The government’s stated objectives for introducing a mobile phone identification number (IMEI) registration system do not fully reflect the actual scope of the initiative. This view was expressed by former Armenian Justice Minister Arpine Hovhannisyan.
According to her, the authorities present the initiative as a mechanism to combat smuggling, prevent the circulation of devices with counterfeit identification numbers, and protect the interests of legal importers.
“At first glance, these objectives appear entirely reasonable. Government representatives insist that the initiative has nothing to do with personal data. However, this is not actually the case,” Hovhannisyan stated.
Previous Anti-Smuggling Mechanisms Were Never Properly Implemented
According to the former minister, if the government presents the new system as a tool against smuggling, it effectively acknowledges that previous mechanisms failed to achieve their intended goals.
Hovhannisyan recalled that legislative amendments adopted in 2023 required the State Revenue Committee, beginning on January 1, 2025, to monitor business activities, compare acquisition and sales volumes, and identify cases of illegal imports through those mechanisms.
According to her, these measures were never effectively implemented in practice.
“For a year and a half, no effective administrative enforcement was carried out under that legislation, no political or legal responsibility was assumed, and now a new instrument is being introduced,” she said.
Armenia Has Chosen a Different Model Than Europe
According to Hovhannisyan, European IMEI registration systems are generally limited to creating databases of device identification numbers, allowing telecommunications operators to service only legally registered devices.
However, she argues that the Armenian proposal extends far beyond that framework.
“Here, the authorities want to obtain information about who owns a particular phone, which telephone number is being used, and also gain access to the complete history of the devices in which a specific SIM card has previously been used,” she explained.
The Issue Goes Beyond Combating Smuggling
In Hovhannisyan’s view, government assurances that the new regulations will not apply to devices already in use are unconvincing because citizens regularly purchase or import new mobile phones.
She also argues that the proposed legislation fails to specify what categories of personal information will be collected and for what purposes.
“If the objective is to combat smuggling, then why is it necessary to collect users’ personal information? Why is there no clear explanation of what specific data will be gathered?” the former minister asked.
The Real Objective May Be Expanding Access for Law Enforcement
According to Hovhannisyan, the initiative’s actual purpose is to expand law enforcement agencies’ access to information about citizens.
“In essence, this is an attempt to simplify the work of law enforcement agencies. That is why the authorities have chosen not the European model, but approaches used in Cambodia, Turkey, India, and Russia. In that case, why not tell citizens directly that their personal data will also be collected and that this system is not intended solely to combat smuggling?” Hovhannisyan concluded.