“The state will be able to see at any time which device you use and when you are active on the network”

Artur Papyan, co-founder of Cyberhub.am, commented on the Armenian government’s plan to introduce a unified IMEI system to ensure the full registration and consistency of imported mobile phones.

“At first glance, it sounds technical and harmless: ‘fighting the shadow economy’, ‘preventing phone theft’. But let’s look at what is actually planned:

1. A massive database will be created linking your passport and personal data, your phone’s IMEI code, and all your SIM/eSIM cards. This is not merely a tax administration tool: it would allow the state to see at any time who is active on the network, which device they are using, and when. 

2. If this database, which processes data from 2.5 million users every minute, goes offline, operators will be forced to disconnect users from the network. And we know how government databases perform – for example, the first-grade school registration system, which this week was expected to serve only about 20,000 parents simultaneously but simply failed to function. 

3. The draft contains another concerning provision: the database administrator may use the information to provide ‘other digital services’ to state and local government bodies or even private companies. In other words, data supposedly collected to ‘combat smuggling’ could tomorrow be used for entirely different purposes that are unknown to the public. 

4. Centralizing data on every mobile phone and citizen in the republic in a single database is a dream target for cybercriminals. If this database is ever hacked – and no system is invulnerable – the security of every one of us would be at risk,” Artur Papyan wrote. 

On June 25, the government approved the draft law “On Amendments and Supplements to the Law on Electronic Communications” and related legislative amendments.

According to the explanatory note, the lack of control over IMEI codes in Armenia creates a number of risks, including the circulation of mobile phones with non-customs-cleared, counterfeit, or altered IMEI codes. This results in tax losses, distorts market competition, and increases technical and security risks. Accordingly, the government plans to introduce an effective system to ensure the full registration and traceability of imported mobile phones in line with international best practices.

Commenting on the initiative, Prime Minister Nikol Pashinyan said:

“The mobile phone market is the largest shadow market, and what we are doing is ensuring that this market can continue to operate legally. Similar solutions have long existed around the world, and our political message is that the era of the black market for mobile phones is coming to an end. No mobile phone in the Republic of Armenia that has not been certified as legally imported will be able to operate.”