At a glance
- Law HO-310-N has been in force since 26 July 2026. One provision, Article 6, is deferred to 1 January 2027.
- Account holders and controlling persons can now be fined AMD 500,000 (about USD 1,270) personally for a self-certification that is missing, false or incomplete, under Tax Code Article 402.3(6).
- The statute applies the fine per occurrence. It does not cap the total for a reporting period.
- The relief for correcting an error before proceedings conclude, in Article 402.3(8), is written for financial institutions. The statute provides no equivalent for the individual who signed the form.
- Armenia’s first CRS exchange took place in September 2025 and covered 47 partner jurisdictions.
A missing, false or incomplete CRS self-certification now costs the person who signed it AMD 500,000, roughly USD 1,270, under Tax Code Article 402.3(6) as rewritten by HO-310-N. The document in question is the short tax-residence declaration your Armenian bank put in front of you at account opening, usually alongside twenty other pages. Until 26 July 2026 an error on it was the bank’s compliance problem; the law has now attached a personal penalty to it.
What HO-310-N changed
HO-310-N was adopted on 3 July 2026, published on 16 July 2026 and took general effect ten days later, on 26 July 2026. Article 9(1) of the law defers one of its articles, Article 6, to 1 January 2027, so that provision has no operation before that date.
The law rewrites Chapter 80.2 of the Tax Code, which governs the automatic exchange of financial account information. Chapter 80.2 previously addressed itself to banks and other reporting financial institutions: they collected self-certifications, ran due diligence, and carried the consequences of getting it wrong. HO-310-N keeps all of that and adds a paragraph, Article 402.3(6), that reaches past the institution to the account holder and, for entity accounts, to each controlling person.
The AMD 500,000 personal fine: who is exposed
Article 402.3(6) sets a fine of AMD 500,000 (about USD 1,270 at 395 AMD to the dollar) on an account holder or controlling person in three situations: failing to provide a self-certification at all, providing one that contains false information, and providing one that is incomplete.
The Armenian text applies the fine to “each occurrence” (յուրաքանչյուր դեպքի). A person holding four accounts at three banks has signed several self-certifications and each one stands on its own. Where the statute stops short is the internal arithmetic: it does not say whether several inaccurate fields on a single form count as one occurrence or as several, and it sets no ceiling for a reporting period. Requirements in this area are unsettled until the tax authority publishes practice or a court rules on it.
Controlling persons sign their own form
If an Armenian company, foundation or trust holds the account and CRS classifies it as a passive entity, the bank must look through the entity to the individuals who ultimately own or control it. Those individuals give a self-certification of their own, separate from the entity’s, covering their personal tax residence and TIN. Article 402.3(6) applies to them directly, so a shareholder who never signed the account-opening pack but appears on the controlling-person schedule carries the same AMD 500,000 exposure. Anyone who owns or directs an Armenian entity through a registered Armenian company structure should confirm which of these forms exists in their name.
There is no cure provision for individuals
Article 402.3(8) disapplies the fine where the violation is remedied before the liability proceeding concludes, or where it is technical in nature. That paragraph is drafted for financial institutions. Article 402.3(9) adds a separate discretionary route through the State Revenue Committee and the Central Bank for a party in severe financial condition. Neither text gives the account holder an equivalent right to escape Article 402.3(6) by fixing the form after the fact, which makes the timing of a correction a matter of getting ahead of the bank’s next due-diligence cycle.
What the self-certification actually asks
For an individual the form captures your full name, residential address, date and place of birth, every jurisdiction in which you are tax resident, and the taxpayer identification number issued by each of them. For an entity it adds the CRS classification, active non-financial entity, passive non-financial entity, or financial institution, plus the controlling-person schedule where the classification is passive.
Five patterns account for most defective forms in CRS practice:
- Declaring a single tax residence while the bank’s file holds a foreign address, a foreign mobile number or a standing instruction to a foreign account, none of which is explained.
- Omitting a second tax residence, which is common for people who moved mid-year and remain resident in the country they left under its own day-count or centre-of-interests test.
- Leaving a TIN blank, or entering one in the wrong format, where the jurisdiction of residence issues them.
- Classifying a holding company as an active non-financial entity when most of its income is dividends, interest or rent, which makes it passive and triggers the controlling-person schedule.
- A mismatch between the form and the identity documents on file, typically a passport from one country and a declared residence in another with nothing tying the two together.
A self-certification describes your position on the day you signed it. Relocations, new passports, a company reorganisation and changes in a jurisdiction’s residence rules all break the match between the form and the facts, and it is the form on file at the bank that Article 402.3(6) measures.
Which accounts are reported
Armenia signed the CRS Multilateral Competent Authority Agreement on 12 January 2024, and the reporting reference period opened on 1 January 2024. The first live exchange happened in September 2025 and covered 47 partner jurisdictions. The figure of roughly 120 jurisdictions that circulates in older coverage describes the wider CRS network Armenia can eventually reach, and the 2025 cycle ran with 47.
