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Armenia Progress Report 2016-2018

For the complete and official IRM report with any updates, download it from the Documents section below.

Armenia’s third action plan aims to improve transparency of government spending and service provision. However, the commitments are too limited in scope to lead to significant changes. The next plan could involve wider consultation and more ambitious commitments.



Well-Designed? *

2. Transparency of state grants

Publish information on grants funded by each state agency.


3. Interactive budget in open data

Improve interactive budget platform to enable users to search, download, process and re-use data.


7. Accessibility of integrated social services

Introduce public platform with information on social services, where citizens can rate services received.


* Commitment is evaluated by the IRM as specific, relevant, and has a transformative potential impact

The OGP task force began development of the third action plan included online consultation platforms and regional meetings. The final selection of the commitments took place during a two-day multi-stakeholder workshop with participation from CSOs, state agencies and international organizations. Greater awareness of the development and the implementation of the action plan, would generate more participation. 

Armenia did not act contrary to OGP process

A country is considered to have acted contrary to process if one or more of the following occurs:

  • The National Action Plan was developed with neither online or offline engagements with citizens and civil society
  • The government fails to engage with the IRM researchers in charge of the country’s Year 1 and Year 2 reports
  • The IRM report establishes that there was no progress made on implementing any of the commitments in the country’s action plan
Mostly “governance” civil society Primarily agencies that serve other agencies

Commitments in Armenia’s third action plan covered state budget, local government, social services, licensing, and accountability of public officials. The overall level of implementation at the end of the first year of the action plan was low.

Commitment Title Well-designed* Complete Overview
1. Transparency of public officials’ trips No No This commitment seeks to create a publicly accessible online platform to report public officials’ business trips. The government has used the existing e-government platform, but the reports are published in PDF format and are not searchable.
2. Transparency of state grants No No This commitment aims to improve budget transparency by providing information on state-funded grants. While some ministries have begun reporting, the commitment does not create a competitive mechanism for grant distribution.
3. Interactive budget in open data No No This commitment aims to improve the current interactive budget platform. While the commitment could improve the searchability of information, changes in practice would depend on the usage of the budget platform.
4. Officials’ declarations in open data No No This commitment seeks greater transparency for high-ranking officials’ declarations. However, the list of non-compliant officials was not published on time, and search capabilities of the platform have not been enhanced.
5. Portal for community decisions No No This commitment seeks to create a unified, online portal for community decisions. The existing Armenian Legal Information System was expanded, but information is not searchable.
6. Licensing register No No The commitment aims to create a unified electronic register of people subject to licensing by state bodies. The new platform is expected to launch May 2018, after the amendments to the “On Licensing” law takes effect.
7. Accessibility of integrated social services No No This commitment seeks to publish information on social services. Progress has been made with the www.esocial.amwebsite, but it is still not possible to rate services or to use an online consultation service.
8. One-stop-shop military registration offices No No This commitment seeks to improve administrative efficiency in military registration. However, implementation was suspended due to planned changes to the military registration offices.

* Commitment is evaluated by the IRM as specific, relevant, and has a transformative potential impact

  1. Raise awareness about OGP process and results through varied communications and outreach.
  2. Coordinate with the Parliament to include more ambitious commitments requiring legislative action.
  3. Increase public participation in the budget development process and expand the ambition of commitments focused on transparent government spending, e.g. with a commitment to establish competitive and transparent mechanisms for awarding state grants and service contracts by executive agencies.
  4. Develop more ambitious commitments that address anti-corruption issues, e.g. providing free access to information on the founders and current shareholders of companies.
  5. Evaluate impact and gaps of implemented commitments to identify areas of focus in future action plans.

All OGP-participating governments develop OGP action plans that include concrete commitments over a two-year period. Governments begin their OGP action plans by sharing existing efforts related to open government, including specific strategies and ongoing programs.

Commitments should be appropriate to each country’s unique circumstances and challenges. OGP commitments should also be relevant to OGP values laid out in the OGP Articles of Governance and Open Government Declaration signed by all OGP-participating countries.[Note85: Open Government Partnership: Articles of Governance, June 2012 (Updated March 2014 and April 2015), ]

What Makes a Good Commitment?

Recognizing that achieving open government commitments often involves a multiyear process, governments should attach timeframes and benchmarks to their commitments that indicate what is to be accomplished each year, whenever possible. This report details each of the commitments the country included in its action plan and analyzes the first year of their implementation.

The indicators used by the IRM to evaluate commitments are as follows:

·       Specificity: This variable assesses the level of specificity and measurability of each commitment. The options are:

o   High: Commitment language provides clear, verifiable activities and measurable deliverables for achievement of the commitment’s objective.

o   Medium: Commitment language describes activity that is objectively verifiable and includes deliverables, but these deliverables are not clearly measurable or relevant to the achievement of the commitment’s objective.

o   Low: Commitment language describes activity that can be construed as verifiable but requires some interpretation on the part of the reader to identify what the activity sets out to do and determine what the deliverables would be.

o   None: Commitment language contains no measurable activity, deliverables, or milestones.

·       Relevance: This variable evaluates the commitment’s relevance to OGP values. Based on a close reading of the commitment text as stated in the action plan, the guiding questions to determine the relevance are:

o   Access to Information: Will the government disclose more information or improve the quality of the information disclosed to the public?

o   Civic Participation: Will the government create or improve opportunities or capabilities for the public to inform or influence decisions?

o   Public Accountability: Will the government create or improve opportunities to hold officials answerable for their actions?

o   Technology & Innovation for Transparency and Accountability: Will technological innovation be used in conjunction with one of the other three OGP values to advance either transparency or accountability?[Note86: IRM Procedures Manual. Available at: ]

·       Potential impact: This variable assesses the potential impact of the commitment, if completed as written. The IRM researcher uses the text from the action plan to:

o   Identify the social, economic, political, or environmental problem;

o   Establish the status quo at the outset of the action plan; and

o   Assess the degree to which the commitment, if implemented, would impact performance and tackle the problem.

Starred commitments are considered exemplary OGP commitments. In order to receive a star, a commitment must meet several criteria:

·       Starred commitments will have “medium” or “high” specificity. A commitment must lay out clearly defined activities and steps to make a judgment about its potential impact.

·       The commitment’s language should make clear its relevance to opening government. Specifically, it must relate to at least one of the OGP values of Access to Information, Civic Participation, or Public Accountability.

·       The commitment would have a “transformative” potential impact if completely implemented.[Note87: The International Experts Panel changed this criterion in 2015. For more information visit: ]

·       The government must make significant progress on this commitment during the action plan implementation period, receiving an assessment of “substantial” or “complete” implementation.

Based on these criteria, Armenia’s action plan does not contain any starred commitments.

Finally, the tables in this section present an excerpt of the wealth of data the IRM collects during its progress reporting process. For the full dataset for Armenia and all OGP-participating countries, see the OGP Explorer.[Note88: OGP Explorer:]

General Overview of the Commitments

Armenia’s third action plan contains eight commitments, grouped into three topics: ensuring transparency and accountability (Commitments 1-4), promoting access to information (Commitments 5-7) and strengthening public integrity (Commitment 8). The commitments cover areas such as state budget, local government, social services, licensing and accountability of public officials. One of the commitments, related to the publication of declarations of high ranking officials (Commitment 4), was carried over from the second action plan. The commitment on community decisions’ platform is aimed at the transparency of local government, which was also covered in the previous action plan. Other commitments include new initiatives, generally addressing access to information and e-governance issues. The relevance of the commitment on “One-Stop-Shop in the Army” (Commitment 8) is unclear as it primarily addresses public administration and bureaucracy issues.


This report presents the commitments of the third action plan in the same sequence and specification as provided in the original action plan.

The Open Government Partnership (OGP) is an international multi-stakeholder initiative that aims to secure concrete commitments from governments to their citizenry to promote transparency, empower citizens, fight corruption, and harness new technologies to strengthen governance. OGP provides an international forum for dialogue and sharing among governments, civil society organizations, and the private sector, all of which contribute to a common pursuit of open government.

