluralism even when ownership appears legally compliant.

Radio (1.5/4): Radio operates under minimal safeguards. According to the legal assessment, while Article 18 of the Audiovisual Media Law provides that "a single legal or a physical person cannot be a founder or a shareholder of more than two licensed audiovisual broadcasters," this regulation explicitly does not apply to radio broadcasters. The law states: "However, this regulation does not apply to radio broadcasters." This exemption means radio faces no ownership concentration limits—a single entity could control multiple radio stations with overlapping geographic reach without legal restriction. The TRC monitors radio ownership and possesses sanctioning authority, but given the absence of concentration thresholds for radio, there are no ownership-related restrictions to enforce. Radio regulation entirely lacks criteria for measuring or preventing concentration, representing significantly weaker safeguards than television.

Print (1/4)  and Online (1/4): Print and online media lack any sector-specific concentration regulations. The Law on Mass Media, which covers both sectors, contains no provisions limiting ownership, establishing market share thresholds, or defining what constitutes problematic concentration. Only general competition law could theoretically prevent excessive concentration, but the Competition and Consumer Protection Commission has never opened proceedings against print or online media entities. Most critically, neither sector has a dedicated regulatory authority monitoring ownership patterns. Without regulatory oversight, legal criteria for defining harmful concentration, or any measurement benchmarks, both print and online media operate with minimal safeguards against ownership concentration.

Merger Control (1/4): Armenia lacks media-specific merger control mechanisms and criteria for assessing when mergers threaten media pluralism. The Audiovisual Media Law does not require ownership change notifications, mandate concentration impact assessments, or grant the TRC authority to block transactions. The Law on Protection of Economic Competition contains no media-specific provisions and establishes no benchmarks for evaluating whether media mergers would harm diversity of voices or opinion. The TRC and Competition Protection Commission operate separately without coordination mechanisms. No media mergers have been reviewed under competition law in recent years, and no methodology exists for assessing their impact on media pluralism.

Implementation Gap and Measurement Deficit

The critical weakness is twofold: the disconnect between legal provisions and enforcement, and the fundamental absence of tools to measure concentration. While television has license-based restrictions, the complete absence of ownership-related sanctions across all sectors, combined with missing criteria for assessing market dominance, means regulators cannot identify concentration risks even where legal authority theoretically exists. The legal assessment notes the TRC "does not have proactive tools to interfere with merger or acquisition" and crucially, the Commission "does not have a power to assess concentration based on such criteria" as audience share or market revenue. For print and online media lacking dedicated regulatory oversight, this gap is more severe. The absence of audience measurement data (Indicator D.1) and comprehensive revenue information (Indicator D.2) compounds this problem—regulators lack both the legal criteria and the empirical data necessary to assess whether ownership patterns threaten media pluralism.

Regulatory Safeguard Score: 7.5 out of 20 (37.5%)

1 = media-specific regulation/ authority

0.5 = competition-related regulation/ authority

SOURCES:

Law on Audiovisual Media of Armenia (2020), Article 18

Law on Protection of Economic Competition (2000), Article 13

Law on Mass Media (2004)

Annual Report 2024, Television and Radio Commission

Legal Assessment Media Ownership Monitor Armenia (2025)

Why?

Cross-media ownership concentration cannot be assessed in Armenia due to the absence of both comprehensive market revenue data and reliable audience measurement across media sectors. According to MOM methodology, when audience shares are unavailable, the indicator scores high risk.

Cross-media ownership is widespread in Armenia, with most companies operating outlets across multiple platforms—television broadcasters maintain online portals, print newspapers operate digital editions, and media companies control both TV channels and websites. However, companies consolidate financial reporting across outlets and platforms, making outlet-specific market share calculations impossible. Of 39 sampled media companies, only 17 provided revenue data—less than half the market.

Without identifying which eight companies control the largest combined market shares across television, radio, print, and online sectors, regulators cannot assess whether cross-media concentration threatens media pluralism. This gap is particularly concerning because cross-media ownership can amplify market power—an owner controlling modest shares in multiple sectors may wield disproportionate influence compared to owners dominant in a single sector.

While the Law on Audiovisual Media requires broadcasters to report revenues and the Law on Mass Media mandates disclosure for print and online outlets, compliance remains inconsistent, and data lacks the granularity necessary for cross-media analysis. Without regulatory mechanisms to systematically collect and publish comprehensive ownership and financial data across platforms, cross-media concentration risks remain invisible to stakeholders.

Why?

Armenia's regulatory framework addressing cross-media ownership concentration is fundamentally inadequate. The audiovisual media legislation lacks established mechanisms to tackle cross-media ownership and contains no criteria for determining control of media companies — such as proprietary rights, financial strength, or voting power that enables direct or indirect influence over strategic decision-making. The framework scores medium risk because the Law on Audiovisual Media provides limited within-sector controls for television broadcasting, but no comprehensive safeguards prevent an entity from dominating across television, print, radio, and online sectors simultaneously. General competition law could theoretically address cross-media concentration, but it has never been applied to media cases.

Media-Specific Cross-Ownership Rules (3/4)

Article 18 of the Law on Audiovisual Media prohibits any single person from holding more than two broadcasting licenses across different coverage territories (republican, capital, or regional). The Television and Radio Commission monitors compliance and possesses sanctioning powers, including license refusal, suspension, or termination. However, TRC annual reports from 2020-2024 show no sanctions imposed for cross-ownership violations.

