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Armenia Action Plan Review 2022-2024

This product consists of an IRM review of Armenia’s 2022-2024 action plan. The action plan comprises 10 commitments. This review emphasizes its analysis on the strength of the action plan to contribute to implementation and results. For the commitment-by-commitment data, see Annex 1. For details regarding the methodology and indicators used by the IRM for this Action Plan Review, see Section III.

Disclaimer: This publication was produced with the financial support of the European Union. Its contents are the sole responsibility of the Independent Reporting Mechanism (IRM) and do not necessarily reflect the views of the European Union. IRM assessments are conducted independently in collaboration with country researchers, reviewed by IRM staff and overseen by the International Experts Panel (IEP) to safeguard independence, objectiveness, and evidence-based research.

Overview of the 2022–2024 Action Plan

Armenia’s fifth action plan features promising commitments around data management, public communications, participatory budgeting, transparency of gifts received by public officials, and public procurement. Implementation will benefit from measures to ensure sustainability of results and more intensive public engagement.


Participating since: 2011

Action plan under review: 2022–2024

IRM product: Action plan review

Number of commitments: 10

Overview of commitments:

Commitments with an open government lens: 9 (90%)

Commitments with substantial potential for results: 1 (10%)

Promising commitments: 5

Policy areas:

Carried over from previous action plans:

· Land ownership transparency

· Beneficial ownership transparency

· Social protection

Emerging in this action plan:

· Policy for government-held data

· Public communication

· Freedom of information

· Participatory budgeting

· Public officials’ gifts

· Open justice

· Public procurement

Compliance with OGP minimum requirements for co-creation: No

Armenia’s fifth action plan (2022–2024) includes 10 commitments, focused mostly on improving government transparency. It introduces new commitments around government-held data, government communication, compliance with freedom of information, participatory budgeting, and judicial transparency. The inclusion of commitments on judicial transparency and participatory budgeting address IRM recommendations.

Similar to the previous action plan, this plan includes commitments incorporating legislative changes. All commitments are linked to other national strategies (particularly the 2021-2026 Action Plan of the Government of the Republic of Armenia) and to the Sustainable Development Goals. Several commitments also address recommendations by the Organisation for Economic Co-operation and Development and the Group of States against Corruption. While these links could strengthen support for implementation, civil society noted that the government planned to implement the activities regardless of their inclusion in the action plan.

Compared to the previous action plan, the co-creation process encompassed consultations with a wider geographic reach and a more proactive awareness raising by the government. International donors continued to support the co-creation process. The United Nations Development Programme supported the meeting in December 2021 to contribute to the co-creation process. The European Union (EU) supported the government and civil society organizations (CSOs) to conduct online consultations with stakeholders in eight regions, hold townhall meetings outside the capital, and carry out a wide range of awareness raising for OGP. Stakeholders assessed the quality of dialogue and geographical reach of the online meetings positively. Moreover, the government was more proactive in its public outreach, promoting OGP through public TV, radio, and traditional and social media. Proposals for commitments were collected electronically by email and, for the first time, via a special form on the government OGP website. In addition, several proposals were produced during a workshop by expert groups, formed based on the priorities in the action plan. This approach was a novelty and reflected the recommendations of previous IRM reports.

The government reviewed the proposals based on their alignment with OGP values and existing government priorities and, jointly with a consortium of CSOs, organized thematic workshops with stakeholders to draft commitments around the shortlist. According to stakeholders, the action plan generally addresses the priorities of government and civil society and is more strategic and comprehensive than previous plans.

IRM has assessed five commitments in detail. These commitments are considered promising as they are prioritized by civil society stakeholders and address policy areas important to Armenia’s open government context. Commitment 1 will legislate a government-wide data management policy and open data procedures. This will provide much-needed requirements across government agencies on what information they should make publicly available and free of charge. Commitment 2 will create a public communication strategy for the government, which could provide greater consistency to how government agencies communicate with the public and address information gaps and disinformation. Commitment 5 will set mechanisms to allocate a portion of community budgets to projects initiated and selected by citizens. It plans to develop participatory budgeting tools in three local communities, with an aim of helping more communities conduct their own participatory budgeting. Commitment 7 will establish a register of gifts received by public officials in connection with their services and adopt regulations on transferring gifts. Despite potential challenges to enforce the register and the regulations, the commitment could improve transparency around gift giving and receiving. Commitment 8 will create an e-procurement platform that will cover information on all stages of public procurement with an open data approach. It could allow easier data analysis and public oversight and procurement statistics in real time. It will also be linked to the beneficial ownership register, helping users identify the beneficial ownership information of all companies that bid on public tenders.

It will be important to maintain consistent public engagement during implementation and ensure the sustainability of results. Several commitments, such as the geoportal (Commitment 6), gift register, e-justice (Commitment 9), and e-procurement, focus on establishing the relevant platforms, while oversight and public awareness are expected to take place beyond the action plan. It is crucial that the government and civil society provide the necessary technical support for civil servants to ensure that the commitments reach their full potential in opening government.

Promising Commitments in Armenia 2022–2024 Action Plan

The following review looks at the five commitments that the IRM identified as having the potential to realize the most promising results. Promising commitments address a policy area that is important to stakeholders or the national context. They must be verifiable, have a relevant open government lens, and have modest or substantial potential for results. This review also provides an analysis of challenges, opportunities, and recommendations to contribute to the learning and implementation process of this action plan.

Table 1. Promising commitments

Promising Commitments
Commitment 1. Data policy legislation: This commitment will adopt a unified data management policy for all state-held information and define a policy for open data in the government.
Commitment 2. Strategic communication architecture: This commitment will develop a unified policy to guide all state bodies in their public communications and revise how participatory mechanisms solicit public feedback.
Commitment 5. Participatory budget on local level: This commitment will create guidelines and a toolkit to support local self-government bodies interested in taking up participatory budgeting. It will also pilot participatory budgeting in three local self-government bodies.
Commitment 7. Registry of gifts for public officials: This commitment will establish a public register with information on gifts received by civil servants in connection with their work. It will also establish mandatory procedures for declaring and registering gifts.
Commitment 8. Comprehensive system of electronic procurement: This commitment intends to create a single platform where procurement information will be published free of charge and automatically. The platform will also be made interoperable with the beneficial ownership register, allowing users to easily retrieve beneficial ownership information of the bidders for public tenders.


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