Armenia began its formal participation in October 2011, when Edward Nalbandian, the Minister of Foreign Affairs, declared his country’s intention to participate in the initiative.[Note1: Armenia Letter of Intent to Join OGP,]

In order to participate in OGP, governments must exhibit a demonstrated commitment to open government by meeting a set of (minimum) performance criteria. Objective, third-party indicators are used to determine the extent of country progress on each of the criteria: fiscal transparency, public official’s asset disclosure, citizen engagement, and access to information. See Section VII: Eligibility Requirements for more details.

All OGP-participating governments develop OGP action plans that elaborate concrete commitments with the aim of changing practice beyond the status quo over a two-year period. The commitments may build on existing efforts, identify new steps to complete ongoing reforms, or initiate action in an entirely new area.

Armenia developed its third national action plan between February 2016 and June 2016. The official implementation period for the action plan was 12 August 2016 through 30 June 2018. This year one report covers the action plan development process and first year of implementation, from August 2016 to August 2017. Beginning in 2015, the IRM started publishing end-of-term reports on the final status of progress at the end of the action plan’s two-year period. Any activities or progress occurring after the first year of implementation, 31 August  2017, will be assessed in the end-of-term report. The government published its draft self-assessment in September 2017. At the time of writing, November 2017, the final version of the self-assessment report has been published.

In order to meet OGP requirements, the Independent Reporting Mechanism (IRM) of OGP has partnered with Tatevik Margaryan, independent researcher, who carried out this evaluation of the development and implementation of Armenia’s third action plan. To gather the voices of multiple stakeholders, the IRM researcher held focus groups and interviews in Yerevan, Dilijan, and Gyumri. The IRM aims to inform ongoing dialogue around development and implementation of future commitments. Methods and sources are dealt with in Section VI of this report (Methodology and Sources).

Armenia is engaged in policy reform processes in an environment of high levels of poverty, corruption and security threats on its border. The current action plan reflects a number of relevant issues related to budget information, asset and income declarations of public officials, decision-making of local authorities and social service delivery. However, civil society considers commitments to be too limited in scope to address the core problems related to current government practices and spending of public funds.

2.1 Background

Armenia’s OGP eligibility criteria (budget transparency, access to information, asset declaration, and citizen engagement) remains unchanged in 2017.

Armenia scores 96 out of 150 on the Right to Information Index, which assesses the strength of countries’ legal framework on the right to information.[Note2: Global Right to Information Rating, The Centre for Law and Democracy,] Armenian Freedom of Information (FoI) legislation was passed in 2003 but access to government-held information, including previously classified Soviet-era files, was problematic. State bodies had frequently cited absence of regulations for implementation of the law as grounds for denying information requests or provision of incomplete information.[Note3: Freedom of the Press 2016: Armenia, ] In October 2015, the Government of Armenia adopted a regulation on the information provision by state bodies with the aim to improve the implementation of FoI legislation. Approved regulations include permitting electronic requests for information, a new procedure of information provision by streamlining the classification, maintenance and provision of information from the government to the public and defining responsibilities of officials responsible for FoI requests.[Note4: Government of Republic of Armenia, Decision No 1204-N, 15.10.2015, ] The previous OGP Action Plan (2014–16) included a commitment on trainings for public officials responsible for handling FoI requests (Commitment 10). At the time of writing, in November 2017, a new draft of the Law on Freedom of Information was under discussion.

Armenia meets minimum requirements for fiscal transparency, that is, having key budget documents publicly available, complete and generally reliable.[Note5: U.S. Department of State 2017 Fiscal Transparency Report,] The Ministry of Finance provides information on the budget and budget reports in a downloadable format on its own website[Note6: The website of the Ministry of Finance of the Republic of Armenia,], while procurement plans, announcements and reports are available on website. However, government spending is not fully transparent, and many cases of conflict of interest, excessive spending on specific products or services, and procurements not serving their purpose are often pointed out by investigative journalists.[Note7: See, for example, media stories by Civilnet under heading “From your pocket to…”,քո-գրպանից, a number of publications in Hetq, such as: “Companies winning in public procurements are not accidental”, 14.09.2017,, , “Ten most expensive restaurants in Armenia: millions of property tax are not paid”, 30.08.2017,, as well as other media publications: “Taron Margaryan makes lavish expenses to please himself: the municipality has bought 500 cognacs”, 29.08.2017,, 41 million AMD for Dilijan training center’s cocktail spoons, cigar clippers and other freaks”, 08.12.2015,] The third action plan includes a commitment on budget transparency, making the state budget available in an interactive electronic platform through applying open data principles with a possibility to download and process the information (Commitment 3).

Open data initiatives have been picking up in Armenia. Several e-government platforms, such as,,, and others, provide information on official statistical data, decisions and legislation.[Note8: Open Data in State Sector of Armenia, 01.12.2016, ] For example, provides data on procurement from single source, funding for state non-commercial organizations and decisions of the prime minister and government cabinet. The unified statistical portal of the Ministry of Justice——provides publication and analysis of statistical data from the State Register of Legal Entities, Civil Status Register, the Compulsory Enforcement Service of Judicial Acts and the Department of Courts. The system combines predefined statistical indicators, which can be viewed as a graph, table, or downloaded as a .csv file. The online database of the Central Bank of Armenia——provides statistical information on economic indicators. However, not all of these platforms function properly or are easy to use. A new foundation, Digital Armenia, was established by the government to form a common digitized environment in all areas of governance on the basis of modern information technologies.

Armenia is categorized as a “partly free” country according to the Freedom House. The Freedom in the World report from 2016 reveals that people’s ability to influence government decisions is limited and formal political opposition is weak.[Note9: Freedom House, Freedom in the World 2017: Armenia,] The ruling party’s dominance and control of administrative resources prevents a level playing field.[Note10: Freedom House, Freedom in the World 2016: Armenia,]

A constitutional referendum was held in Armenia in 2015. The approved amendments to the constitution will result in a change in the country’s political system, from semi-presidential to a parliamentary republic, which is planned to happen in April 2018 when the current president’s term is over.

The Constitution of Armenia guarantees civil liberties, freedom of expression and freedom of assembly and association. However, the Armenian government has a record of interference with public protests. Armenian human rights groups have highlighted the misuse of the penal code to intimidate protesters and prevent protests deemed unfavorable by the government.[Note11: Civicus Monitor, ] The police took harsh measures against peaceful protesters calling for resolution of a siege following the seizure of a police station by armed citizens. A large-scale police operation resulted in dozens of injured protesters and journalists.[Note12:, Yerevan: Police and Demonstrators Clash; 60 Injured, 30 July 2016, ] According to Human Rights Watch, authorities have used excessive force against peaceful protesters and pressed unjustified criminal charges against protest leaders.[Note13: Human Rights Watch Report 2017, Armenia,] Nations in Transit Report 2017 shows a declined rating of National Democratic Governance (from 5.75 to 6.00 on a scale from 1 to 7, where 1 is the most democratic and 7 is the least democratic) justified by the inability of the government to address legitimate popular grievances before they spill over into protest, and then to resolve those protests without violence.[Note14: Nations in Transit 2017, Armenia Country Profile, ]

Media freedom faces challenges. Most print and broadcast outlets are affiliated with political and commercial interests, and journalists are known to practice self-censorship to avoid harassment. Most independent outlets carrying out investigative journalism operate online.[Note15: Freedom House, Freedom in the World 2016: Armenia, ] Taking into account the growing internet penetration rate, reaching 70.1 percent by June 2017, online media and resources are accessible to most of the population.[Note16: Internet World Stats, ] Civil society in Armenia includes a few outspoken organizations and watchdog groups, mostly in Yerevan[Note17: Freedom House, Freedom in the World 2016, ]. Non-governmental organizations lack local funding and rely largely on the support of foreign donors. In December 2016, the parliament passed a new Law on Public Organizations[Note18: Non-governmental organizations in Armenia are classified into public organizations (which is the majority of NGOs) and foundations by their legal status.], which was developed with extensive input from civil society and had been on the civil society and government agenda for several years. The law allows public organizations to directly engage in income-generating activities and represent their constituents’ interests on environmental issues in courts, and requires organizations receiving public funding to submit annual financial reports.[Note19: USAID 2016 CSO Sustainability Index (CSOSI) for Central and Eastern Europe and Eurasia, ]