Article 18's scope is limited to audiovisual broadcasting licenses (however, radio broadcasters are exempt from some regulations) and does not address cross-ownership between television and other media types. A broadcaster owning two television licenses could simultaneously own multiple newspapers, radio stations, and digital news sites without regulatory restrictions. The law defines cross-media concentration narrowly—as owning multiple broadcast licenses—rather than addressing ownership spanning different media sectors. Without criteria for measuring combined market influence across platforms, regulators cannot assess whether multi-platform ownership threatens pluralism beyond simple license counting.

Merger Control and Competition Law (1/4)

The audiovisual media legislation contains no grounds or procedures authorizing the regulatory body to prevent media mergers or acquisitions that could adversely affect pluralism or content diversity. The TRC lacks authority to assess the impact of proposed concentrations on media pluralism or to make recommendations about whether mergers should be authorized. The Law on Protection of Economic Competition could theoretically prevent mergers creating dominant cross-media positions, but it contains no media-specific provisions. The Competition and Consumer Protection Commission has never reviewed media mergers, and no coordination mechanism exists between the TRC and the Competition Commission for assessing cross-media transactions.

Regulatory Safeguard Score: 4 out of 8 – Medium Risk (50%)

1 = media-specific regulation/ authority

0.5 = competition-related regulation/ authority

SOURCES:

Law on Audiovisual Media of Armenia (2020), Article 18

Law on Protection of Economic Competition (2000)

Annual Report 2024, Television and Radio Commission

Legal Assessment Media Ownership Monitor Armenia (2025)

Why?

Ownership information for media outlets in Armenia is predominantly accessible through public registries and information requests, though proactive transparency remains limited. Of the 42 investigated outlets, ownership data was available for 92.8% through active disclosure, responses to inquiries, or public records. However, only 26.2% of outlets demonstrated active transparency by proactively publishing comprehensive ownership information, falling below the 75% threshold required for low risk assessment.

The State Register of Legal Entities of Armenia serves as the primary source for ownership information, providing online access to founding documents, shareholder information, and since 2021, beneficial owner disclosures. The Television and Radio Commission maintains a list of licensed broadcasters, though without comprehensive ownership details. No centralized register exists for print or online media. The MOM Team submitted information requests to all investigated media companies in 2024-2025, with several companies providing detailed responses regarding ownership structures, revenue sources, and beneficial owners.

MOM investigated a sample of 42 outlets, 39 companies, and 48 individual owners. The transparency assessment uses five categories:

• Active Transparency means company / channel informs proactively and comprehensively about its ownership, data is constantly updated and easily verifiable. 11 outlets, 8 companies, and 22 owners were ranked as Actively Transparent, representing 31.7% of the entire sample.  
• Passive Transparency means upon request, ownership data is easily available from the company/channel. 7 outlets, 5 companies, and 1 owner were ranked as Passively Transparent, representing 10% of the entire sample. Most of these companies, outlets, and owners are related to media that provided detailed replies to MOM information requests. These media companies responded to inquiries with detailed ownership structures but do not maintain systematic public disclosure practices on their websites or platforms.
• Data Publicly Available means ownership data is easily available from other sources, e. g. public registries, etc. 21 outlets, 22 companies, and 20 owners were ranked as Data Publicly Available, representing 48.8% of the entire sample. Even when outlets did not inform publicly about their owners, this information could be found in the State Register of Legal Entities.
• Data Unavailable means ownership data is not publicly available, company/channel denies the release of information or does not respond, no public record exists. 2 outlets, 2 companies, and 1 owner were classified as Data Unavailable, representing 3.9% of outlets. These cases typically involved complex corporate arrangements or companies that did not respond to information requests and had incomplete State Register filings.
• Active Disguise means that in addition to unavailability of true data, ownership is disguised, e. g. through bogus companies, etc. No cases of Active Disguise were identified in Armenia's media market.

Why?

Armenia's regulatory framework for media ownership transparency shows significant variation across sectors. Television and radio benefit from comprehensive disclosure requirements with active regulatory oversight, while print and online media operate under general transparency obligations without sector-specific monitoring.

Television and Radio: Strong Safeguards (4.5/5 each)

The Law on Audiovisual Media (Article 19) requires audiovisual providers to publish annual income reports on their websites by May 1, disclose founders and shareholders, and submit detailed revenue breakdowns to the Television and Radio Commission. The TRC actively monitors compliance and possesses sanctioning powers including fines, license suspension, or termination. All entities must also report ownership to the State Register of Legal Entities, which since 2021 requires disclosure of real beneficiaries—individuals controlling entities or owning 20% or more of voting shares. The Criminal Code (Article 294) criminalizes false disclosure, creating both administrative and criminal penalties.

Despite these requirements, some beneficial owners remain unidentified. Complex ownership structures involving intermediate holding companies or proxy arrangements can obscure ultimate control. The TRC's annual reports do not systematically publish submitted ownership data, limiting public accessibility beyond what entities voluntarily post.

