Armenia’s Licensing Framework: A Comprehensive Guide to Required Business Authorizations

Last reviewed: 8 September 2026.

Armenia licenses a defined list of business activities set out in Article 43 of the Law on Licensing, and the licensing authority has 23 working days to grant or refuse an application unless a sector statute sets its own period. Everything outside that list can be carried on as soon as the company is registered. If the authority lets the period pass without a refusal and the state duty has been paid, the applicant is treated as licensed on the fifth working day after it expires.

The list has moved in the last two years. Cryptoasset service providers became licensable on 31 January 2026, auditing stopped being a licensed activity in 2021, and four agricultural activities join the list on 1 January 2027. Below is the current mapping of activity to authority to capital threshold to state duty, with the dates on which each of the pending changes bites.

License, municipal permit, or notification: which one applies

Armenian law does not label its system as a three-tier structure, and the tiers are an explanatory device, so do not expect to find the phrase in the statute. The distinction still governs where you file and what you pay.

National licenses are issued by ministries, the Central Bank, the Public Services Regulatory Commission, the audiovisual regulator and other authorized state bodies, under the Law on Licensing or a sector statute. Municipal permits are granted by the community council under the Law on Local Duties and Fees, and the fee is set by that council within statutory limits. Notification activities require a filing under the Law on Notification of Activity Implementation; the right to operate ordinarily arises on the fifth working day after filing if no timely refusal issues.

A single business can sit in two tiers at once. A jewellery shop that sells finished gold and silver articles at retail needs the municipal permit; if the same company also assays or hallmarks articles, organizes a precious-metals trading venue, or deals in specified natural loose diamonds, it carries a national notification obligation as well.

Licensed activities, licensing authority and license term

The allocation of authorities changed in the 2026 revision of the government decision that assigns them. Two entries in particular are commonly stated wrongly: gambling now sits with the Ministry of Economy, and hazardous waste with the Ministry of Environment.

Sector-by-sector state duties beyond the categories set out below were not established by the sources reviewed for this page. The verified duties appear in the fees section. Deeper treatment of individual sectors sits in the firm’s guides to mining licenses, natural resource utilization, renewable energy, import permits, spirits and wine production, foreign educational institutions and construction, food and technology.

Four activities people expect to be licensed that are not

• Auditing. The audit license under the Law on Licensing was discontinued, with earlier licenses ceasing to operate under a transition effective from 2021. Auditors now work through professional qualification, and audit organizations through membership and official accounting in the specialized professional organization.
• Customs representation. A legal entity must be entered in the register of customs representatives kept by the State Revenue Committee and satisfy Customs Code conditions. That is a registration, and no Licensing Law license is issued.
• Real-estate brokerage. Ordinary brokerage and agency work carries no license today. The Law on Realtor Activity, adopted on 13 November 2025, introduces qualification and official accounting; limited provisions start on 1 November 2026 and the main regime on 1 June 2027. The firm’s guide to registering as a real estate broker sets out what the new regime will require.
• Real-estate appraisal. Appraisal already runs on a statutory qualification and official-accounting regime, with conditions such as professional insurance. It is governed separately from both the Licensing Law and the Notification Law.

Financial services: the capital thresholds that actually apply

There is no universal AMD 20,000,000 capital floor for financial activity in Armenia. That figure circulates widely and it does not exist. Each regulated activity carries its own Central Bank threshold, and the spread runs from AMD 10,000,000 to AMD 30,000,000,000.

Read the figures below as minimum total capital except where charter capital is named. The distinction decides whether a business is capitalized to be registered or capitalized to operate: an insurer registers on AMD 50,000,000 (about USD 137,000) of charter capital and cannot write a single non-life policy until total capital reaches AMD 1,000,000,000.

USD conversions use the Central Bank of Armenia official rate of 363.85 dram to the dollar, 4 September 2026.

Payment organizations run to a two-month Central Bank decision period, hold their license indefinitely, and benefit from deemed licensing where the statutory non-refusal conditions are met. Issuing electronic money requires the money-transfer license plus the necessary Central Bank permission, and is not a third license category. The full procedure sits in the firm’s guide to the payment services license.

Crypto license in Armenia: the CASP regime in force since 31 January 2026

Armenia now licenses cryptoasset service providers. The Law on Cryptoassets, HO-159-N, was adopted on 29 May 2025 and entered into force on 4 July 2025; the Central Bank’s implementing licensing and prudential regulation, Regulation 7/02, took effect on 31 January 2026. Operating any of the listed services without a license is no longer possible lawfully.