On the policy level, the government has undertaken a range of legal reforms on anti-corruption measures, however, implementation of the law remains the main problem. Corruption is pervasive. Armenia ranks 113 out of 176 countries on Transparency International’s 2016 Corruption Perceptions Index, sharing this position with Bolivia and Vietnam.[Note20: Transparency International, Corruption Perceptions Index 2016,] The report by the Council of Europe’s Group of States against Corruption (GRECO) notes that corruption remains an important problem for Armenian society, even though the fight against it has been high on the political agenda for years. According to the report, the judiciary in Armenia appears to be particularly prone to corruption and suffers from the deficit of independence. There are also concerns about the lack of clear separation of powers, the weakness of the Parliament and insufficient transparency in public decision-making.[Note21: Council of Europe urges Armenia to step up corruption prevention among parliamentarians, judges and prosecutors, 25.02.2016,] In the Global Corruption Barometer 2016 Survey, 24 percent of Armenian respondents said they had paid a bribe to at least one of the eight services mentioned. At the same time, 63 percent of respondents thought that “ordinary people do not make difference in the fight against corruption”, and 77 percent stated that “reporting corruption is socially not acceptable in this country”, which represents the highest number of all 42 countries of the region.[Note22: Global Corruption Barometer 2016 Survey in Armenia,]

Amendments to the Criminal Code were approved by the government in November 2016 and adopted by the parliament in December 2016, requiring high-level officials to “reasonably substantiate” the origin of their declared assets that significantly exceed their annual legitimate income. Failure to do so would make them liable for criminal prosecution[Note23: RA law “On Amendment to the Criminal Code”, 16.12.2016,]. The amendment entered into force on 1 July 2017. Asset and income declarations of high-ranking public officials in Armenia have been published online since 2014.  In 2015, the government tightened the requirement for high-ranking officials to disclose assets and transactions by reducing the number of categories where disclosure was required only after the value passed certain thresholds. Thresholds remained for some valuable assets, for instance, where the value exceeds AMD 8 million, or for the assets and transactions of family members.[Note24: Armenia End-of-Term Report 2014-2016 – For Public Comment, ] In June 2017, a package of anti-corruption legislative amendments was adopted, establishing administrative liability for failure to submit declarations on time or for violating regulations for declarations, as well as for failure to submit full or correct information by negligence, and criminal liability for intentional non-submission of the declarations, presenting false information, or hiding the information subject to declaration. The circle of officials subject to declaring income and assets has been enlarged to include not only high-level officials, but also officials employed in senior positions.[Note25: Amendments to the RA law “On Public Service”, 09.06.2017,,] Apart from income and assets, declaration of interests will be included in the scope of high-ranking officials’ declarations from 2019. The officials will have to report whether they are founders or have at least 10 percent shares in any company, are in the managing body of a company or have membership of any non-commercial organization. In order to scrutinize income and asset declarations from more than 2,000 senior state officials and investigate possible conflicts of interest or unethical behavior, a Commission on Preventing Corruption will be formed and start functioning in 2018.[Note26: RA law “On the Commission on Preventing Corruption”, 09.06.2017,] The third OGP action plan includes a commitment to publish asset and income declarations of public officials in open data. In the framework of anti-corruption measures, a law on whistleblowing was adopted in June 2017 and will enter into force in 2018.[Note27: RA law “On Whistleblowing System”, 09.06.2017, ]

On 4 April 2016, based on the publication in (an electronic media outlet[Note28:, Mihran Poghosyan, the Armenian general who mastered the ins and outs of Panama’s offshore zone, 4 April 2016, ]), Special Investigative Service initiated a criminal case against Major General of Justice, Head of Compulsory Enforcement Mihran Poghosyan, based on Article 310 of the Criminal Code of Armenia (illegal participation in entrepreneurial activity). Mr. Poghosyan was indicated in the ‘Panama Papers’ as a shareholder of three offshore companies in Panama. In January 2017, the criminal proceedings were terminated[Note29:, Criminal proceedings on Mihran Pogosyan’s alleged offshore scandal are terminated, 24012018,]. Offshore scandals with involvement of officials are not new in Armenia, however, there is a lack of (at least publicly known) measures applied to ensure identification, penalty, and/or prevention of misuse of public funds through offshore accounts, which would increase public confidence towards relevant anti-corruption programs implemented by the government.

In April 2016, the Nagorno Karabakh conflict escalated, leading to unprecedented fighting along the contact line between Nagorno Karabagh and Azerbaijan for four days and the highest number of deaths including among civilian population since the 1994 trilateral ceasefire agreement. [Note30: Joint Statement by the Heads of Delegation of the OSCE Minsk Group Co-Chair Countries, 8 December 2016,] This “four-day war” created an upswing of national solidarity and support for army forces, at the same time generating questions related to corruption in the military and the inability of Armenian authorities to ensure security.[Note31: ] From January 2017, the government introduced a new tax for all taxpayers (about two dollars monthly) to allocate for compensation paid to the families of servicemen killed and to the servicemen seriously injured in action. A special insurance foundation was established to organize, coordinate and distribute the funds. This initiative was criticized by representatives of opposition and civil society raising further concerns on corruption issues.[Note32:, Taking Care of Soldiers: Armenia’s Government Cries Poverty; Wants to Mandate New Tax, 15 November 2016,;, Armenian Parliament Approves Army Compensation Scheme, 17 November 2016, ] To provide transparency for the foundation, the government created a website where reports on income and spending, as well as information on the foundation’s board of directors, principles of work and internal decisions are included.[Note33: Insurance Foundation for Servicemen,]

Public trust in government and public institutions remains low. The recent data from the annual Caucasus Barometer study showed that 5 percent of Armenian respondents said they fully trust, and 16 percent – somewhat trust the executive government, while 22 percent rather distrust and 36 percent fully distrust the government[Note34: Caucasus Barometer, Public Perceptions on Political, Social, and Economic issues in the South Caucasus Countries: Some findings from the CRRC 2017 data, December 2017,

Yerevan, page 15,]. Public confidence in the electoral process has been a continuous problem. A New Electoral Code was adopted in May 2016.[Note35: Armenpress, Armenian Parliament adopts Electoral Code draft, 17 May 2016, ] Discussions on the Code were participatory, allowing equal representation of authorities, political opposition and civil society in the working group.[Note36: Armenia Now, 4+4+4: Opposition seeks particular format for Electoral Code debate, 23 March 2016, ] Some of the changes welcomed by civil society were the publication of signed voter lists and the partial removal of limitations on observer and journalist access at polling stations. Despite some of the positive changes to the law, the parliamentary elections held in April 2017 did not contribute to increasing public confidence in the electoral process. Citizen Observer Initiative, a coalition of Armenian NGOs, recorded several violations during the pre-voting period and throughout the voting process.[Note37: PanARMENIAN.Net, Armenian elections: Citizen Observer registers 1918 violations overall, 2 April 2017, ] The Final Report of OSCE/ODIHR Election Observation Mission indicates that accuracy of the voter lists was improved and voting procedures were generally followed; however, the election campaign “was tainted by credible and widespread allegations of vote-buying, pressure on public servants including in schools and hospitals, and of intimidation of voters to vote for certain parties”[Note38: OSCE/ODIHR Election Observation Mission Final Report։ Republic of Armenia – Parliamentary Elections, 2 April 2017, page 2,].

A cabinet reshuffle took place in September 2016, and the new prime minister took office amid promises of economic reform and anti-corruption efforts. In June 2017, a new government program was introduced for 2017-2022, outlining long-term reforms in public governance and the legal system, foreign policy and defense, economic progress, and social issues.[Note39: Program of the Government of the Republic of Armenia, 2017-2022, Yerevan, June 2017, ] Changes in the cabinet have affected OGP processes, including the delay in starting the implementation of the action plan.

In November 2017, Armenia and the European Union signed a new framework agreement, dubbed the Comprehensive and Enhanced Partnership Agreement (CEPA). Among other issues, the agreement envisions clearer rules on publication of tenders and review procedures, new rules on public subsidies, more transparent public procurement, and increased attention to democracy elements such as free and fair elections and the right to fair trial. The agreement set up an independent Civil Society Platform, composed of Armenian and EU organizations, which will monitor the implementation of the agreement and make recommendations to the Armenian authorities and to the EU.[Note40: The Comprehensive & Enhanced Partnership Agreement between the European Union & Armenia (CEPA), ]

2.2 Scope of Action Plan in Relation to National Context

The themes of the third action plan prioritized by the stakeholders are mostly related to transparency issues. These include providing information and reporting on state-funded projects (Commitment 2), improvement of officials’ income declaration system (Commitment 4) and accountable licensing (Commitment 6). However, many CSOs are pessimistic about the actual impact these commitments could make due to their limited scope and/or reach.