Overall, the media ownership transparency framework in Moldova is primarily focused on the audiovisual sector, leaving significant gaps for print and online media, where ownership and funding information are not subject to mandatory disclosure requirements. Hence the risk related to ownership transparency is assessed as medium. 

Print and Online: Weak Safeguards (2.5/5 each)

Print and online media face significantly weaker transparency safeguards. The Law on Mass Media requires outlets to publish ownership information and annual financial reports, but no regulatory authority oversees compliance for non-audiovisual media. These sectors rely on the State Register for ownership disclosure, which operates as a passive repository without verification mechanisms or active monitoring.

The legal assessment emphasizes this regulatory void: print and online reporting "is not monitored by any regulatory body." While criminal penalties theoretically apply for false disclosure, enforcement depends on detection—unlikely without regulatory oversight.

Critical Gaps

The enforcement asymmetry between regulated audiovisual media and unregulated print/online sectors creates the framework's fundamental weakness. Broadcasters face active monitoring and sanctions for non-compliance, while newspapers and digital outlets operate with minimal accountability. This uneven application means transparency depends on which sector an outlet operates in rather than consistent principles. Additionally, the 20% beneficial ownership threshold may not capture all individuals exercising influence through smaller stakes or informal control, and the State Register lacks investigative capacity to verify disclosed information or identify undisclosed owners.

Regulatory Safeguard Score: 14 out of 20 - Medium Risk (50%).

TV (4.5/5) | Radio (4.5/5) | Print (2.5/5) | Online (2.5/5)

1 = media-specific regulation/ authority

0.5 = competition-related regulation/ authority

SOURCES:

• Law on Audiovisual Media of Armenia (2020), Article 19
• Law on Mass Media (2004)
• Law on State Registration of Legal Entities (2001), Chapter 12.1
• Criminal Code of Armenia (2022), Article 294
• Legal Assessment Media Ownership Monitor Armenia (2025)

Why?

When assessing the political interconnectedness of media outlets, MOM Team followed the above methodology and identified only those companies whose connections to political parties could be demonstrated through ownership structures. Among the 42 media outlets studied, some produced content suggesting political affiliation. The political leanings of these outlets are evident from their editors' speeches, interviews, and the programs they host, revealing which political forces they support. However, since MOM Team conducted ownership structure analysis rather than qualitative content analysis, and these political connections were not reflected in ownership structures, these media outlets were not classified as politically affiliated. In other words, MOM Team only counted verifiable ownership connections, not editorial bias.

8.1 Television Market: Due to the absence of television audience data, MOM Team cannot assess the market share of politically affiliated television companies. However, among the 10 television companies studied, the owners of nine demonstrate political connections. Notably, several owners operate through proxy arrangements.

Public Television Company (First Channel, 1inLratvakan): The founder of Public Television Company is the Republic of Armenia, funded through the state budget. Although the Law on Audiovisual Media guarantees that Public Broadcaster funding cannot fall below the previous year's budgetary allocation, the fact that the National Assembly approves the Public Broadcaster's budget creates political dependency. The Public Broadcaster's Council also lacks complete independence. While Council members are selected through competitive procedures, they are appointed by the Prime Minister.

Senior officials at Public Television Company previously held positions in the Prime Minister's staff and Yerevan Municipality. The host of the company's main political program, Petros Ghazaryan, is married to the Minister of Education, Science, Culture and Sports. Lusine Barseghyan, Director of News and Analytical Programs at Public Television Company, previously worked at Haykakan Zhamanak newspaper (a media outlet affiliated with Prime Minister Nikol Pashinyan's family), served as assistant to National Assembly Speaker (current Minister of Foreign Affairs) Ararat Mirzoyan, and is married to Vahagn Tevosyan, former member of parliament from the "My Step" faction. According to investigative journalist Katya Mamyan's 2025 research, Petros Ghazaryan's interviews predominantly feature representatives and supporters of the ruling "Civil Contract" party, who occupied more than half of the program's airtime.

Armenia TV: Armenia Television Company was formerly part of Panarmenian Media Group. Since 2019, Robert Hovhannisyan has been the sole owner of the television company. Hovhannisyan is the brother-in-law of Artur Janibekyan, founder of Comedy Club Production. Janibekyan is a friend of Mikayel Minasyan, former Ambassador to the Vatican and son-in-law of Armenia's third President Serzh Sargsyan. Janibekyan holds an 85% stake in the Jazzve café founded by Mikayel Minasyan.

A TV Television Company: Davit Avetisyan, sole owner of A TV, previously headed Panarm LLC (Panarmenian Media Group) and Armenia Television Company, which, according to numerous press publications and journalistic reports, were affiliated with Mikayel Minasyan.

Shant Television Company: Shant Television Company has consistently demonstrated loyalty to whichever government is in power. Aram Mnatsakanyan, who holds a 48% stake, is a classmate of Mikayel Minasyan. In June 2020, Mnatsakanyan's shares were seized. He was charged with money laundering in preliminary agreement with his classmate Mikayel Minasyan and Minasyan's associate Leonid Arevšatyan.