Ten service types are regulated: operation of a cryptoasset trading platform, custody and administration, dealing on own account, dealing for a client, receipt and transmission of orders, placement, portfolio management, advice, transfer services, and issuance of asset-referenced tokens. One license can name several of these services, and further services are added afterwards through the statutory Central Bank procedure. That consolidation is specific to this sector and does not generalize.

Minimum total capital by service

USD conversions use the Central Bank of Armenia official rate of 363.85 dram to the dollar, 4 September 2026. The applicable minimum is generally the greatest of the fixed amount attached to the services provided, 25 percent of the relevant fixed-cost measure, and, for an asset-referenced-token issuer, the applicable reserve-linked percentage. That percentage increases once the specified number of Armenian acquirers is reached, so a token issuer can face a figure well above AMD 200,000,000.

Who can hold the license, and by when

• A domestic licensed provider must ordinarily be an Armenian joint-stock company or limited-liability company. A foreign legal entity can reach the market through an Armenian subsidiary, or through an Armenian branch holding the required Central Bank permission.
• The Central Bank decides an initial registration and licensing application within two months. Adding further services to an existing license runs on a one-month period. The Bank can suspend the running of the period where the statute allows it to seek further information, and a deemed-approval mechanism applies where no timely refusal or lawful suspension occurs.
• The annual state duty is AMD 500,000 (about USD 1,375). For a relevant foreign branch or representative office it is AMD 200,000 (about USD 550). A separate one-off application fee was not identified in the primary materials reviewed.
• Legal entities already carrying on cryptoasset services when the law took effect may continue for one year from the date the licensing regulation took effect, which puts the hard deadline at 31 January 2027. An individual entrepreneur does not become eligible for a license in that form; the transition permits temporary continuation, after which the activity must stop unless the business is reorganized into an eligible structure.
• Legacy token issuers had three months from the entry into force of the relevant implementing rules to submit an offer document or whitepaper, which produced a deadline of 30 April 2026.

Fit-and-proper testing of management, FATF-standard anti-money-laundering and know-your-customer controls, IT security requirements and capital held in a Central Bank-approved local account all apply. The firm’s dedicated guide covers CASP licensing and crypto company formation in full.

Municipal permits: what the local council controls

The Law on Local Duties and Fees lets the community council permit and charge for a defined set of activities. The council fixes the fee within statutory limits, so the amount varies by community and the application goes to the municipality.

• Retail sale of alcoholic beverages and of tobacco products
• Retail sale of articles made of precious metals
• Public catering, and operation of catering, entertainment and certain other establishments after 24:00
• Outdoor trade and outdoor advertising
• Retail of fuel, compressed natural gas and liquefied petroleum gas at specified locations
• Funeral, cemetery and related municipal services
• Keeping domestic animals in the cases covered by local rules

Taxi work is the usual point of confusion. Passenger transport, taxis included, remains inside the national licensing framework; municipalities layer their own operational, stand, parking and fee requirements on top of the national license.

Notification-only activities

Under the Law on Notification of Activity Implementation a person files a notification and acquires the right to operate on the fifth working day after filing, absent a timely refusal. The current list includes public electronic-communications services that do not require owning or operating a network, specified groundwater drilling and water-calculation services, specified production and import of higher-strength alcoholic products, assaying and hallmarking of precious-metal articles, organization of precious-metals trading venues, specified trade, import, export and transit of natural loose diamonds, trust management of participatory interests in limited-liability and additional-liability companies, specified transport-training and electronic-platform passenger services, genetic-engineering activity, tourism operator, agent, hotel and guide activity, and fitness-centre and gym activity from 15 February 2026.

Three entries that still circulate in older guides have gone. Notification entries for ordinary beer, wine, cider and honey-drink production were removed with effect from 1 January 2024, leaving only specified higher-strength and distilled categories. The cement-import entry was repealed. Real-estate appraisal moved to its own qualification and accounting regime.

How long an Armenian license lasts

A license is issued without a term unless the Law on Licensing or another statute expressly provides otherwise. The statute does expressly provide a five-year term for three important business licenses: urban development and construction, pharmacy activity, and provision of medical assistance and services. These are business and institutional licenses in their own right, and treating them as individual professional certificates understates the renewal obligation on the company.

Education works differently again, because the sector separates an institution’s activity license, program licensing, teacher and professional qualifications, accreditation and attestations. A six-year term is often quoted for an educational business license; no general six-year term for the underlying institutional license was identified in the consolidated Licensing Law, and it should not be relied on without identifying the specific education statute and license category.

Spectrum, broadcasting, water use, subsoil use and concession-type rights carry fixed terms under their own sector statutes. Several of these are permits, authorizations or resource-use rights that the Law on Licensing does not principally govern.

The application process and the 23-working-day rule

The simple and compound license procedures were removed by the 2015 licensing reform, and the articles that carried them are repealed. Any guide still promising a three-working-day automatic license or a 23-to-30-day compound track is describing law that no longer applies.