The current action plan reflects a number of issues related to budget information, asset and income declarations of public officials, decision-making of local authorities and social service delivery. However, civil society representatives interviewed for this report note that the commitments in the third action plan are too limited in scope to address the core problems related to current government practices and spending of public funds. For example, the commitment on state grants falls short of establishing a competitive mechanism of grant provision and its scope does not include recipients of government subsidies, donations, and other types of funding. Likewise, the commitment on publication of officials’ income and assets declarations does not cover publishing information on findings and application of relevant sanctions. CSOs are skeptical that open data on declarations could have any impact unless responsible bodies initiate relevant measures to hold officials accountable for false or late declarations, or for illicit enrichment. High-ranking government officials are known to own stakes in companies which are not declared. According to journalistic investigations, often the parents of either the officials or their spouses, as well as children living separately, are registered as owners or shareholders of companies.

While corruption is pervasive, and implementation of anti-corruption legislation remains a challenge in Armenia, the action plan does not place sufficient emphasis on anti-corruption enforcement measures. As corruption concerns are largely related to public procurement and misuse of public office, the government could have included commitments on instilling transparency in procurement procedures. Likewise, more wide-reaching efforts are needed for public accountability on overall budget spending.

The action plan contains a commitment on budget spending, however, it does not capture the military sector which has been closed for public oversight. Information on army expenditure has been restricted in Armenia as a matter of national security. After the large scale ceasefire violation along the Line of Contact in April 2016, significant concerns were raised on the efficiency of spending of public funds for defense purposes. Thus, the government could address public concerns y opening up information on military spending wherever possible.

The low level of public trust hinders the effectiveness of public participation. For example, creation of the online legal drafts platform ( aimed at providing better access to information and expanding public participation was an important step forward. However, according to civil society representatives, the feedback on their comments is posted with delays, while follow-up information on the draft status is often not available. The government should take steps toward more effective usage of public participation mechanisms and pro-active organization of public consultations.

The work of law enforcement officials is another problematic area which raises concerns among local NGOs and international organizations. Non-withstanding the recent policy and tax reforms, the violent conduct of police, the negative public image of tax enforcement officials and the enrichment of officials working in compulsory enforcement bodies call for steps toward improvements and increased accountability in these structures. There is need for transparency of disciplinary measures taken toward police and other state officers for alleged ill-treatment and abusing their authorities.

Improvement is also needed in increasing the transparency and accountability of the State Commission for the Protection of Economic Competition, an independent body aimed at protection and promotion of economic competition. The problems with monopolization and lack of competition are critical issues reflected in international reports and raised by civil society. More transparency in the activities of the commission, including reporting on sanctions applied, can potentially enhance the effectiveness of its work and improve public trust in state efforts in this direction.   

The consultation process for the third action plan was extensive, including online platforms and offline meetings in several regions. The awareness-raising activities on the development and implementation of the action plan, however, need to improve further to stimulate more participation and inform the wider public.

3.1 Leadership

This subsection describes the OGP leadership and institutional context for OGP in Armenia. Table 3.1 summarizes this structure while the narrative section (below) provides additional detail.

Table 3.1: OGP Leadership

1. Structure



Is there a clearly designated Point of Contact for OGP (individual)?





Is there a single lead agency on OGP efforts?





Is the head of government leading the OGP initiative?


2. Legal Mandate



Is the government’s commitment to OGP established through an official, publicly released mandate?


Is the government’s commitment to OGP established through a legally binding mandate?


3. Continuity and Instability



Was there a change in the organization(s) leading or involved with the OGP initiatives during the action plan implementation cycle?


Was there a change in the executive leader during the duration of the OGP action plan cycle?



Armenia is a unitary state that, following constitutional changes, will transition in April 2018 from a semi-presidential to a parliamentary republic. The Staff of the Government of the Republic of Armenia acts as the administrative office for executing decisions and assignments issued by the Republic of Armenia government and the prime minister. The Staff of the Government has been the leading office responsible for Armenia’s OGP commitments. (See Table 3.1 on the leadership and mandate of OGP in Armenia). At the current time, its mandate is the organization of working group meetings and follow-up of implementation of commitments by ministries. The government allocated four staff members to oversee implementation of the action plan, however, there is no dedicated line in the government’s budget for OGP-related activities. The task force includes: a Deputy Chief of Staff, who serves as the OGP Working Group coordinator, and is responsible for convening and chairing Working Group meetings, and meeting with responsible agencies and other local and international stakeholders; and a leading specialist of the Department of Foreign Relations of Government Staff, who serves as the Government’s Point of Contact, responsible for communication with the OGP Support Unit, the Secretary of the Working Group, and the Secretary of the Sustainable Development Goals-Armenia Working Group, as well as maintaining ongoing communication with OGP stakeholders, organizing meetings, and preparing meeting minutes and information to be posted on the OGP Armenia website and Facebook page. Two other staff members include the Head of the Personnel Management Department, who was the ex-Point of Contact, and the Extractive Industries Transparency Initiative (EITI) project leader, who are both involved as Working Group members. 

The third national action plan was approved by the Protocol Decree of the Government of Armenia on 11 August 2016.[Note41: Extract from RA Government Meeting Protocol, 11082016, ] On 16 December 2016, a multi-sector working group was set up in accordance with the Prime Minister’s Decree 12-06A[Note42: Decision of RA Prime Minister N 12-06A on appointing Coordinator and Creation of Working Group, 16 December 2016, ] for the implementation of the national action plan. Section 1.3 describes the activities of the working group. (The delay between national action plan approval and formation of the new working group was due to the change of prime minister and cabinet in September 2016.) The coordinator of the third national action plan implementation, Vahe Stepanyan, was assigned along with the new working group set-up.Another change of coordinator was made after Vahe Stepanyan was promoted from Deputy Chief of Staff to Chief of Staff of the Government in June 2017; thus, his deputy, Vahe Jilavyan, took over the role of coordinating the OGP Armenia Working Group from 25 July 2017.[Note43: Decision of RA Prime Minister N 828-A on amendments to the decision of 16 December 2016 N 1206-A, , ]

The mandate of the working group has not changed since the last action plan. The composition of the group has partly changed to include state officials responsible for the implementation of the commitments under the third action plan.

The Staff of the Government has prepared a document on working group composition and meeting procedure. The draft document was discussed at the working group meeting on 30 October 2017 and finalized by the end of 2017. However, since structural changes in the government system are expected in spring 2018, it was decided to postpone the approval of the document until the new cabinet is formed.

3.2 Intragovernmental Participation

This subsection describes which government institutions were involved at various stages in OGP. The next section will describe which nongovernmental organizations were involved in OGP.

Table 3.2 Participation in OGP by Government Institutions

How did institutions participate?

Ministries, Departments, and Agencies


Judiciary (including quasi-judicial agencies)

Other (including constitutional independent or autonomous bodies)

Subnational Governments

Consult: These institutions observed or were invited to observe the action plan but may not be responsible for commitments in the action plan.

24[Note44: Ministry of International Economic Integration and Reforms, Ministry of Agriculture, Ministry of Culture, Ministry of Defense, Ministry of Diaspora, Ministry of Economy, Ministry of Education and Science, Ministry of Emergency Situations, Ministry of Energy and Natural Resources, Ministry of Finance, Ministry of Foreign Affairs, Ministry of Healthcare, Ministry of Justice, Ministry of Labor and Social Affairs, Ministry of Nature Protection, Ministry of Sport and Youth Affairs, Ministry of Territorial Administration and Development, Ministry of Transport and Communication, Ministry of Urban Development, RA Police, State Property Management Department, General Department of Civil Aviation, State Committee of the Real Estate Cadastre, State Revenue Committee]


1[Note45: General Prosecutor’s Office of the Republic of Armenia]

13[Note46: Commission on Ethics of High-Ranking Officials of the Republic of Armenia, Human Rights Defender of the Republic of Armenia, Procurement Support Center State Non-Commercial Organization (currently dissolved), National Academy of Armenia, Central Bank of Armenia, National Statistical Service of the Republic of Armenia, Central Electoral Commission of the Republic of Armenia, Public Service Regulatory Commission, National Commission on Television and Radio of the Republic of Armenia, Council of Public Television and Radio Company of Armenia, State Commission for the Protection of Economic Competition of the Republic of Armenia, Civil Service Council of the Republic of Armenia, EKENG CJSC]

1[Note47: Yerevan Municipality]

Propose: These institutions proposed commitments for inclusion in the action plan.