According to the Prosecutor's Office, Leonid Arevšatyan acquired a 48% stake in Shant LLC for 5 million USD through a foreign organization. In 2011, a fictitious loan agreement was concluded between organizations owned by Minasyan and others, through which the sum was transferred to Shant founder Artur Yezekyan. Subsequently, Leonid Arevšatyan, Mikayel Minasyan, and Aram Mnatsakanyan attempted to conceal the unlawful origin of the shares. In 2015, Aram Mnatsakanyan acquired this stake for 97.6 million AMD through a fictitious transaction, giving their actions a legal appearance.

In 2024, Shant Television Company acquired a 50% stake in Mediahouse Armenia, a television advertising sales company created to counterbalance Media International Service, which is affiliated with Mikayel Minasyan. Mediahouse Armenia's financial director is Arman Harutyunyan, brother of Prime Minister's Chief of Staff Araik Harutyunyan, who is also a member of the "Civil Contract" faction on Yerevan's City Council.

Kentron Television Company: Sedrak Arustamyan, owner of Kentron Television Company, is a shareholder or director in several companies owned by or affiliated with Gagik Tsarukyan, Chairman of the "Prosperous Armenia" party, or his family.

5 TV Channel: Armen Tavadyan, owner of 5th Channel Television Company, maintains close relationships with Armenia's second President Robert Kocharyan. During Kocharyan's trial for the "March 1" case, Tavadyan participated in rallies organized in his defense. Tavadyan faced separate charges in that case for attempting to obstruct justice, specifically for allegedly bribing people and encouraging them to provide false testimony in favor of Robert Kocharyan. Due to the statute of limitations, criminal prosecution against Armen Tavadyan was terminated by court decision in 2022.

H2 Television Company: Samvel Mayrapetyan, owner of 50% of H2 Television Company, is a major businessman with political connections. His elite construction business flourished during the presidency of Armenia's second President Robert Kocharyan, when he received preferential construction rights in downtown Yerevan. Samvel Mayrapetyan and Robert Kocharyan's eldest son, Sedrak Kocharyan, jointly own Toyota Yerevan LLC, which engages in sales and service of Toyota brand automobiles.

FreeNews TV Company: Little is known about Hasmik Danielyan, founder and sole owner of the relatively new (2020) Freenews Television Company. However, 51% of her shares were temporarily transferred to Armen Ghaleсhyan, who served on Yerevan's City Council from 2018-2023 representing the ruling "My Step" alliance. Additionally, since its founding, Free News LLC's director has been Mariam Margaryan, former wife of National Assembly Speaker Alen Simonyan.

8.2 Radio market: Among nine radio stations, five demonstrate political affiliation.

Public Radio: Public Radio is classified as politically affiliated due to evident political influence over its governing body. While Public Broadcaster Council members are selected through competitive procedures, the Prime Minister appoints them. Additionally, the National Assembly, where the political majority holds decisive power, approves the radio's budget. These structural dependencies create potential for political influence. However, Public Radio demonstrates greater editorial independence than Public Television Company. This may be attributed to radio's smaller influence on public opinion, resulting in reduced political interest in controlling its operations.

Yerevan FM and Avtoradio: Among the shareholders of Yerevan FM and Avtoradio radio stations, Armen Amiryan has political affiliation. He was a member of the Republican Party of Armenia, elected to the National Assembly in 2017 on the party's electoral list, but renounced his mandate to continue working as Minister of Culture. In 2018, he terminated his membership in the Republican Party of Armenia.

Sputnik Armenia: The founder of Sputnik Armenia radio station is a foreign government—the Russian Federation—and on this basis it is considered politically affiliated.

Radio Hay: The political affiliation of Radio Hay founder and owner Anahit Tarkhanyan is reflected in two episodes. In 2018, as a mayoral candidate, she participated in extraordinary Yerevan City Council elections on the "Yerevan Community" alliance list. Her husband, Andreas Ghukasyan, is chairman of the Armenian Constructive Party. He ran as a presidential candidate in the 2013 presidential elections. Ghukasyan hosts the program "Political Analyses with Andreas Ghukasyan" on Radio Hay, sponsored by the Armenian Constructive Party.

8.3 Print Market: Among the eight print media outlets studied, the owners of four demonstrate political affiliation.

Iravunk Newspaper: All three shareholders of Iravunk newspaper are or were connected to the Constitutional Right Union party. Hayk Babukhanyan is the party chairman and has served as a member of parliament for two convocations, once on the 'Law and Unity' alliance list and the second time on the Republican Party electoral list. In 2021, Babukhanyan also founded the 'Strong Armenia with Russia' party. Gegham Grigoryan is a member of the party presidency. The third shareholder, Hovhannes Galadjyan, who died in 2024 (his shares transferred to a family member), was also a member of the party presidency.

Azg Newspaper: The founders of Azg newspaper, including Editor-in-Chief Hakob Avetikyan, are members of the Ramgavar Azatakan Party.

Joghovurd Daily: Taguhi Tovmasyan, founder and owner of Johovurd daily newspaper, is a member of the 8th convocation National Assembly, belonging to the "I Have Honor" faction. Although included in the "I Have Honor" alliance list as a non-party member of parliament, she represents this political force.

Past newspaper: Varuzhan Babajanyan, the founder and owner of the newspaper Past, has been involved in politics. Although not a member of any political party, he has run in parliamentary elections three times (in 2017, 2018, and 2021) as a candidate representing the Prosperous Armenia party or the Tsarukyan alliance. However, he has never been elected.

