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Beneficial Ownership Register (AM0037)



Action Plan: Armenia Action Plan 2018-2020

Action Plan Cycle: 2018

Status: Active


Lead Institution: Ministry of Justice

Support Institution(s): State administration bodies FOICA, Transparency International, Armenian Lawyers' Association

Policy Areas

Anti-Corruption Institutions, Beneficial Ownership, E-Government, Extractive Industries, Legislation & Regulation, Open Data

IRM Review

IRM Report: Armenia Design Report 2018-2020

Starred: Pending IRM Review

Early Results: Pending IRM Review

Design i

Verifiable: Yes

Relevant to OGP Values: Access to Information Civic Participation , Technology

Potential Impact:

Implementation i



3. Open and public beneficial ownerships’ register
Commitment Start and End Date Commitment Start: November 2018
Commitment End: December 2020
Lead implementing agency Ministry of Justice
Person responsible from lead implementing agency Mariam Galstyan
Title, Department Head of Anti-Corruption Policy Development Division of Anti-Corruption and Penitentiary Policy Development Department

Email: Phone +37410-594023
Other actors involved Other state actors involved State administration bodies
Civil society, private sector FOICA, Transparency International, Armenian Lawyers' Association
Issues subject to regulation Although the legislation in the Republic of Armenia (RA) prohibits public officials to be engaged in business activities, the lack of information about the ultimate beneficial owners of legal entities may actually enable the violation of this requirement and contribute to the spread of corruption.

After the Velvet revolution in the spring of 2018 the new government launched a real and effective fight against corruption and the disclosure of information about property owners can significantly contribute to the realisation of the government’s ambitions. With this commitment the government will adopt international beneficial ownership transparency standards and will monitor abuses of company ownership for illegal purposes. Taking into account the open will of the new government to eliminate corruption in all spheres, government of RA pledged to ensure the publicity of data on the real owners of companies operating in the country.

Main objective The main objective of the commitment is to open information on companies’ real owners to prevent and identify the misuse of company ownership for corruption offenses.

The publication of information of companies’ real owners will also support tax and law agencies to enforce the laws and regulations more effectively and carry out their functions and activities. The transparency of such information will promote the engagement of citizens in the fight against corruption and can increase trust in government. At the same time, it can have a positive effect in increasing investments in the Republic of Armenia.

Brief Description of Commitment The Government is committed to develop and implement a common mechanism for identifying the real owners of companies operating in RA, by creating and launching a comprehensive open and freely accessible register of beneficial ownership.

OGP challenge addressed by the commitment Publicity, accountability, enhancement of public integrity, innovation

Relevance to OGP values The Register will provide access to actual owners’ information, increase public confidence, increase transparency and public control, and thereby improve the accountability of companies.

Ambition The commitment is exclusive for Armenia and other OGP member countries. Armenia will have an effective tool for Civil society and the State agencies to determine the ultimate beneficial owners in all sectors of the economy operating in RA. This commitment is a comprehensive and inclusive program, which will lead to positive changes including a huge impact on the fight against corruption and money laundering. By doing so, Armenia will join the group of pioneer countries in the field of Beneficial ownership transparency.
Promotes efforts for implementation of SDG Goals or Targets 16.5 Substantially reduce corruption and bribery in all their forms.
17.17 encourage and promote effective public, public- private, and civil society partnerships, building on the experience and resourcing strategies of partnerships.
Verifiable and measurable criteria for performance of commitment Start End
Ongoing Actions
1. Development of a legislative package that establishes the framework necessary to meaningfully advance on beneficial ownership transparency and implement an open register of ultimate beneficial owners.
This legislative package will be based on a comprehensive analysis of international experiences on issues such as the Beneficial Ownership Data Standard, the definition of beneficial owners, verification and registration mechanisms, and the range of required documentation.
In addition, the development of the legislative package will include consultations with stakeholders, such as representatives of civil society and the private sector, and the presentation of a consolidated package to the Prime Minister’s Staff.
November 2019
2. Presentation of legislative drafts package to the National Assembly
July 2019
3.Development of a database (using the Beneficial Ownership Data Standard) of ultimate beneficial owners of all companies operating in Armenia within the State Registry which will be responsible of the technical implementation and discussions with civil society and the private sectors. The database will be open and freely accessible to the public and ensure adequate use and search capabilities.
May 2019
4. Piloting the register by entering data of ultimate beneficial owners of companies in the metal mining industry operating in Armenia. This includes collecting, verifying, publishing, and resolving system problems which are encountered during the pilot.
November 2020
5. Launch of an open and public register of ultimate beneficial owners and parallel launch of a public awareness campaign.
October 2020