Accounts opened before 1 January 2024 are pre-existing accounts and were subject to a reporting threshold of USD 250,000 or the equivalent in AMD or another currency, under paragraph 6(2) of Joint Order N 542-N. HO-310-N removed that blanket threshold from the Tax Code and directs a new joint due-diligence procedure from the State Revenue Committee and the Central Bank, which had not been published as of 11 August 2026. Joint Order N 542-N remains formally in force in the meantime, so the threshold applying to pre-existing accounts from the next cycle onward is unsettled.
CRS reporting turns on tax residence. Accounts of people resident outside Armenia are collected by the Armenian tax authority and passed to their jurisdiction of residence. FATCA runs on a separate track and turns on US person status, applying regardless of where you are tax resident: Armenia has had a Model II intergovernmental agreement with the United States since February 2018, banks request a W-9 or W-8BEN, and US persons carry their own FBAR filing obligation once aggregate foreign account balances pass USD 10,000. Our FATCA and CRS reporting overview sets out how the two regimes operate on the bank’s side; this page covers the personal fine that HO-310-N added on top of them.
What the banks now have to do
Reporting financial institutions file their CRS data electronically by 30 June each year under Article 443.4(1) and (2), including a NIL return in years when they identify no reportable accounts. The next annual deadline under the revised provision is 30 June 2027. Notices and tax alerts published before HO-310-N cite 10 May, which was the previous rule and has been superseded. Institutions must keep the underlying records for at least five years under Article 443.5, and the State Revenue Committee has a dedicated thematic audit for financial-account compliance accuracy under Article 335(3)(10), with the audit order presented three working days before the audit begins under Article 339(4)(1).
Article 402.3 sets the institution-side penalties:
| Provision | Failure | Fine |
|---|---|---|
| Art. 402.3(1) | Due diligence or record retention, per account holder | AMD 1,000,000 (about USD 2,530) |
| Art. 402.3(2) | Reporting item omitted, plus a further amount if still not provided 30 days after the penalty | AMD 500,000, then AMD 1,000,000 |
| Art. 402.3(3) | Reporting item filed late | AMD 250,000 (about USD 630) |
| Art. 402.3(4) | Reporting item false or incomplete | AMD 1,000,000 |
| Art. 402.3(5) | Self-certification obtained for due diligence is false or incomplete | AMD 500,000 |
| Art. 402.3(6) | Account holder or controlling person: self-certification missing, false or incomplete | AMD 500,000 (about USD 1,270) |
One inaccurate self-certification can therefore engage paragraph 4, paragraph 5 and paragraph 6 at the same time, two of them against the bank and one against you. Whether the tax authority may apply them cumulatively on a single form is not resolved by the statute. In practice this gives your bank a direct financial reason to re-paper an account whose file looks inconsistent, which is why account holders are hearing from compliance departments now rather than in 2027. Anyone maintaining accounts through the Armenian banking system should expect those requests to become routine.
Secondary legislation still pending
HO-310-N mandates several implementing acts and gives the authorities deadlines running from commencement on 26 July 2026. The list of nonreporting institutions, the list of exempt accounts and the new due-diligence procedure are due within two months, by 26 September 2026. The NIL-return form and the rules for transferring information between government bodies are due within three months, by 26 October 2026. The principal reporting form and its format are due within six months, by 26 January 2027.
None of these had been confirmed published as of 11 August 2026, and none of the deadlines has expired. The pre-HO-310-N acts, including Joint Order N 542-N, remain nominally in force until they are replaced. The self-certification obligation and the AMD 500,000 fine operate now regardless, because Article 402.3(6) took effect with the rest of the law on 26 July 2026 and does not depend on any of the pending acts.
Frequently asked questions
Does this apply to an account I opened before 2026?
What counts as a controlling person?
Can I avoid the fine by correcting the form later?
I am tax resident in Armenia only. Am I exposed?
What if I am tax resident in two countries?
Is the fine charged once a year or once per form?
Does the AMD 500,000 fine apply to FATCA forms as well?
Is a small balance below the reporting threshold safe?
What to check on your own file
- Ask each Armenian bank for a copy of the self-certification it holds for every account in your name. Banks retain these for at least five years under Article 443.5, so the document exists.
- Check the declared jurisdictions of tax residence and the TIN recorded for each against your position today, including any residence you acquired or lost since signing.
- For entity accounts, confirm the CRS classification and read the controlling-person schedule. A passive classification pulls individual shareholders and directors into Article 402.3(6) in their own right.
- Where the form no longer matches the facts, file a corrected self-certification and keep the bank’s dated acknowledgement of receipt.
- If your income is taxed in more than one place, settle the residence analysis before the form is signed. Guidance on Armenian tax residence and obligations covers how the day-count and centre-of-interests tests apply.
Last updated: 11 August 2026