8.4 Online market: Among the 15 online media outlets studied, 10 have politically affiliated ownership.

Azatutyun (Radio Free Europe/Radio Liberty): The founder of Azatutyun is a foreign government—the United States—and on this basis it is considered politically affiliated.

1in.am: Arman Babajanyan, owner of the 1in.am online media outlet, is the founder of the 'For the Republic' party. On December 9, 2018, he was elected as a member of parliament on the 'Bright Armenia' party's national electoral list.

Tert.am: Tert.am, formerly part of Panarmenian Media Group and later transferred to Quartet Media, has connections to the Republican Party of Armenia. The newspaper's first founder, Arman Sahakyan, was a member and parliamentarian of the Republican Party of Armenia (RPA). All four founders of Quartet Media—Samvel Farmanyan, Karen Bekaryan, Arman Saghatelyan, and Mihran Hakobyan—were National Assembly members representing the RPA; some were also party members (Mihran Hakobyan left the party in 2019).

24news: Two of 24 News's shareholders—Narek Galstyan and Georg Sachleyan—are members of the Social-Democratic Hunchakian Party.

Armenian Times (Haykakan Zhamanak): The controlling stake in the Haykakan Zhamanak online media outlet belongs to Kima Mkrtchyan, mother-in-law of Prime Minister Nikol Pashinyan. Another shareholder, Hayk Gevorgyan, was a member of the 7th convocation National Assembly representing the "My Step" party alliance electoral list. The third shareholder, Petros Makeyan, is a political figure who served as chairman of the "Democratic Homeland" party.

Civic.am: Civic.am is the website of Armenia's ruling "Civil Contract" party, although there is no indication of this on the site. The Media Ownership Monitor research team discovered this through court documents. One week before the research results presentation, party Vice-Chairman and "Civil Contract" faction member of parliament Vahagn Aleksanyan announced during Civic.am's "Ambion" podcast, which he hosts, that Civic.am is the "Civil Contract" website and is funded by the party.

Armlur.am: Taguhi Tovmasyan, founder and owner of armlur.am (published by Zhohovurd Tert Khmbagrutyon LLC), is a member of the 8th convocation National Assembly, belonging to the "I Have Honor" faction. Although included in the "I Have Honor" alliance list as a non-party member of parliament, she represents this political force.

Radar.am: Major shareholder Varag Siseryan of radar.am was a member of the Civil Contract party. Although he left the party in 2020, he declared that he would not change his political line. He is affiliated with Yerevan Mayor Tigran Avinyan, having served as head of the office of then-Deputy Prime Minister Tigran Avinyan from 2018-2020.

Mediahub.am: Mediahub.am is affiliated with "Hayrenik" party chairman Artur Vanetsyan. Vahagn Boyajyan, the site's sole owner and director, served as head of the press center of former National Security Service chief Artur Vanetsyan and became his assistant after Vanetsyan's resignation. The site's editorial office is located in the Hayrenik party building.

8.5 Transparency of politically affiliated ownership: Almost none of the politically affiliated media outlets publicly declare their affiliation with any party. Nearly all position themselves as independent media outlets. As described above, even the civic.am website of the "Civil Contract" party contained no indication that it was founded by the party. Only one week before the completion of this research, shortly before the presentation, did party Vice-Chairman Vahagn Aleksanyan openly declare that the website was created and is funded by the Civil Contract party.

8.6 There is regulation on conflicts of interest, but it only covers some politically affiliated groups (effectively). Article 15(2) of the Law on Audiovisual Media prohibits the President, government members, Parliament members, judges, and municipal leaders—along with their immediate relatives (parents, spouses, children, siblings)—from being founders or shareholders of private broadcasting entities. This creates clear conflict of interest safeguards for television and radio at national and local levels. However, the Law on Mass Media contains no such restrictions for print newspapers or online news platforms, meaning politicians cannot own TV or radio stations but face no legal barriers to owning newspapers or digital news sites. The prohibition also applies only to direct ownership roles (founders/shareholders) and may not capture indirect control through intermediate companies or proxy arrangements.

8.7 Editorial Independence and Self-Censorship: Specific cases of ownership interference in editorial policy and editorial work are not widely known, which does not mean such interference is excluded. In Armenia, journalists avoid discussing internal editorial problems because both the market and the country are small, and "everyone knows everyone." Additionally, knowing about a media outlet's political connections, journalists and editors understand how to cover stories through self-censorship. International organizations' and research institutions' reports document that journalists in Armenia practice self-censorship to align their materials with the media outlet's political line, but they do not speak about this publicly.

8.8. Editorial Independence Guarantees: Self-regulation mechanisms for media outlets in Armenia began to be introduced in the 2000s. Some media outlets have their own codes of ethics. The Media Self-Regulation Initiative unites more than 90 Armenian media outlets.

Score: 2,62 High Risk

SOURCES:

Legal Assessment Media Ownership Monitor Armenia 2025

Freedom of Expression and Media Consumption Research in Armenia (2023), Internews, accessed 16.10.2025

Peculiarities of Media Functioning in Armenia (2018), Wschód Europy, Vol. 4, Issue 1, accessed 16.10.2025

Waning Trust and Rising Polarization: Armenia's Bumpy Road to Free Press, International Press Institute, accessed 16.10.2025

(Armenian) Code of Ethical Principles for Armenian Media (2024), Media Ethics Observatory, accessed 16.10.2025

Media Ethics Observatory: 2025 Statements and Opinions, Media Ethics Observatory, accessed 16.10.2025

Draft Amendments to the Law on Mass Media and Related Legislation, e-Draft, Armenian Government Portal, accessed 16.10.2025

Why?

