In the past few years, the Armenian CSOs have constantly faced the government desire to take them under control through getting more financial information on them. At present, the State Revenue Committee gets more information than it did before, which raised questions about the need for these amendments to the NGO law. The changes have been made without proper consultations during the COVID-19 pandemic lockdown. Because of the new law now the NGOs are asked for more information on their financial income with a detailed description of the implemented projects. This shrinks the space for civil societies to freely decide on their accountability and relation with the public in regards to the information they want to publicize. 

 More legitimacy, transparency and accountability to NGOs, but in reality...

The only reporting obligation for NGOs was to provide the state with a financial report if the NGO used public money.

On 29 October 2018, the State Revenue Committee of Armenia published draft amendments to the Law on Public Organisations. The original Law on Public Organisations dates from 2016 and required reporting only by those NGOs in receipt of public resources (resources of state or local self-government bodies and bodies or legal entities that manage public resources). The draft proposed in 2018 introduced a reporting requirement for all public organisations regardless of their funding source. In its first version, it required the online publication of personal data about donors, members, staff, governing bodies and volunteers who had received funding. Finally, the part of the report to be published online should include “the names of public administration and local self-government bodies, the names of legal entities, the residency and the legal form of the organisation, the group of individuals according to the size of the income made. The part of the report which would not be published online includes the physical person's name, surname, the amount of income, the passport data, public service number, residency address or place of registration, telephone number all of which are non-disclosable personal data, and the processing, as well as transfer of these data to third parties and their use, shall be carried out exclusively by the authorized body, in accordance with the procedure established by law. Personal data relating to the source of annual income may be included in the report published on the website at the discretion of the organisation publishing the report, and only in compliance with the law.”

The first proposal met with strong opposition by the NGO sector which was basing itself on Council of Europe standards. In this context, a Working Group on the “Issues of Transparency and Accountability Provision of NGOs and Foundations” was set up under No 93-A Decree dated on 14 February 2019. The draft law was developed by this Working Group which was composed of representatives of the public authorities and 9 members representing civil society organisations. My organisation and I were not part of this working group, but most of the selected organisations are trusted by CSO representatives.


At the end of February 2020 NGOs were consulted by parliamentary committees on the proposed amendments to the Law on Public Organisations. On 6 March 2020 the law was passed in its first reading. The amendments adopted in the first reading refer to Article 24 of the current Law. After the second reading in the National Assembly of the Republic of Armenia, which took place on 25 March 2020, the President signed the amendments on 8 April 2020.

The issue here is related to the so-called “shrinking space” for civil society organisations. We see the fact that the government wants full and comprehensive information about each NGO, about the whole third sector. Even though we still have not submitted any report, as we were waiting for the official template forms to be published and it was optional for the first year, we think that this should be seen in the recent development of labeling many organisations. In Armenia we have the labeling of “Soros” organisations, or if you are working with European institutions, foundations and NGOs, then you belong to the pro-European anti-nationalistic and anti-traditional groups, you “eat” grants and do money laundering. Also, in the Armenian society the recent discussions on the Istanbul convention have led to the rise in hate speech against the Council of Europe and the EU.

All the above-mentioned processes of adopting a law also need to be seen through the prism that happened during the strictest lockdown and COVID-19 pandemic outbreak. After the public discussion with NGOs and Parliamentarians, where no consensus was reached, many left the room with anger and feeling that watchdog NGOs are being restricted now. When the full lockdown started, there were no further public discussions with the stakeholders. The law was passed so quickly and quietly that we all were disappointed. All the processes in the country were slowed down, however, the parliament was operating as if there was nothing happening in the country, even more than 100 MPs gathered in one room without proper social distancing most of the time and passed laws.

As a youth NGO, we will see what this new amendment brings, however, this is a concrete example of shrinking CSOs’ space by forcing them to publish their donors, financial income and projects. We see it as an attempt to have access to the full financial information of NGOs under the excuse of making NGOs more legitimate, accountable and transparent to the public. This could raise and deepen the polarisation of society resulting from the division between the organisations considered as “acting in the public interest” and “foreign agents” because of publishing all financial income and the donors list of NGOs. We do not believe in the fake narrative of bringing more visibility and transparency to the NGO sector, as many NGOs voluntarily publish their financial income and projects in their websites and are accountable to their stakeholders and target groups. This extra information which is mandatory and is submitted to the state body can be used to control the NGOs and make them dance to the government’s tune.