Since 2021, the electoral and related legislation of the Republic of Armenia has undergone significant and wide-ranging changes aimed at ensuring more complete realization of electoral rights, increasing the effectiveness of electoral processes, strengthening the integrity of political parties, preventing illegal influence on electoral processes, including through the misuse of administrative resources, charity, and other methods, as well as the abuse of finances, improving oversight of electoral processes and political financing, and tightening liability for electoral violations.

Nevertheless, as 2026 approaches, numerous risks remain. These include threats of cyberattacks, disinformation, information manipulation, and the spread of hate speech, in response to which Armenia’s state institutions are carrying out certain efforts. At the same time, unlimited financial flows (cash and crypto), campaigning and its financing by third parties, and external influence through unregistered political and civil entities remain outside their focus. It is evident that these risks are neither properly recognized, nor adequately addressed by the relevant authorities. It is also clear that even the oversight functions prescribed by law are not sufficiently implemented. Under these conditions, the state’s preparedness to guarantee competitive, clean, free, fair, transparent, and lawful elections is called into question.

On the doorstep of 2026, changing the rules of the game for political parties is controversial, though, it is urgent to address issues of transparency and accountability in election financing, without which it is impossible to hold elections that meet democratic principles and international standards.

Below are the proposals of the undersigned civil society organizations. It is expected that they will be acted upon in order to prevent, as much as possible, the involvement of “dirty money” in the upcoming parliamentary elections and to ensure transparency of financing.

1. Under the legislation of the Republic of Armenia, any political party may participate in elections, even if it is established just a few days before the registration deadline. Political entities/movements may abuse this opportunity. Some already organize large-scale and costly campaigns without any accountability. This creates unequal starting conditions for different political forces involved in the electoral contest, distorts competition, and also carries risks from the perspective of foreign interference.

Recommendation:
It is necessary to regulate the transparency and accountability of the activities of unregistered political entities by applying to the extent possible,the requirements applicable to registered parties.

  • The Electoral Code of the Republic of Armenia should require that parties running in upcoming elections that did not have state registration during the preceding year must record their campaign-related income and expenditures starting, at a minimum, from the moment the Central Electoral Commission (CEC) sets the election date, and include them in their campaign funds.
  • An obligation should be established for members of the governing bodies of newly registered parties to submit asset and income declarations covering the previous year at the time of nomination of the party (including within an alliance), if they are not already subject to declaration.

2. According to Part 1 of Article 27 of the Electoral Code of the Republic of Armenia, candidates and parties/alliances are obliged to cover expenses related to the preparation, organization, and conduct of election campaigning from the campaign fund, which is financed exclusively through the parties themselves. Under the RA Law “On Parties,” legal persons are prohibited from making contributions to parties, and certain thresholds are set for natural persons. However, there is no legal prohibition preventing legal entities (in particular, party-affiliated media outlets, foundations, or companies) from conducting campaigning themselves, or individuals from spending amounts exceeding the established thresholds for campaigning in order to support or harm competing forces. Consequently, the party financing thresholds set by the Electoral Code of the Republic of Armenia and the Law “On Parties” are misleading and, in practice, meaningless if they are not accompanied by constraints on third party financing. Existing liability measures for the involvement of illegal financing are insufficient. Their current scope and the severity of prescribed sanctions cannot prevent violations.

Recommendation:
It is necessary to limit, though not prohibit, the contributions (including in-kind contributions) of third parties involved in pre-election campaigning.

  • A reasonable threshold should be established for expenditures made by other persons in order to prevent circumvention of campaign expenditure limits outside the procedures set by political finance legislation and to prevent disruption of a level playing field.
  • Administrative and/or criminal liability should be stipulated for violation of contribution limits by third parties involved in campaigning or for circumventing these limits by any means through other persons. Scope of liable subjects for the investment and use of illegal funds in favor of a party should also be expanded, and not limited solely to party members.

3. The financial transparency and accountability of parties established by legislation are not fully ensured. According to Article 27 of the RA Law “On Parties,” a party submits its annual report for each reporting year to the Corruption Prevention Commission (CPC) by February 20 of the year following the reporting year. The CPC publishes these reports on its website within three days, except for parties subject to audit (i.e., those receiving state budget funding and exceeding the AMD 25 million threshold), whose annual reports and audit opinions are published within three days after the audit opinion is received.

Thus, the reports of the most significant parties become available several months later, and in the case of the 2026 parliamentary elections—immediately before the elections, which does not allow voters to properly examine the materials and also creates unequal conditions for competing parties.

According to Article 26 of the RA Electoral Code, after the deadline for registration of electoral lists of parties/alliances participating in elections and until the third day after voting, every three working days, banks submit to the CPC data on the balances, inflows, and outflows of financial resources in the bank accounts of parties participating in elections (including within alliances). The CPC summarizes this data, prepares a summarized report, and publishes it on its website.

However, there is no accountability—neither for voters, nor for the CPC, nor for the CEC—regarding financial flows during the period preceding the deadline for registration of electoral lists, even though it is the function of the CEC’s Audit and Oversight Service to examine the expenditures of political forces. In relation to the 2026 parliamentary elections, this means that income received from January 1, 2026 until approximately the start of the campaign in early May will become available only the following year, in May 2027.

Recommendation:
It is urgent to ensure timely transparency and full oversight of pre-election campaign financing.

  • It is necessary to guarantee that parties participating in the 2026 parliamentary elections submit to the CEC their financial reports for January–May 2026 (up to the day of the start of pre-election campaigning) and that these reports are made public.
  • A requirement should be introduced to publish the patronymic names of parties’ donors.
  • A requirement should be established that all service contracts concluded by parties with legal and natural persons in the context of campaigning be published or, at a minimum, made available to observer organizations as electoral documents.
  • For the future, legal and technical foundations should be created to ensure real-time publication of party financial inflows for contributions exceeding the minimum wage.
  • It is also necessary to provide a mechanism whereby the financial reports of parties subject to audit are published on equal terms with others, with the possibility of subsequent adjustments.

“Akanates” Observation Mission
“Independent Observer” Observation Mission