December 29, 2025, Yerevan
At its December 25, 2025 session, the RA Government approved the draft law “On Amendments and Supplements to the Law ‘On Audiovisual Media’” prepared by the Ministry of High-Tech Industry. The document was included in the list of issues not requiring a report. While this procedure is generally accepted (though not always justified), the fact that the draft law was not properly discussed with specialized non-governmental organizations either at the stage of generating the idea or in the course of drafting the document itself, raises concerns. All the more so if we take into account the fact that this working style of the Ministry of High-Tech Industry is already becoming a trend, with the ministry from time to time initiating modifications to the Law “On Audiovisual Media.”
Nevertheless, we, the undersigned journalistic organizations, find it necessary, within the scope of our mission, to make the existing concerns and perspectives publicly known through accessible channels. While the format of a statement does not allow us to address in detail all the positive and negative aspects of the draft law, several fundamental issues should nonetheless be highlighted.
Despite the justifications provided in the draft law, the authors failed to ensure legal certainty and define clear, self-contained norms in a number of provisions, especially in Article 9. For example, the phrase “dissemination of information containing propaganda of violence and cruelty” may be perceived and interpreted in very different ways, and, accordingly, also applied differently. The same concerns the broadcasting of “films and audiovisual programs containing propaganda of criminal subculture” and other provisions. Assurances that the regulatory body—the Commission on Television and Radio—has developed or will develop clarifying criteria are not fully convincing, as the draft itself contains evident risks of arbitrary decision-making inconsistent with advanced international practice.
Let us bring another example: in one case, the draft law prohibits the dissemination of calls for criminally punishable acts or other actions forbidden by law, whereas in another case, the propaganda of criminal subculture—which is also criminally punishable by nature—is subject only to a time restriction.
The absence or insufficiency of clarity and criteria may very likely result in the highlighted provisions being interpreted and applied according to political circumstances, posing a serious threat to freedom of expression and pluralism. Therefore, we express our readiness to present our detailed suggestions and considerations aimed at enhancing the draft law.
Based on the above, we urge:
- the Ministry of High-Tech Industry, prior to submitting this draft of amendments and supplements to the Law “On Audiovisual Media” to the parliament, to initiate an open discussion of the document with the engagement of journalistic organizations and other stakeholders;
- the National Assembly Standing Committee on Science, Education, Culture, Diaspora, Youth and Sport, as a signatory to the Memorandum on the Reform of Media Legislation, upon receiving the above-mentioned draft, to hold meetings and undertake practical work aimed at revising the document and bringing it into compliance with international norms.
COMMITTEE TO PROTECT FREEDOM OF EXPRESSION
YEREVAN PRESS CLUB
MEDIA INITIATIVES CENTER
JOURNALISTS’ CLUB “ASPAREZ”
MEDIA DIVERSITY INSTITUTE-ARMENIA
PUBLIC JOURNALISM CLUB
“JOURNALISTS FOR THE FUTURE” NGO
“JOURNALISTS FOR HUMAN RIGHTS” NGO
