By Siranush Adamyan and Paul Vartan Sookiasian
Armenia's planned mobile phone registration system will not involve the collection of citizens' personal data or enable surveillance, the government said on Tuesday, responding to concerns raised over the initiative.
The government stressed that the centralized database would store only the device's 15-digit International Mobile Equipment Identity, or IMEI, number, without any personal information attached.
"The introduction of an IMEI registration system in Armenia is intended to ensure the lawful circulation of mobile phones," the government said in a statement.
According to the government, the measure aims to reduce the circulation of illegally imported mobile phones, ensure fair competition for legal importers, protect consumers from devices with counterfeit or altered IMEI numbers, and establish a unified registry of mobile phones.
"It is important to emphasize that the initiative has no connection to the collection of citizens' personal data or to monitoring citizens," the statement said. "The database being created will contain only the device's 15-digit IMEI number, without any personal data."
The government approved the draft legislation last week. If adopted by parliament, it would require all mobile phones in Armenia to be registered, with unregistered devices blocked from connecting to local networks.
Officials say the system is intended to curb grey market imports of mobile phones. Speaking at the June 25 cabinet session, Prime Minister Nikol Pashinyan argued that the new rules would help combat illegal imports and improve market oversight.
The proposal has nevertheless drawn criticism from cybersecurity specialists and digital rights advocates, who warn that it could create new privacy risks and expand the state's surveillance capabilities.
Information security expert Samvel Martirosyan told CivilNet that while the IMEI code itself does not expose private data, it can still enable greater traceability of users’ devices.
“An IMEI number by itself does not give anyone access to the contents of your phone, your messages, or your conversations. But it does make certain forms of monitoring easier because a person can no longer effectively hide the device they are using,” he said.
He added that the system could have uneven effects across society. “For ordinary citizens, this may simply mean additional fees and more bureaucracy, but for people who could be subject to scrutiny, it creates mechanisms that facilitate monitoring,” Martirosyan said.
Data protection expert Grigor Hayrapetyan raised more fundamental legal concerns, arguing that the proposal goes beyond technical registration of devices. “The project is not just about creating a database of IMEI codes, but about linking IMEI codes with personal data, meaning it will be visible which phone belongs to whom,” he said.
Hayrapetyan warned that the creation of a centralized database introduces structural risks such as unauthorized access, abuse, or data leaks, even if strong cybersecurity measures are applied.
He added that concerns relate not only to security, but also to whether the system complies with core data protection principles such as purpose limitation and proportionality, which require that data be collected only for specific and necessary reasons.
Critics have pointed to examples abroad in which centralized databases have been exposed to leaks and sold on illicit markets, leading to fraud, scams, and other abuses.
Government officials, however, insist that the system differs from such models because it would record only device identifiers and not user information. They say the goal is to improve regulation of the mobile phone market, not to monitor individuals.
The proposal is expected to be debated further before moving to a parliamentary vote.
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