Armenia: A model for economy-wide beneficial ownership transparency

Armenia’s mining sector, responsible for around 28% of exports in 2022, has long been vital to the economy. But for years, hidden company ownership and undisclosed political ties weakened public oversight, eroded trust and heightened corruption risks, putting sustainable development and investor confidence at stake. In 2020, investigations by journalists and civil society revealed links between influential individuals and mining companies, raising concerns around conflicts of interest in license awards. Without access to beneficial ownership data, regulators lacked tools to detect risks and ensure accountability.

Following Armenia’s 2018 “Velvet Revolution”, the government made transparency and anti-corruption priorities of its reform agenda. With strong backing from civil society and the EITI multi-stakeholder group, beneficial ownership disclosure became a cornerstone of these efforts. Armenia joined the EITI in 2017, with support from the World Bank, and was among the first countries to pilot beneficial ownership reporting in the extractive sector in 2020. A year later, the government launched a public beneficial ownership register, initially covering extractive companies, and in 2023 expanded it to cover the entire economy, setting a transparency standard that goes beyond the EITI framework.

Under the Opening Extractives (OE) programme, launched in Armenia in 2021, the EITI and Open Ownership have provided technical assistance to accelerate these reforms and scale up data use. This has led to stronger and more systematic beneficial ownership disclosures, and greater use of ownership data by civil society and the media to drive accountability. Armenia’s progress offers a model for other countries seeking to advance transparency, accountability and good governance through beneficial ownership disclosure.

OE has helped strengthen Armenia’s central beneficial ownership register, supporting transparency and oversight across sectors. A 2022 review of Armenia’s initial disclosures laid out a clear path for further improving the register – including consolidating fragmented data systems, strengthening data verification and increasing use of ownership data by public and civil society actors. 

• Economy-wide coverage: As of 2023, over 120,000 legal entities were covered, transforming Armenia’s corporate landscape and strengthening safeguards against corruption. Companies must disclose beneficial owners with 20% or more ownership or control over the company. This threshold is lower for extractive companies, which must report owners with an ownership level of 10% or higher. Where the beneficial owner is a politically exposed person, the threshold drops to 0%.
• Public access: Basic company and beneficial ownership information is freely accessible via the State Registry, such as full name of the beneficial owner, their citizenship, the year in which the ownership relationship began and the ownership percentage. Access to further details (i.e. date in which the person became a beneficial owner, passport number, patronymic name and registered address) requires registration and a fee. Journalists benefit from free access to detailed information, enabling cross-checks with other datasets in investigations.

In countries where beneficial ownership information is publicly accessible, we see stronger democratic institutions and greater public trust in government. Armenia’s commitment to making this information available through its Business Registry is a vital step toward building transparency, promoting accountability and combating corruption. Rather than deterring investment, this transparency fosters a more attractive and secure environment for responsible business and long-term investment.

OE has supported the development of robust legal and data systems for ownership data collection, disclosure and verification. 

• Legal reforms: In June 2021, Armenia adopted legal amendments expanding beneficial ownership disclosure beyond the extractive sector. Supported by OE’s technical guidance and drawing on international best practice, the reforms introduced a clear legal definition of beneficial ownership and disclosure thresholds, with a phased rollout starting in the metal mining sector in September 2021 and extending to most legal entities by 2023.
• Structured data: In 2021, Armenia became one of the first countries to publish ownership data in accordance with the Beneficial Ownership Data Standard (BODS), improving data quality, accessibility and interoperability.
• Digital declarations: Feedback from companies led to the introduction of a digital platform to replace PDF declarations forms, improving usability, submission rates and data quality. Technical guidance and support from the OE team helped operationalise this shift.
• Verification mechanisms and data reliability: With OE support, the Armenian government strengthened its tools to identify data inconsistencies and verify foreign ownership through a risk-based approach. This built on findings from the 2022 OE scoping report and helped align Armenia’s systems with international good practice.

The Opening Extractives programme has been instrumental in strengthening transparency in Armenia’s extractive sector. It has supported our efforts to identify beneficial owners, develop new transparency mechanisms, and reinforce public trust in both government and industry.

Efforts are underway to embed beneficial ownership data into Armenia’s mining licensing processes to improve governance and integrity.

• Due diligence tools: Armenia piloted a draft due diligence framework to support licensing authorities in assessing applications using beneficial ownership data. With support from the OE programme, the Ministry of Territorial Administration and Infrastructure (MTAI) has begun integrating these tools into mining licence screening. Targeted training sessions helped officials understand how to use ownership data to enhance due diligence, improve transparency and flag potential conflicts of interest. This work is informing the OE programme’s new licensing manual, expected in 2025, which aims to embed the systematic use of beneficial ownership information into licensing procedures.
• Legal safeguards: The MTAI proposed legislation to bar an entity’s beneficial owners as well as their affiliated persons and close relatives from acquiring mining rights for 10 years if previous rights were revoked to that entity under the grounds stipulated in the Subsoil Code. The MTAI is working to secure the legal authority to use ownership data in this process, in consultation with Open Ownership.

The programme has contributed directly to our work on improving licensing procedures at the Ministry of Territorial Administration and Infrastructure, providing valuable guidance on integrating ownership data into due diligence processes. These efforts are vital to ensuring that Armenia’s natural resources are managed responsibly and in the public interest.

Through partnerships with local organisations, OE has strengthened the capacity of journalists and civil society actors to use beneficial ownership data for oversight and accountability.

• Data use workshops: Between 2021 and 2022, OE and the Freedom of Information Center of Armenia (FOICA) trained over 50 journalists and civil society actors in using beneficial ownership data to identify irregularities. FOICA continues to train non-governmental actors and produced a video tutorial on using the register.
• Investigative journalism: OE and FOICA training programmes led to seven investigations linking ownership data with tax, royalty and procurement data. Findings revealed undisclosed and politically linked ownership in a hydroelectric power project tied to a member of parliament, foreign and politically connected ownership behind gold exploration applications in Lori province, failures to disclose or fully declare beneficial owners in mining operations in Syunik and Lori, and incomplete or misleading beneficial ownership declarations in Armenia’s media sector.
• Awareness-raising: With OE support, FOICA developed accessible information cards to promote public understanding of beneficial ownership data, helping support broad civil society advocacy in the country, as well as corporate accountability.

Armenia’s progress in beneficial ownership transparency offers a compelling model for other EITI countries. By enacting legal reforms, improving data systems and building capacity for data use, Armenia has demonstrated how openness can drive accountability, mitigate corruption risks and foster a more responsible extractive sector.

With continued OE support, Armenia is well placed to embed ownership checks in licensing, strengthening data verification, and ensure beneficial ownership data serves the public interest.

Civil society groups should be granted with complete and free access to public registry. If challenges are managed, I am convinced that in two years we will have progressive practices in beneficial ownership transparency.

The Opening Extractives programme is made possible with the generous support of the BHP Foundation. This impact story includes contributions from Louise Russell-Prywata (Deputy Executive Director, Open Ownership), Emily Manuel (Senior Regional Manager Asia Pacific, Open Ownership), Agustina De Luca (Senior Advocacy Manager, Open Ownership), Phoebe Williams (Advocacy Associate, Open Ownership), Isabelle Kermeen (Communications Manager, Open Ownership), Alice Perepyolkina (EITI Communications Officer) and Leila Pilliard (Communications Manager, EITI).