Armenia's media infrastructure presents mixed risks. Print and internet distribution show minimal political interference, while television broadcasting demonstrates concerning political affiliations through regulatory concentration and appointment mechanisms. The monopolistic audience measurement service and absence of transparent data create significant vulnerabilities for media pluralism.

9.1 Print Media Distribution Networks: Low Risk

Three distribution agencies operate in Armenia: Haypost (focused on postal services), Blitz Media (newspapers and magazines), and Press Stand (largest, with 330 kiosks). Press Stand's owner Arman Sahakyan is a Republican Party member and former parliamentarian who also founded tert.am through Media Style LLC in 2008. Despite this political background, no evidence exists of discriminatory distribution practices. The sector's primary challenges are economic rather than political: only eight national newspapers remain (down from twenty five years ago), with circulation of 1,000-6,000 copies and average sales of 50%. Print consumption collapsed to 3%, with only 0.5% considering it a news source.

9.2 Radio Distribution Networks: Low Risk

The Television and Radio Commission (TRC) allocates radio licenses through competitive tenders with no documented cases of politically motivated discrimination. Radio serves primarily as entertainment rather than news. The TRC's structural independence is compromised by its appointment mechanism—members are elected by the National Assembly requiring three-fifths majority, ensuring ruling party control. However, given radio's limited role in news dissemination, this poses minimal practical risk to media pluralism.

9.3 Television Distribution Networks: Medium Risk

Television infrastructure shows concerning political affiliations through state ownership and regulatory control. The Public Broadcaster operates under 100% state ownership, with its Council members appointed by the Prime Minister for six-year terms despite competitive selection processes. The TRC allocates broadcasting licenses and multiplex slots through tenders, but the Commission's independence is compromised by the three-fifths National Assembly vote requirement for member appointment, giving the ruling party complete control over all appointments. The 2020 transition to the multiplexing framework involved significant regulatory decisions about slot allocation. While no documented evidence exists of systematic current discrimination against specific outlets, the concentration of appointment powers within the executive branch and ruling party creates structural risks.

9.4 Internet Distribution Networks: Low Risk

Four companies dominate telecommunications: Viva Armenia, Telecom Armenia, Ucom, and GNC-Alfa (OVIO), collectively paying AMD 20.4 billion in taxes during January-June 2025. Only Ucom demonstrates political connections through links to former Finance Minister Gagik Khachatryan, whose son Gurgen chairs the board. However, the family currently faces criminal prosecution including money laundering charges, suggesting diminished political influence. Telecom Armenia's owners (Yesayan brothers) show no political affiliations. No evidence exists of discriminatory pricing or access restrictions based on outlets' political positions, and legal proceedings against telecommunications oligarchs mitigate concerns about the politicisation of internet infrastructure.

9.5 Advertising Market Service Providers: Medium Risk

Armenia's advertising market (TV market) is dominated by two main advertising sales houses: MIS and Mediahouse Armenia. MIS has faced historical concerns about political connections, with suspected links to Mikayel Minasyan, the former president's son-in-law, who is now facing criminal charges. Mediahouse Armenia is 50% owned by the Public Television Company of Armenia, and its finance director is the brother of the Prime Minister's Chief of Staff Arayik Harutyunyan. Some outlets, including 5th Channel, have claimed discriminatory treatment in advertising distribution. While the legal assessment notes no established mechanisms exist to monitor non-transparent allocation of advertising funds, the concentration of the market in two agencies with documented political connections, combined with complaints of discrimination, creates structural risks for fair market access.

9.6 Audience Measurement Services: High Risk

Armenia lacks a reliable audience measurement system. The primary measurement service, Admospher, has been widely disputed and failed an international audit, undermining industry confidence in its data. According to media reports and industry sources, no credible measurement services currently operate in Armenia, creating a vacuum in audience data that affects media outlets' ability to demonstrate their value to advertisers. A new audience measurement system by Inditronics is expected to launch in November-December 2025, but until then, the absence of reliable, transparent, and independently verified audience data creates significant barriers for independent media to access advertising revenue and poses serious risks to fair competition and media pluralism.

Score: 1.6 Medium Risk

SOURCES:

Legal Assessment MOM Armenia 2025

Economic Context - Armenia

State-Owned Media - Armenia

Technology Context - Armenia

Media Market Analysis, Armenia, Zinc Network, 2024

Annual Report 2024, Television and Radio Commission of Armenia

Why?