13[Note48: Ministry of Finances, Ministry of Economy, Ministry of Defense, Ministry of Labor and Social Affairs, Ministry of Emergency Situations, Ministry of Justice, Ministry of Sport and Youth Affairs, Ministry of Culture, Ministry of Education and Science, Ministry of Nature Protection, Ministry of Territorial Administration and Development, State Property Management Department, State Committee on Water Economy of the Ministry of Agriculture ]



4[Note49: Commission on Ethics of High-Ranking Officials of the Republic of Armenia, Council of Public Television and Radio Company of Armenia, Civil Service Council of the Republic of Armenia, EKENG CJSC]


Implement:  These institutions are responsible for implementing commitments in the action plan whether or not they proposed the commitments.







The Staff of the Government of Armenia sent out invitations for participation in the third action plan development to all governmental agencies and a number of independent agencies and commissions. The invitation was also sent to the State Prosecutor’s office and Yerevan Municipality.[Note50: Vahe Jilavyan, Lilia Afrikyan (Staff of the Government), interview by IRM researcher, 17 October 2017] Table 3.2 above details which institutions were involved.

Ministries and agencies who wished to participate sent their representatives to the kick-off meeting. Later they made written proposals and discussed these in person with Staff of the Government.[Note51: OGP Midterm Self-Assessment Report on the Third Action Plan of the Republic of Armenia (2016-2018),] In particular, 11 ministries and four other state agencies presented their proposal, with seven proposals eventually included in the finalized action plan.

During the implementation period, the agencies directly involved in the third action plan as responsible for commitments were participating in the OGP Armenia working group, along with the agencies involved in the framework of the second action plan.[Note52: The Working Group to coordinate the works stipulated under the action plan of the participation of Armenia in the Open Government Partnership ]

3.3 Civil Society Engagement

The timeline of the action plan development and consultation process was drafted by the Government’s OGP task force, and further presented and discussed during the February 15 extended meeting of the working group. The following day, the timeline was posted on[Note53: 2016-2018 (third) Action Plan Development Timeline, ] Further, the guidelines on the main criteria for commitments and format for submitting suggestions on commitments were published.[Note54: The government has published the guidelines for the recommendations on the third action plan, ] The call for input to the action plan was sent electronically to working group members and in hard copies to government agencies. The CSOs involved in the working group were requested to disseminate the call among their networks.[Note55: Aram Asatryan (ex-Staff of the Government), interview by IRM researcher, 8 December 2017],[Note56: OGP Midterm Self-Assessment Report on the Third Action Plan of the Republic of Armenia (2016-2018), ]

In April 2016, the Staff of the Government organized regional meetings in marzes (administrative territorial units of Armenia outside the capital) to engage regional and specialized non-governmental organizations, as well as raise awareness on the OGP initiative and development of the third action plan.[Note57: Regional meeting kick-off by the government, ] In addition, on 13 April 2016, an open call for ideas was made through an online crowdsourcing tool, developed with the support of Kolba Innovations Lab of the UN Development Programme, to engage larger groups of stakeholders.[Note58: OGP Third Action Plan: Idea Contest, ] The tool was innovative as it allowed soliciting ideas for the action plan directly from citizens. As a result, by the end of April, 18 recommendations were submitted by citizens using this tool.[Note59: Marina Mkhitaryan, Aram Asatryan: Beggars and Netizens: Crowdsourcing policy-making in Armenia, 02.08.2016, ]

More than 70 recommendations were received in writing, including 39 recommendations from state agencies, 22 from CSOs and 18 from individuals. These submissions were discussed in several stages. First, the Staff of the Government selected suggestions deemed to be within the framework of the announced guidelines. Then, meetings with the authors of these recommendations and the representatives of relevant government agencies were organized to discuss further details and feasibility. The recommendations of agencies were also discussed separately.[Note60: Aram Asatryan (ex-Staff of the Government), interview by IRM researcher, 8 December 2017],[Note61: OGP Midterm Self-Assessment Report on the Third Action Plan of the Republic of Armenia (2016-2018),]

On 11–12 June 2016, the working group held a workshop on the third action plan in Aghveran, a mountain resort outside the capital, with the support of the UNDP. Besides the working group members, representatives of other local and international organizations and government agencies were invited to participate. Participants included those who provided suggestions on commitments deemed by the government’s task force as fitting into the framework of pre-announced requirements. The participants were divided into two sub-groups (representing civil society and state bodies) to discuss and shortlist the recommendations. The two shortlists were then compared, and the recommendations in both lists were adopted. The recommendations included in one shortlist only were also discussed, and some of them were eventually added to the consolidated shortlist.[Note62: Vahe Jilavyan, Lilia Afrikyan (Staff of the Government), interview by IRM researcher, 17 October 2017] Overall, eight commitments out of 70 recommendations presented were included in the third action plan. Though the final draft was prepared by the Staff of the Government, the voice of civil society was heard and during the workshop in Aghveran CSOs could put a veto on a commitment they did not want to include,[Note63: Marina Mkhitaryan (UNDP Kolba Lab), interview by IRM researcher, 8 November 2017] as well as propose modifications of the commitments in the shortlist.

The final version of the draft action plan was posted on website for public comments on 18 July 2016. Three days were provided for comments; however, no comments were received in this period.[Note64: The draft OGP third action plan Armenia, ] The summary of recommendations with feedback on their adoption, or reasons for rejection, was posted on the Government’s official website[Note65: Summary of recommendations presented for OGP Armenia third Action Plan, ] along with the final version of the third action plan.

Civil society representatives highlight that compared to the second action plan, the input of CSOs in the third action plan was less significant. Unlike the second action plan development process, where several CSOs organized discussions and collected suggestions from the CSO community in the framework of donor-funded projects, CSOs did not take any initiative and/or leadership role in the third action plan development process. According to a CSO representative, the quality of the input from public and CSOs was affected by the limited involvement and awareness-raising activities by CSOs at local level.[Note66: Tamara Abrahamyan (Araza NGO), interview by IRM researcher, 7 December 2017] Seven of eight commitments included in the final draft of the action plan were provided by governmental agencies, with some of them reflecting adjusted and/or combined versions of recommendations originally provided by CSOs, and one commitment (commitment 3) was based on the recommendation provided by a CSO representative. As a result, CSOs did not take ownership of the commitments, which further impacted their level participation in the implementation process.

Many stakeholders, and particularly representatives of government and international organizations, state that the development process of the third action plan was largely participatory and allowed inclusion of a diversity of views. However, several CSOs, including OGP Armenia Working Group member CSOs, working in the areas of human rights, good governance and access to information, are not satisfied with the content of the action plan and the possibilities for input. They mention that the limitations set did not allow inclusion of more ambitious commitments. Apart from the OGP framework, the limitations included budget constraints, exclusion of legislative initiatives justified by the scope of the government jurisdiction, and exclusion of anti-corruption measures which were to be covered by the Anti-Corruption Strategy (such as, for example, transparency in public procurement, verification of beneficial ownership, and declaration of foreign assets by public officials). It may be therefore concluded that the consultation process was extensive in scope and provided multiple channels of communication but the final incorporation of suggestions from civil society and the public was limited.

Countries participating in OGP follow a set of requirements for consultation during development, implementation, and review of their OGP action plan. Table 3.3 summarizes the performance of Armenia during the 2016-2018 action plan.

Table 3.3: National OGP Process

Key Steps Followed:  6 of 7


1. Timeline Process & Availability

2. Advance Notice

Timeline and process available online prior to consultation



Advance notice of consultation





3. Awareness Raising

4. Multiple Channels

Government carried out awareness-raising activities



4a. Online consultations:     





4b. In-person consultations:




5. Documentation & Feedback

Summary of comments provided





6. Regular Multi-stakeholder Forum

6a. Did a forum exist?



6b. Did it meet regularly?          