The current sequence:

1. Register the legal entity first. Licensing presupposes an entity. Banks, insurers, credit organizations and other Central Bank-regulated entities follow the special Central Bank registration and licensing route.
2. File with the correct authority. The sector table above sets out which body holds the power; filing with the wrong ministry costs the whole period.
3. Pay the state duty. Deemed licensing only operates where the duty has been paid, so an unpaid duty removes the applicant’s best protection against a slow regulator.
4. The authority decides within 23 working days of receiving the application, unless another statute sets a different period or a subordinate licensing regulation shortens it. Central Bank applications run on two months.
5. A refusal must be adopted and communicated inside the applicable period. If none is, and the duty is paid, the applicant is treated as licensed on the fifth working day after the period expires, and the authority must issue the license within five further working days.

Applications from foreign-owned businesses attract one extra document step, covered below. Sequencing and the practical causes of refusal are treated at length in the firm’s guides to licensing timelines and common application mistakes.

What a license costs: verified annual state duties

Armenian state duties are expressed as multiples of a base unit of AMD 1,000. The duties below were verified against the statutory schedules; the remainder of the Article 43 fee schedule was not established by the sources reviewed for this page.

USD conversions use the Central Bank of Armenia official rate of 363.85 dram to the dollar, 4 September 2026.

The name duty is charged annually for as long as the name is used, so it recurs as an operating cost for the life of the company. Whether a shortened or stylized form such as “Arm…” in Latin letters falls inside the rule is uncertain without an official State Register interpretation of the individual name.

Gambling duties are location-specific

The AMD 600,000,000 figure attached to gambling in most guides is real and narrow. It applies to lotteries and to internet gambling. Land-based venues pay by location, and the range is enormous.

USD conversions use the Central Bank of Armenia official rate of 363.85 dram to the dollar, 4 September 2026.

A 10 percent turnover charge on gambling operators effective July 2025 has been reported in several places. It was proposed and then dropped: the government proceeded through increased state duties before final enactment. Separate Tax Code provisions tax players’ winnings at differentiated withholding rates of 5, 10 and 20 percent depending on the bracket, and those provisions reach the player. The revised regime also includes other activity-linked and volume-linked duty components, so the headline duty may understate an operator’s total fiscal burden.

Company registration and activity licensing are two separate steps

State registration of an Armenian commercial legal entity remains free of state duty. Timing depends on the filing method and on who the founders are: the standard electronic template package can register immediately; where all founders are natural persons the ordinary period is one working day; where a legal entity is among the founders it runs to two working days.

Registration gives the company legal existence and nothing more. If the activity appears on the licensable list, the company then applies for the license as a separate matter with its own period, its own duty and its own refusal grounds. The firm’s business registration service page covers formation, and the taxes page covers what follows registration on the fiscal side.

Foreign-owned businesses

• Foreign documents require apostille or consular legalisation, plus a notarized Armenian translation. Build the legalisation time into the schedule before the 23-working-day clock is relevant, because it runs before filing.
• 100 percent foreign ownership is generally permitted with no foreign-investment approval requirement.
• A wholly foreign-owned Armenian company can hold subsoil, mining and critical-infrastructure licenses.
• Aviation is the notable carve-out: an Air Operator Certificate requires majority Armenian ownership and control.
• Foreign citizens cannot own land outright in Armenia. Land is held by lease, or through the Armenian company.

What changes between November 2026 and June 2027

Pesticide and agrochemical businesses that operated under the notification regime get a transition: they may continue under the transitional rule until the relevant annual state-duty point, after which a license is required.

Two further 2026 additions are already in force. Individual medical-professional licensing was introduced, sitting alongside the institutional medical license, and cultural-auction-organizer activity became licensable during 2026. No activity was identified as having been fully removed from the licensable list between 2024 and 2026, though establishing that as an exhaustive negative would require a formal comparison of every version of the list.

Suspension, revocation and appeal

Enforcement escalates in stages. A warning ordinarily carries a 10 to 30 day cure period. Fines follow under the Code of Administrative Offences. Suspension comes next, and involuntary revocation requires an order of the Administrative Court, so a regulator cannot simply cancel a license by its own decision.

Reporting frequency depends on oversight intensity: annual by default, and semi-annual or quarterly in high-oversight sectors. The e-government portal at e-gov.am carries both the licensing and the license-reporting functions.

A refusal or suspension is challenged first in the administrative track, with a two-month period in the ordinary case and 30 days in the expedited case, and then before the Administrative Court on a two-month period. Filing does not automatically stay the decision where public health or national security is engaged.

Frequently asked questions