  1. Open Data in Official Declarations

    AM0035, 2018, Asset Disclosure

  2. Government Grant Transparency

    AM0036, 2018, Fiscal Transparency

  3. Beneficial Ownership Register

    AM0037, 2018, Anti-Corruption Institutions

  4. Modernization of Community Website

    AM0038, 2018, E-Government

  5. State Water Cadastre

    AM0039, 2018, E-Government

  6. Land Cadastre

    AM0040, 2018, E-Government

  7. Integrated Social Services

    AM0041, 2018, E-Government

  8. Unified Information System for Management of Education

    AM0042, 2018, Capacity Building

  9. Exploring Medical Assistance Program

    AM0043, 2018, E-Government

  10. Platform for Submitting Petitions

    AM0044, 2018, E-Government

  11. Public Service Dashboard

    AM0045, 2018, E-Government

  12. State Travel Transparency

    AM0027, 2016, E-Government

  13. Accountability for Grants of the Government

    AM0028, 2016, E-Government

  14. Transparency of the State Budget

    AM0029, 2016, Fiscal Transparency

  15. "Open Data" in Official Declaration:

    AM0030, 2016, Anti-Corruption Institutions

  16. Portal for Community Decisions.

    AM0031, 2016, Capacity Building

  17. Accountability Licensing

    AM0032, 2016, Capacity Building

  18. Accessibility of Integrated Social Services

    AM0033, 2016, E-Government

  19. "One-Stop-Shop" Pilot Project Within Military Registration Offices

    AM0034, 2016, Capacity Building

  20. Digitization and publication of data in the “Republican Geological Fund” SNCO

    AM0016, 2014, Extractive Industries

  21. Ensuring Transparency in Mining

    AM0017, 2014, Extractive Industries

  22. Ensuring Public Awareness About Health Care Financing

    AM0018, 2014, E-Government

  23. Ensuring Transparency of Asset and Income Declarations of the RA High-Ranking Officials

    AM0019, 2014, Asset Disclosure

  24. Online Broadcasting of the State Procurement Appeals Board Sessions

    AM0020, 2014, E-Government

  25. Community Microsurvey Introduction in 10 Communities

    AM0021, 2014, E-Government

  26. Ensuring Open, Transparent, Participatory and Accountable Process of State Policies and Legislative Reforms

    AM0022, 2014, E-Government

  27. Public Awareness on the Lawmaking Activity of State Governance Bodies

    AM0023, 2014, E-Government

  28. Ensuring Transparency of the Election of Governing Boards of the RA General Secondary Education Institutions and of the Annual Budget Planning and Expenses of Ra General Secondary Education Institutions

    AM0024, 2014, Education

  29. Knowledge and Capacity Building of Public Servants in the Freedom of Information and Anticorruption Field

    AM0025, 2014, Capacity Building

  30. Ensuring Transparency of Local Self Government Bodies of Large Communities

    AM0026, 2014, E-Government

  31. Reviewing the Regulatory Normative Legal Acts (Regulatory Guillotine Project)

    AM0001, 2012, Legislation & Regulation

  32. Improving Internal Audit System for the Public Sector

    AM0002, 2012, Audits and Controls

  33. Improving Procurement Procedures

    AM0003, 2012, Capacity Building

  34. Improving Budget Planning and Reporting Systems Through Full Utilization of Program Budgeting

    AM0004, 2012, Audits and Controls

  35. Promoting Transparency and Objectiveness in Tax Administration

    AM0005, 2012, Conflicts of Interest

  36. Fight Against Corruption

    AM0006, 2012, Anti-Corruption Institutions

  37. Introduction of a Unified Payment System (Portal)

    AM0007, 2012, E-Government

  38. State Car Inspection Improvements

    AM0008, 2012, Infrastructure & Transport

  39. Implementation of an Electronic System for Consular Services

    AM0009, 2012, Citizenship and Immigration

  40. Implementation of Mail-Armenia System

    AM0010, 2012, Citizenship and Immigration

  41. Introduction of e-Statistics System

    AM0011, 2012, E-Government

  42. Introduction of e-Documentation Sharing System in Urban Communities

    AM0012, 2012, E-Government

  43. Ensuring Transparency of Asset Declarations

    AM0013, 2012, Asset Disclosure

  44. Standardization of Offical Websites Content

    AM0014, 2012, E-Government

  45. Improvement of Knowledge and Skills of Public Servants on Access to Information

    AM0015, 2012, Capacity Building