7. Government Self-Assessment Report

7a. Annual self-assessment report published?        



7b. Report available in English and administrative language?





7c. Two-week public comment period on report?



7d. Report responds to key IRM recommendations?







Table 3.4: Level of Public Influence

The IRM has adapted the International Association for Public Participation (IAP2) “Spectrum of Participation” to apply to OGP.[Note67: IAP2’s Public Participation Spectrum, ] This spectrum shows the potential level of public influence on the contents of the action plan. In the spirit of OGP, most countries should aspire for “collaborative.”


Level of public influence
During development of action plan
During implementation of action plan

The government handed decision-making power to members of the public.




There was iterative dialogue AND the public helped set the agenda.




The government gave feedback on how public inputs were considered.



The public could give inputs.



The government provided the public with information on the action plan.



No Consultation

No consultation



3.4 Consultation During Implementation

As part of their participation in OGP, governments commit to identify a forum to enable regular multi-stakeholder consultation on OGP implementation. This can be an existing entity or a new one. This section summarizes that information.

As noted in 3.1, the multi-sector working group for the third action plan was approved by the Prime Minister in December 2016.[Note68: Decree of the Prime Minister of Armenia No 1206-A, 16.12.2016, ] The delay in an official decision on working group composition was due to the Prime Minister’s resignation in September 2016 and subsequent change of cabinet. The group consists of 26 members, including 15 representatives from government staff and ministries, 10 from civil society and one private sector representative. Most of the members were involved in the last working group, while two members representing NGOs, one private sector representative, and representatives of two more ministries were additionally involved on the basis of their engagement in the implementation of commitments in the third action plan. Involvement in the working group is open to CSOs by application. There was no open call for applications nor an explicit announcement about the opportunity of involvement in the group. Organizations active in discussions of action plan development and working in the areas of the finalized action plan were suggested by the current WG members, and some of them eventually did become involved. The NGOs represented in the working group are active mostly in the areas of human rights, anti-corruption, social policy, and freedom of information. Two members of the working group are leaders of regional NGOs, while others are Yerevan-based organizations’ representatives. The gender balance is equal among NGO representatives, while five of 15 government representatives are female, which is generally a better reflection of gender balance in government’s higher-level staff.[Note69: According to “Armenia: Country Gender Assessment” by Asian Development Bank, 2015, women represent 13.7 percent of higher civil servant staff in Armenia (, page 35).]

The working group does not have any internal procedures or regular meetings. The OGP coordinator in the Staff of the Government convenes the meeting and the Government Point of Contact sends out invitations to members along with the draft agenda, which is open to suggestions. The meeting is chaired by the OGP coordinator, and minutes are prepared by the point of contact, which are then sent to WG members for comments. During the meeting, the responsible agencies for the commitments present the status of implementation and answer questions from WG members. The agenda may include planning of the next action plan development, setting internal rules of procedure, and other current issues related to the action plan and WG procedures. During the third action plan implementation, by the time of writing this report, working group meetings were held on 16 November 2016, 16 May 2017, and 30 October 2017, which cannot be considered regular given that the OGP Guidance Note recommends one meeting every two months. Generally, the meetings are open to observers, however, since the meetings are held at the government’s premises, an advance request on participation is needed for entrance into the building. In practice, there was no such request received by the Staff of the Government. The notice of the meeting is sent to the working group members and information about the meeting is not publicly available in advance. Representatives of international organizations are also invited to participate in meetings as observers.[Note70: Vahe Jilavyan, Lilia Afrikyan (Staff of the Government), interview by IRM researcher, 17 October 2017]

The minutes of the working group meetings, as a rule, are posted on the website under the ‘news’ section for public access. Comments are also allowed. The minutes include a review of the action plan commitments’ implementation, which is one of the main themes of meetings. The IRM researcher participated in the meeting of 30 October 2017, which was dedicated to the discussion of rules of procedure for the group.

Apart from the meetings, the working group communicates online to discuss issues when necessary.[Note71: Vahe Jilavyan, Lilia Afrikyan (Staff of the Government), interview by IRM researcher, 17 October 2017] However, apart from the working group meeting in May 2017, interviewed CSO representatives did not recall any online communication informing them of any commitment implementation process. Throughout the third action plan implementation, the online communication was exclusively on meeting organizational issues and development of internal rules of procedure for the group. At the same time, the Staff of the Government noted that more initiative and a proactive attitude is expected from the CSO community, and that the government is always open to discuss public concerns and receive inputs from CSOs.[Note72: Vahe Jilavyan, Lilia Afrikyan (Staff of the Government), interview by IRM researcher, 17 October 2017]  During the implementation of some of the commitments, the responsible agencies have consulted stakeholder CSOs on issues related to commitment implementation.

In addition to working group meetings, a workshop on OGP was organized on 25 January 2017 by the Freedom of Information Center NGO, titled “5-year Co-operation between the Government and the Civil Society”. During the event, the OGP initiative, main achievements and further steps were presented by the Staff of the Government and other members of the working group and discussed with civil society stakeholders.[Note73: “5-year Co-operation between the Government and the Civil Society”, ]

3.5 Self-Assessment

The OGP Articles of Governance require that participating countries publish a self-assessment report three months after the end of the first year of implementation. The self-assessment report must be made available for public comments for a two-week period. This section assesses compliance with these requirements and the quality of the report.

The government self-assessment was developed by the Staff of the Government and published on 11 September on in the administrative language for a two-week comment period.[Note74: Public consultation: Draft Self-Assessment Mid-Term Report of the Government, ] The report was also sent to working group members with a request to disseminate among stakeholders, as well as being posted on OGP’s Armenia Facebook page[Note75: Open Government Partnership/Armenia Facebook post, ], which is followed by 535 users. No comments were received during the assigned period. During the interviews and focus groups conducted by the IRM researcher, most of the CSO representatives not involved in the working group noted that they were not aware of the report.

The report includes a review of consultation efforts during action plan development and implementation and provides the status of completion of all commitments. It assesses the implementation of three commitments as complete, three as substantial, and two as limited. Evidence of the completion is provided for part of the commitments and activities, mostly as references to legal acts and relevant websites. Limited information is provided on challenges, particularly related to awareness-raising and following up commitments under previous action plans. A brief paragraph on next steps is included, with reference to the elaboration of internal procedures for the working group and plans to continue awareness-raising activities.  

3.6 Response to Previous IRM Recommendations

Table 3.5: Previous IRM Report Key Recommendations

Integrated into Next Action Plan?


The government can promote OGP through a well-designed national public awareness campaign, including the use of print media, radio and television, and targeted at a wide range of civil society stakeholders and citizens.


To reach out to a broader base of regional CSOs, government could organize meetings and have an equal distribution of consultative sessions of the OGP working group across the country.


To ensure meaningful participation in the development and implementation of the action plan, the government should prepare and present a timetable of OGP events necessary to ensure transparent and participatory development and implementation of the action plan.


The government may adopt a more holistic approach by including commitments that address more comprehensive reforms in areas such as public procurement and elections.


Ensure commitments from each iteration of the action plan are implemented within a specific timeframe to avoid excessive carry-over, or in certain cases, the loss of commitments as a result of non-implementation. In this regard the government should re-commit to fully implement the program budgeting commitment from the first action plan by 2018.


Of the five IRM recommendations, government addressed four in their self-assessment and integrated two in the action plan.

According to the self-assessment report, the recommendation for an awareness-raising campaign has been addressed throughout the third action plan development. Several regional meetings have been carried out, and a television program was filmed and broadcasted on Yerkir Media channel.[Note76: See, for example,,,, ] However, apart from including an item on awareness raising in the third action plan development timeline, no systematic outreach strategy was designed. Based on the feedback from stakeholders not involved in the working group[Note77: Focus group discussion in Yerevan, 26 October 2017], the IRM researcher finds that the campaign coverage was limited and did not reach a wide range of stakeholders.

The television program on OGP was developed by NGOs in the framework of a USAID-funded program “Media for Informed Civic Engagement”. Throughout the implementation period, in collaboration with Yerkir Media channel, the Freedom of Information Center (FOICA) produced 10-minute video stories on OGP commitments’ progress in the framework of “Civil Community for Open and Accountable Government” project funded by the U.S. Embassy[Note78: See, for example,,,] in 2016. However, no coverage on OGP was provided on public television, print media, or any radio channel. The website[Note79: OGP Armenia website, ] and Facebook page[Note80: OGP Armenia Facebook page, ] of OGP Armenia serve as the main sources of information on action plan development and implementation progress. These tools have been created under the USAID-funded program and are currently administered by FOICA on a voluntary basis.