10.1 & 10.2 State Advertising Distribution and Rules (Medium Risk)

The concept of state advertisement is not addressed in the audiovisual media legislation. It provides no definition and no monitoring mechanism for advertising allocation. There are no legal grounds nor a mechanism for monitoring and identifying non-transparent allocation of public funds, such as favoring or subsidizing certain media institutions that publish content favorable to the government. However, the Law on Advertising obliges advertising transmitters to grant no less than 5% of annual advertising time (or print space) to non-commercial advertising of national interest on health matters, environmental protection, and social security. Orders for placing social advertisements can be made by ministries, government departments, territorial and local governmental bodies, as well as by non-governmental organizations, with the government covering production and placement costs when it acts as the advertiser. Despite this provision for social advertising, there are no rules, transparent mechanisms, or oversight systems governing state advertising distribution to media outlets. While there is no documented evidence of systematic discrimination in state advertising distribution, the absence of any regulatory framework means proportionality cannot be verified. State advertising distribution occurs without established criteria, monitoring mechanisms, or transparency requirements, creating an environment where discriminatory practices could occur without detection or accountability. There is no data on the volume of state advertising or its distribution across different media sectors (television, radio, print, and online media). The Ministry of Finance informed the research team of the Media Ownership Monitoring project that advertising expenses in the state budget are not itemized as a separate line item, but rather are included within the costs of individual programs. Consequently, the Ministry does not have precise data on the total volume of state advertising.

10.3-10.6 Missing Data

10.7 Direct state support to media (Medium Risk) The state in Armenia provides direct financial support to media through several mechanisms with varying levels of transparency. The Ministry of Education, Science, Culture and Sports has operated a "Publication of Non-State Press" program since 2008, offering grants through announced competitions across three categories: periodicals for national minorities, literary publications, and cultural publications. The ministry makes funding decisions based on professional council recommendations and publishes results on its website, providing some transparency. However, the Diaspora Affairs Office also provides financial support to media outlets (AMD 56.5 million over 2020-2024, increasing from AMD 10 million annually to AMD 16.5 million in 2024) but declined to specify distribution mechanisms or beneficiary identities, citing confidentiality clauses in contracts. Additionally, the government established the Public Benefit Media Environment Foundation in April 2025 to provide grants to private broadcasters on the public multiplex for creating public-benefit content, but the foundation's budget, procedures, and allocation criteria remain undeveloped. While some direct support mechanisms operate with transparent competition-based rules, others lack clarity and oversight, creating risks for potential political bias in allocation.

10.8 Is indirect financial support distributed fairly, transparently, and based on clear rules?

Armenia does not provide indirect financial support to the media through tax privileges or cost reductions. The only support has been the provision of premises in buildings considered state property to certain media outlets, either free of charge or at reduced rates. Since the Soviet era, numerous editorial offices have been housed in the Press Building, which was constructed for media purposes and is located in downtown Yerevan. The building was transferred to the State Property Management Committee. In 2025, the committee began sending eviction notices to editorial offices whose contracts had expired, refusing to extend them. For example, the "Aravot" newspaper, which had occupied space in this building for 31 years since its founding, vacated the premises in July 2025. Meanwhile, the Yerevan City Hall decided to review the preferential rental rates for editorial offices housed in buildings on its balance sheet, bringing them into alignment with market prices.

Since Armenia provides no indirect financial support to media that could present risks of unfair or discriminatory distribution, this question presents no assessment risk. The elimination of subsidized office space as of 2025 means there are no remaining indirect support mechanisms through which political bias or discrimination could operate.

10.9 Do all media outlets have access to the state-financed news agency, and do they receive quality content relevant for their news production?

Armenia has only one state news agency—Armenpress, the first Armenian news agency, founded in 1918. As a state agency, it naturally reflects the policy of the state or government and is considered an official source. High-ranking officials frequently grant exclusive interviews to Armenpress, and government and prime ministerial political statements are transmitted through the agency. All media outlets can use Armenpress materials with proper attribution, as the content is open and free. However, you will not find criticism of government activities in Armenpress materials; its content primarily reflects government priorities.

Armenpress journalists benefit from accompanying official delegations on foreign visits and covering important negotiations or other political events. Through state mechanisms, it is able to conclude agreements with state news agencies of other countries to exchange information.

10.10 Do you consider the financing of the PSM independent and adequate?

The Public Broadcaster receives state budget allocation through a procedure defined in Article 29 of the Law on Audiovisual Media, with an important safeguard stipulating that funding cannot fall below the previous year's allocation. This provides financial stability and prevents abrupt budget cuts as a direct control mechanism. However, the financing structure creates unfair competitive conditions in a media market where Public Television already commands 60.6% of market share and Public Radio holds 56.1% of market share. In 2020, legislation was changed to allow the Public Broadcaster—already financed through state budget allocations and dominating the market—to also generate revenue from advertising. This dual income stream creates non-equal and disadvantageous conditions for private television and radio companies that depend entirely on commercial revenue for survival. Private broadcasters report that Public TV's ability to offer lower advertising prices and package advertisements across multiple channels, while maintaining guaranteed state funding and holding majority market dominance, has created unfair competition that weakens private operators. The adequacy of PSM financing is not in question; however, the independence of the financing mechanism from political pressure is compromised by state budget dependency, and the competitive fairness of the system is fundamentally undermined by allowing a state-funded broadcaster commanding 60%+ market share to compete directly in advertising markets while maintaining budget security. This creates a MEDIUM RISK environment where the PSM's financial independence enables potential political influence through budget allocation, while its dominant market position, combined with dual revenue streams (budget + advertising), distorts market conditions and threatens the viability of private media competitors.

