Armenia to register mobile phone IMEI numbers: Experts warn of risks
IMEI registration in Armenia
The Armenian government plans to introduce a unified system to register and monitor the IMEI numbers of mobile phones. If the system comes into force, only phones that have entered the country legally or have been registered will be able to connect to mobile networks. The government plans to launch the system on 1 January 2027 and has already approved the decision.
Prime Minister Nikol Pashinyan said the measure targets the black market for mobile phones. He added that the government would introduce separate regulations for individuals to ensure that people bringing phones into the country for personal use do not face difficulties.
Government officials insist they have no intention of monitoring the country’s entire population. Information security experts, however, disagree. They also warn that the system could create risks for the protection of personal data.
“Keeping information on every phone and every citizen in the country on a single platform is the dream of any cybercriminal. If someone hacks that database — and no system is invulnerable — the security of every one of us will be at risk,” information security expert Artur Papyan said.
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Plans for a unified IMEI registration system
The government has approved draft amendments to the law on electronic communications.
According to the explanatory note, Armenia’s lack of IMEI oversight creates a number of risks. These include the circulation of mobile phones with counterfeit or modified IMEI numbers, which leads to:
- tax losses,
- unfair competition,
- more technical problems, and
- increased security risks.
The government argues that a unified IMEI system will allow the authorities to match customs and other records. As a result, only mobile phones that have entered the country legally will gain access to mobile networks.
“This will reduce the illegal trade in mobile phones, strengthen state oversight and improve public security.”
The new rules will also require importers and retailers to notify the authorised state body before importing or selling mobile phones. Individuals will be able to register the IMEI number of a newly purchased phone online.
The government says the new system will help reduce the shadow economy, regulate the mobile device market, protect consumers, and prevent phone theft and fraud.
Pashinyan: ‘The era of the black market for mobile phones is coming to an end’
Prime Minister Nikol Pashinyan said the government had discussed the issue for about six months. He stressed that many countries had already introduced similar systems.
“Armenia should follow the same path. That does not mean we should stop carrying out our regular oversight functions, including the strict controls we already enforce. But it is clear that we need radical, standardised and civilised solutions.”
According to Pashinyan, the mobile phone market is the country’s largest shadow market.
“No matter what we do, this market continues to operate. Our political conclusion is that the era of the black market for mobile phones is coming to an end. No phone without proof of legal import will work in Armenia.”
“All concerns will be addressed” – Justice Minister
Justice Minister Srbuhi Galyan rejected claims that the unified IMEI registration system would allow the authorities to monitor people.
“The goal is not to place anyone under surveillance. The goal is simply to stop the illegal import of mobile phones into Armenia,” she told reporters.
Responding to concerns about access to personal data, Galyan said the government would ensure a high level of data protection.
“We are currently drafting new legislation on personal data protection. I believe all your concerns will be addressed.”
Expert opinion
Information security expert Samvel Martirosyan explained that an IMEI is a mobile phone’s unique 15-digit identification number.
He argued that registering IMEI numbers would make people far easier to monitor.
According to Martirosyan, the authorities would create an organisation with access to a vast amount of information, including phone IMEI numbers, SIM cards, passport details and other personal data.
Under the proposed system, any phone whose IMEI number is not registered in the state database would eventually lose access to the mobile network.
“It will also be ‘great news’ for tourists. Someone comes to Armenia, and on the 30th day their phone stops working because it has not been registered. Or they will have to go through the registration process.”
Martirosyan argues that the proposal amounts to “disproportionate data collection” without adequate oversight mechanisms.
He questions whether introducing what he describes as “a system of excessive surveillance” for the entire population is justified in order to combat the black market. He says the government should first consult the expert community before adopting such a significant measure.
Referring to international practice, Martirosyan listed countries that have introduced similar regulations, including Turkey, Iran, Lebanon, Egypt, Uzbekistan, Kazakhstan, Azerbaijan, Tajikistan, Indonesia, Pakistan, Nepal, Cambodia, Bangladesh, Chile, Colombia and Mexico.
“As you can see, IMEI registration exists in the world’s ‘most democratic’ countries. And now another ‘bastion of democracy’ – Russia – is introducing it as well,” he said.
Information security expert Artur Papyan believes the government wants to establish comprehensive control over mobile phones.
According to Papyan, government officials describe the initiative as a way to “combat the shadow economy” and “prevent phone theft”. At first glance, he says, the proposal appears to be “a purely technical and harmless” measure. However, he argues that it deserves a broader assessment.
He says the authorities plan to create a massive database containing citizens’ passport details, personal information, phone IMEI numbers and all associated SIM and eSIM cards.
“This is not simply a tax enforcement tool. It will give the state the ability to see at any moment who is active on the network, from which device and when.”
Papyan also argues that the database, which would contain information on 2.5 million users, could fail at any time. If that happened, he says, mobile operators would have to disconnect users from the network.
He also warns that the draft law contains a provision that could affect everyone in the country. It would allow the database administrator to provide unspecified “other digital services” to state and local authorities, as well as private companies, using information stored in the database.
“In other words, data that is supposedly collected to ‘combat smuggling’ could tomorrow be used for completely different purposes that we know nothing about,” Artur Papyan said.
On the issue of combating phone theft, Papyan recalled numerous cases in which phone owners reported stolen devices to the police and provided the IMEI number, yet received no assistance.
IMEI registration in Armenia