The OGP Government Point of Contact indicated that the awareness-raising challenges are well-recognized by the task force; better television coverage and organization of regional meetings on the action plan implementation process are currently being discussed by the Staff of the Government. As to the administration of the OGP website and Facebook page by NGO representatives, the OGP task force finds this approach effective as it allows critical articles and comments to take place on these platforms.[Note81: Vahe Jilavyan, Lilia Afrikyan (Staff of the Government), interview by IRM researcher, 17 October 2017 ]

The second recommendation of the IRM report was addressed by the task force through organization of regional meetings in five regions of Armenia at the action plan development stage, which, however, did not provide equal coverage through the country, leaving out five other regions. The electronic tool for crowdsourcing ideas did, however, provide an opportunity for citizens to have their input regardless of location.

The third recommendation of the IRM report was also addressed, and the timeline of OGP events was posted on website in February 2016[Note82: 2016-2018 (third) Action Plan Development Timeline,], providing opportunities for more transparent and participatory development and implementation of the action plan. The dissemination of the information on the timeline, however, was not sufficient to engage wide groups of society.

The fourth recommendation was related to the scope of action plan commitments. The IRM researcher recommended including more comprehensive reforms related to themes such as public procurement and elections. The government’s self-assessment report indicated that these reforms have been addressed in previous action plans, for example, in relation to public procurement.[Note83: OGP Midterm Self-Assessment Report on the Third Action Plan of the Republic of Armenia (2016-2018),] According to a number of stakeholders interviewed, the commitments of the third action plan are not ambitious enough and do not sufficiently address priority areas such as anti-corruption, freedom of information, local governance reforms, etc. Many recommendations provided by CSOs were rejected with the justification that they would require legislative amendments and/or are implemented in the framework of other projects.[Note84: Summary of suggestions on the third action plan, ] Thus, the IRM researcher concludes that this recommendation was not properly reflected in the third action plan.

The fifth IRM recommendation referred to following the specific timeframe of commitments (so that they do not get lost during unavoidable delays). It was also recommended to re-commit the program budgeting commitment from the first action plan. This recommendation was not addressed in the self-assessment report. Though the third action plan indicated specific timeframes for each commitment, the current report shows that there are delays in the implementation process and that the program budgeting commitment was not included in the third action plan. Thus, this recommendation was not implemented.

A well-designed public outreach campaign is needed not only during action plan development, but also through the implementation process and follow-up of the outcomes achieved. Ambitious commitments addressing stakeholder priorities such as budget transparency, civic participation and anti-corruption measures should be included in further action plans, as well as securing appropriate human and financial resources to ensure full implementation of the commitments.

This section aims to inform development of the next action plan and guide completion of the current action plan. It is divided into two sections: 1) those civil society and government priorities identified while elaborating this report and 2) the recommendations of the IRM.

5.1 Stakeholder Priorities

The themes of the current action plan prioritized by the stakeholders are mostly related to transparency issues. These include providing information and reporting on state-funded projects (Commitment 2), improvement of officials’ income declaration system (Commitment 4) and accountable licensing (Commitment 6).

Stakeholders recommend expanding the scope of current commitments to cover the following measures:

·       Establish competitive mechanisms of grant provision and enlarge the scope of published information on state-funded projects, including recipients of subsidies, donations, and other types of funding, as well as relevant reports. The main problem behind the commitment 2 is the lack of procedures for selecting, monitoring and reporting of organizations implementing state-funded projects, and the lack of information published on these organizations and/or projects.

·       Apply measures to verify the information provided in the officials’ income and assets declaration and publish information on findings and application of subsequent sanctions. CSOs are skeptical if the open data on declarations would have any impact unless responsible bodies initiate relevant measures to hold officials accountable for false or late declarations, or for illicit enrichment.

·       Extend the scope of information included in the officials’ declarations, including sources of monetary gifts, companies where they have ownership, geographical location of the estate property, sources of loans as well as the scope of their family members subject to declaration beyond cohabitants. According to journalist investigations, often the parents of either the officials or their spouses, as well as children living separately, are registered as owners or shareholders of companies.

The stakeholder priorities for the next action plan include further anti-corruption measures, including:

·       Provide free access to information on the founders and current shareholders of companies. According to journalist investigations and CSO monitoring reports, a number of conflict of interest issues were identified related to state procurement. According to the law, information on the names of founders can be accessed free of charge from the State Registry database on website;[Note158: Article 61, RA Law on the State Registration of Legal Entities, State Accounting of the Divisions of Legal Entities, Enterprises and Individual Entrepreneurs, 03.04.2001, ] however, in fact, the information on founders of joint stock companies and non-governmental organizations is not available, as well as updated information on the current shareholders of companies. More details on a specific organization (including information on founders and current shareholders) are provided on the basis of a query sent to the State Registry and require payment of state fees.

·       Publish information on personal expenses of officials covered from the state budget, particularly related to usage of vehicles and phone communication. Recent media publications revealed substantial amounts of phone expenses by parliament members, and misuse of official cars for personal purposes is also an often-discussed issue. 

·       Publish timely information on the activities and decisions of the State Commission for the Protection of Economic Competition. Monopolization of several segments of the economy and the lack of competition in the market are critical issues raised by civil society, and accountability of these activities is a priority to be addressed.

5.2 IRM Recommendations

The awareness-raising activities and involvement of CSOs in the development of the action plan should be further enhanced as well as continued throughout the implementation process. This would provide better quality inputs in the action plan and subsequently more effective implementation. At the same time, the government should take on more ambitious commitments addressing access to information, public accountability and civic participation in further action plans.

More ambitious commitments addressing country priorities

It is recommended to take on more ambitious commitments that can transform practices in open budgeting, transparent and accountable spending, and verification of beneficial ownership and real beneficiaries of organizations. To respond to these challenges, the next action plan should include commitments that prioritize establishing competitive mechanisms for awarding grants or service contracts to non-profit organizations by executive agencies, with transparent and fair selection criteria and further accountability measures in place. Another area that would benefit from more openness is the ownership and participation of shareholders in companies published on Government could commit to provide free access to information on the founders and current shareholders of all companies in the current register.

An example of a more ambitious commitment for government spending would be to publish information on the personal expenses of officials covered by the state budget, particularly related to usage of vehicles and phone communication.

Awareness-raising on the action plan development and implementation

Although more awareness-raising activities were initiated by the government through the third action plan development process as compared to previous action plans, the quality of the inputs provided and the scope of the audience covered need improvement. The OGP Armenia website and Facebook page cover a limited number of users and are administered by a CSO, which puts the sustainability of these channels at risk. The IRM researcher recommends implementing the following activities in relation to awareness raising:

·       Utilize more resources and channels for raising awareness on the concept of OGP in general, and action plan development and implementation processes in particular.

·       Actively engage CSOs in both consultation and implementation processes through their available resources or by allocating additional resources from government and donor funds. Broaden the coverage to regional stakeholders and clearly formulate the OGP messages through the consultations on action plan development.

·       Organize large awareness-raising campaigns on the outcomes of the current and previous action plans. To this end, the government might consider using the “Hraparakum” program on public television which covers the activities and programs of government.[Note159: “Hraparakum” TV series, ] Government could prepare and use video PSAs presenting accessible information on OGP aimed both at soliciting suggestions in the development process and ensuring usage of the outputs after commitment completion.

·       Take ownership of the OGP Armenia website and Facebook page through securing the website costs from the state budget and allocating staff for administration and maintenance.

·       Promote successful results of commitments in the international arena.

CSO participation in OGP processes

The multi-stakeholder working group, established in the framework of OGP initiatives, serves as an effective platform for exchange of information, discussion, and dialogue among stakeholders. The regularity of working group meetings should be improved and transparent mechanisms on the procedures of participation designed, along with the internal procedures of meetings. The development of internal procedures is currently under way, and it is recommended to make them public upon approval.