10.11 The independence of the appointment and dismissal process of the PSM management (Medium Risk)

According to the Law on Audiovisual Media, the Public Broadcaster is defined as "a broadcaster owned by a company 100 percent owned by the Republic of Armenia." The Council serves as "the body responsible for managing and overseeing the Public Broadcaster." While Council members are "selected through competitive processes," they are "appointed by the Prime Minister for six-year terms." This concentration of appointment authority within the executive branch compromises the independence of PSM governance. The legal assessment notes that "Article 29 of the 'Law on Audiovisual Media' defines the financing procedure, requiring the Council to compile and submit annual budgetary funding requests to the Ministry of Finance." The law provides "an important safeguard stipulating that funding cannot fall below the previous year's budget allocation." While the competitive selection process and prohibition against reducing funding provide some protections, the Prime Minister's direct appointment authority over all Council members creates structural vulnerabilities. The appointment mechanism enables potential political influence over PSM management, though the six-year terms and competitive selection process offer partial mitigation.

Score: 2 Medium Risk

SOURCES:

Law on Audiovisual Media of the Republic of Armenia (2020), Article 19

Law on Mass Media of the Republic of Armenia (2004)

After 31 Years Working in the Press Building, "Aravot" Forced to Find New Office, media.am, 2025

State Participation in Media Outlets and State Support to Media, Media Ownership Monitoring Armenia 2025

Legal Assessment, Media Ownership Monitoring Armenia 2025

Why?

Armenia lacks comprehensive legal frameworks to protect net neutrality. While the Law on Electronic Communication serves as the central law governing the Internet, it contains no express reference to the principle of net neutrality. A 2014 government decree that mentioned net neutrality among 17 principles of Internet development was invalidated in 2022, leaving no current legal instrument defining or protecting net neutrality. There are no regulatory authorities charged with monitoring or enforcing net neutrality protections, no mechanisms to prevent blocking, throttling, or zero-rating, and no sanctions for violations. The absence of legal safeguards creates significant risks for media diversity and equal access to online information.

Regulatory Sageguards Score: 0 out of 11  = 0% High Risk

Metadata: The legal assessment provides clear information that Armenia has no net neutrality protections in law. The 2014 Government Decree on the Principles of Internet that mentioned net neutrality was invalidated on January 1, 2022. The current Law on Electronic Communication does not address net neutrality. No regulatory authorities, enforcement mechanisms, or sanctions exist. All questions (11.1-11.11) received a score of 0, resulting in 0% regulatory safeguards and a HIGH RISK assessment.

SOURCES:

Legal Assessment MOM Armenia 2025

Law on Electronic Communication of the Republic of Armenia, adopted 08 July 2005

Why?

While Armenia has a national commitment to gender equality, including the Gender Policy Implementation Strategy (2019–2023), women have only recently begun to be appointed to high-ranking political and governmental positions. As of now, nearly half of the country’s cabinet members are women—a significant step forward in public representation.

However, beyond government and law-enforced initiatives, women’s participation in managerial positions across most private sectors remains limited, and the media industry is no exception. Specific gender equality policies within newsrooms are neither widespread nor systematically implemented across the sector.

There is a clear vertical gender segregation within Armenia’s media industry: women make up a substantial portion of the journalist workforce but remain underrepresented in top editorial and management roles. This mirrors broader national trends, where the share of women in senior management positions has historically fluctuated but consistently remained below parity.

In both Public Service Media (PSM) and private outlets, women are less likely than men to serve as Chief Editors, Directors, or Board Chairs. This pattern reflects a global tendency, where women hold considerably fewer top editorial roles relative to their overall presence in journalism.

According to the Media Ownership Monitoring (MOM) Armenia data, 17 owners of 42 media outlets (40%) are women, but the situation is even more unequal in other managerial positions: just 9 of 42 editor-in-chiefs and CEOs (21.4%) are women. This gender gap persists across all four media types – Radio, Online, Print, and Television – with one notable exception: in Radio, women make up over 50% of owners and founders within the MOM sample of 9 radio stations.

The Committee to Protect Freedom of Expression continuously monitors cases of physical or other types of violence and discriminatory treatment against journalists; however, it does not maintain separate statistics on gender-based violence or discrimination. According to the Committee’s reports for 2023 and 2024, six and fifteen cases of physical violence were recorded, respectively. In 2023, out of the six recorded cases, five involved female journalists, and in 2024, seven out of the fifteen cases involved women. The relatively high number of attacks against female journalists—by law enforcement officers, politicians, or protesters—is explained by the fact that women constitute the majority of the journalistic workforce. However, it is a fact that female journalists are sometimes specifically targeted on the basis of gender. In 2025, one such case was recorded.

Score: 2,28 = Medium Risk

SOURCES:

Annual Report of CPFE on situation with freedom of expression and violations of rights of journalists and media in Armenia, Committee to Protect Freedom of Expression, 2024

Armenia: Pashinyan’s cabinet reshuffle promoting gender equity, Eurasianet, 2024

Women are the majority in Armenian media, but they are not owners, Factor.am, 2023

Statement by Journalist Organizations Regarding Unacceptable Conduct by Member of Parliament Andranik Kocharyan Toward Journalist Hripsime Jebejyan, March 21, 2025