CSOs are concerned with the lack of collaboration and consultations through the implementation period. Though all the commitments in the third action plan indicated CSOs among stakeholders, involvement in the implementation process was minimal. On one hand, responsible agencies often did not communicate with involved CSOs, and on the other hand, there was a lack of initiative on the part of CSOs. Several CSO stakeholders explain their limited involvement with a lack of trust and motivation, a result of disappointment with the outcomes of the last action plan and a lack of transformational commitments in the current plan. However, as noted by the stakeholders and pointed out in the IRM Progress Report Armenia 2014-15[Note160: Armenia: IRM Progress Report for 2014-2015, ], the commitments are most successful if a CSO is involved as a stakeholder in the implementation or monitoring process. It is therefore recommended that the government take proactive steps to address these concerns and involve stakeholder CSOs in the implementation process, including ongoing consultation on outputs, challenges, and more effective implementation of specific commitments.

Quality of the action plan

The limitations set by the government have meant that only executive lead commitments have been prioritized, limiting the scope and ambition of the action plan. This approach does not allow for addressing many issues of concern presented by civil society.

The OGP action plan should be treated as a national action plan which includes all branches of government as well as civil society. Several countries have incorporated legislative amendments in their OGP action plans to address issues that reflect country priorities. For example, in the Ukraine’s third action plan, a number of commitments entailing legislative amendments are included, such as development of legal amendments or new drafts on urban planning documentation, disclosure of information in extractive industries, and public consultations.[Note161: Ukraine Third  National Action Plan, 2016-2018, ]

The Armenian government needs to consider involvement of stakeholders from Parliament in the development in order to remove the limitation on commitments requiring legislative amendments. The current action plan, in fact, includes commitments that go beyond the executive branch. For example, commitment 4 pertains to an independent commission that is not subordinate to the government but still committed to the implementation.

Budget limitations were another factor for the selection of commitments though not explicitly mentioned in the summary of proposals as a reason for proposal rejection. In some cases, the budgeting issue was mentioned by responsible institutions as a reason for delay and/or limited implementation of commitments. However, CSOs consider that the government is able to, and must, allocate necessary budget resources in order to implement all the commitments in an optimally efficient manner. Resources can be allocated also in the framework of large donor programs aimed at the improvement of public administration. It is recommended to estimate the commitment budget and consider possible sources of funding for implementation and further maintenance of outputs before incorporating the commitment into the action plan. Synergy with relevant projects of CSOs/international organizations with secured funding might also be a solution (as was the case with the second action plan).

Publication of the summary of proposals provided throughout the action plan development process is a valuable step forward. However, the explanations for the rejection of specific proposals are general and vague. Therefore, it is recommended to provide detailed explanations of rejection for each proposal individually to provide better accountability and increased trust in the process.

Impact assessment and sustainability

Sustainability of achievements in the framework of the OGP plan is another issue of concern. The functionality and usability of the platforms created should be ensured. The lack of awareness on numerous sources of information is emphasized by many stakeholders, while platforms created through OGP commitments are not always functional. For example, the Health Financing Portal established in the framework of the second action plan is currently not available. The relevant financial and human resources need to be secured for sustainability of OGP commitment outcomes. Creation of an inventory of open data sources and organization of outreach campaigns to ensure usage of these sources is another activity recommended for sustaining results and reaching the intended impacts of the commitments.

Based on CSOs’ suggestions, it is recommended to conduct evaluation and impact assessment of commitments implemented in the framework of not only the current, but also previous action plans. This would help to identify the actual impact and gaps that can be reflected in further undertakings of the government and civil society, including through future action plans. This activity might also be useful in increasing the visibility of the OGP initiative and thus improve public trust in its effectiveness.

Table 5.1: Five Key Recommendations


Utilize more resources and wide-coverage channels for raising awareness of the OGP concept, process of action plan development and implementation, as well as on the results achieved, including through video PSAs and other communication tools.


Coordinate with the Parliament to include more ambitious commitments that require legislative action in areas of access to information, public accountability, and participation.


Expand the scope of budget-related commitments focusing on the transparency of government spending and increase public participation in the budget development process. Establish competitive and transparent mechanisms for awarding state grants and service contracts by executive agencies.


Include more ambitious commitments that address anti-corruption issues, e.g. providing free access to information on the founders and current shareholders of companies.


Conduct evaluation and impact assessment of implemented commitments to identify the actual impact and gaps that can be reflected in further activities of the government and civil society, including through future action plans.

The IRM progress report is written by researchers based in each OGP-participating country. All IRM reports undergo a process of quality control to ensure that the highest standards of research and due diligence have been applied.

Analysis of progress on OGP action plans is a combination of interviews, desk research, and feedback from nongovernmental stakeholder meetings. The IRM report builds on the findings of the government’s own self-assessment report and any other assessments of progress put out by civil society, the private sector, or international organizations.

Each IRM researcher carries out stakeholder meetings to ensure an accurate portrayal of events. Given budgetary and calendar constraints, the IRM cannot consult all interested or affected parties. Consequently, the IRM strives for methodological transparency and therefore, where possible, makes public the process of stakeholder engagement in research (detailed later in this section.) Some contexts require anonymity of interviewees and the IRM reviews the right to remove personal identifying information of these participants. Due to the necessary limitations of the method, the IRM strongly encourages commentary on public drafts of each report.

Each report undergoes a four-step review and quality-control process:

1.     Staff review: IRM staff reviews the report for grammar, readability, content, and adherence to IRM methodology.

2.     International Experts Panel (IEP) review: IEP reviews the content of the report for rigorous evidence to support findings, evaluates the extent to which the action plan applies OGP values, and provides technical recommendations for improving the implementation of commitments and realization of OGP values through the action plan as a whole. (See below for IEP membership.)

3.     Prepublication review: Government and select civil society organizations are invited to provide comments on content of the draft IRM report.

4.     Public comment period: The public is invited to provide comments on the content of the draft IRM report.

This review process, including the procedure for incorporating comments received, is outlined in greater detail in Section III of the Procedures Manual.[Note162:  IRM Procedures Manual, V.3 : ]

Interviews and Focus Groups

Each IRM researcher is required to hold at least one public information-gathering event. Researchers should make a genuine effort to invite stakeholders outside of the “usual suspects” list of invitees already participating in existing processes. Supplementary means may be needed to gather the inputs of stakeholders in a more meaningful way (e.g., online surveys, written responses, follow-up interviews). Additionally, researchers perform specific interviews with responsible agencies when the commitments require more information than is provided in the self-assessment or is accessible online.

For interview purposes, the IRM researcher has contacted all agencies and organizations indicated in the action plan as responsible or involved stakeholders representing governmental agencies and CSOs. In addition, other organizations involved in the working group and representatives of the media were interviewed on OGP development and implementation processes and/or specific commitments.

In total, 27 in-person interviews, nine telephone interviews and two focus group discussions were conducted by the IRM researcher in Yerevan, Dilijan, and Gyumri through October-December 2017.

For each focus group discussion, 35–40 participants were invited. The following criteria of selecting the invitees of focus group discussion were taken into consideration:

·       organizations both experienced and previously not involved in the OGP processes,

·       organizations working in thematic areas relevant to OGP in general and the third action plan in particular, including good governance and accountability, budget transparency, local government, and social services.

The IRM researcher attended an Open Space forum organized by “NGO Center” Civil Society Development NGO on 27-28 October 2017, where issues under a headline topic of inter-sectoral collaboration were discussed, and participated in a small group discussion on CSO-government collaboration challenges in the framework of the OGP initiative. On 30 October 2017, the IRM researcher attended the meeting of the OGP Armenia Working Group.

About the Independent Reporting Mechanism

The IRM is a key means by which government, civil society, and the private sector can track government development and implementation of OGP action plans on an annual basis. The design of research and quality control of such reports is carried out by the International Experts Panel, comprised of experts in transparency, participation, accountability, and social science research methods.

The current membership of the International Experts Panel is

·       César Cruz-Rubio

·       Hazel Feigenblatt

·       Mary Francoli

·       Brendan Halloran

·       Hille Hinsberg

·       Anuradha Joshi

·       Jeff Lovitt

·       Fredline M’Cormack-Hale

·       Showers Mawowa

·       Ernesto Velasco

A small staff based in Washington, DC, shepherds reports through the IRM process in close coordination with the researchers. Questions and comments about this report can be directed to the staff at


Filed under: IRM Report


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