Armenia’s Unauthorized Building Legalization Law: The HO-331-N Pathway and What It Costs

Legalizing a building put up on private land in Armenia with no construction permit now carries a local duty of three times the design-permission fee, three times the construction-permit duty, and a flat AMD 100,000,000 (about USD 275,000 at the Central Bank of Armenia official rate of 364.19 on 3 September 2026) in Yerevan and four adjoining marzes, or AMD 50,000,000 (about USD 137,000) elsewhere. The route itself, Article 2(3.2) of Law HO-397-N, was inserted by Article 1(7) of Law HO-331-N of 3 July 2026 and has applied since 18 July 2026. Owners have until 30 December 2027 to get a structure into it, and the deadline governs a filing with a ministry, not a payment to a municipality.

Two routes, two deadlines, two evidence packages

Armenian law has carried two separate transitional mechanisms since 18 July 2026, and they are frequently reported as one. Article 2(3.1) of Law HO-397-N is an extension of the older cadastral accounting regime. It applies where the information and documents required under the earlier deadlines in Article 2(3)(1) to (4) were never submitted. For privately owned property, the structure ordinarily has to be visible in the 2021 orthophoto material; structures on state and community land get a broader exception.

The Article 2(3.1) package consists of photographs, data from openly accessible sources, a qualified person’s conclusion, the owner’s written declaration of the construction year, and any further accounting documents the Government prescribes. It goes to the Cadastre Committee by 31 December 2026, and the Committee either confirms or refuses the accounting.

Article 2(3.2) is the new provision. It applies to entirely unauthorized structures on land owned by natural or legal persons, and it expressly reaches structures erected after the earlier statutory cut-off. Its deadline of 30 December 2027 covers two things: cadastral accounting by the Cadastre Committee, and submission of the list-inclusion package to the Ministry of Territorial Administration and Infrastructure.

Armenian general news coverage of the July 2026 package has reported a single deadline of 31 December 2026, with demolition for anything unregistered after that date. That date is real and it belongs to Article 2(3.1). An owner whose structure has no permit at all is looking at the 2027 route, and the photographs-and-declaration evidence list reported in the press is the Article 2(3.1) list, not the Article 2(3.2) one.

What must be filed, and with whom

Step one: cadastral accounting

Accounting runs through the Cadastre Committee and produces a measurement code, which is the document every later step depends on. Under Government Decision N 14-N of 5 January 2022, the surveyor must hold a qualification certificate for geodetic and mine-surveying activity, or for cartographic, land-management, measurement and accounting activity, under the Law on Geodetic and Cartographic Activity. This is a cadastral and geodetic specialist, and the technical-condition expert described below is a separate licensed professional.

Under N 14-N as it currently stands, the surveyor conducts the land survey and structure measurement, documents the results under Government Decision N 1028-N, attaches four to six colour photographs showing all sides of the structure and the number of storeys, agrees the completed package with the customer, and uploads it through the online measurement office. The agreement form also records the year in which the owner asserts the structure was built. Government Decision N 14-N is scheduled for amendment in October 2026, so the accounting requirements specific to the Article 2(3.2) route are not yet in final form.

Step two: the list-inclusion package

Article 2(3.2) requires the persons who carried out the unauthorized construction to submit four items to the Ministry of Territorial Administration and Infrastructure:

• The measurement code confirming Cadastre accounting.
• A positive technical-condition conclusion issued by a person or organization holding the urban-planning activity licence with the annex for technical-condition examination and passporting of buildings and structures. The conclusion must address the structure’s technical condition, the reliability and strength of its load-bearing elements, its seismic safety, and whether safe operation is possible.
• A positive fire-safety conclusion from the Urban Development, Technical and Fire Safety Inspectorate confirming compliance with fire-prevention requirements.
• A written preliminary assessment from the competent legalization authority confirming the absence of material urban-planning violations, of violations of or danger to the rights and legally protected interests of third persons, the state or the community, and of the refusal grounds prescribed by the Government’s legalization and disposal procedure.

The structural and seismic assessment is a statutory precondition to list inclusion, and so is the fire-safety conclusion. Both have to exist before the Ministry will consider the file, which means commissioning two licensed reports well inside the 2027 window.

After the Ministry receives the packages, the Government approves the list of eligible structures by no later than 20 February 2028. Only a listed structure may then be legalized under the Government procedure, on payment of the local duty. Existing Government Decision N 912-N of 18 May 2006 directs the landowner to apply to the relevant community head, who decides legalization or refusal.

What the duty costs

Law HO-332-N added point 24 to Article 12(1) of the Law on Local Duties and Fees, and added Article 9(1)(2.1), which makes the duty payable only for structures that have been accounted under the Government procedure and included in the Government-approved list. The formula has three components: the local fee in force at the time of payment for preparing the design permission or architectural-planning assignment, the construction-permit local duty calculated under the applicable community-council decision, and a flat sum. USD figures below use the Central Bank of Armenia official rate of 364.19 on 3 September 2026.

Exemptions and reductions do exist

Article 2(3.2) contains an express exemption for listed unauthorized structures constructed with state-budget financing or co-financing. Those structures owe nothing under the paragraph.

Article 16 of the Law on Local Duties and Fees lets a community council, acting on submission by the community head and on the documentation the council prescribes, grant a percentage reduction in the rate, a zero rate, or complete exemption from a calculated local duty. Nothing in Article 16 excludes the new point 24. The relief is discretionary: the council must have adopted the mechanism and must decide to apply it.

Why nobody can quote you a final number yet

Article 12(2) permits community councils to apply reducing coefficients to the rates stated in Article 12 for rural and urban settlements, and Article 12(3) permits higher rates in urban settlements and Yerevan. Point 24 is not among the points expressly excluded from either provision. Whether those coefficients touch the whole aggregate including the flat AMD 100,000,000 or AMD 50,000,000 component, only the variable permit components, or nothing at all, has not been resolved by any enacted implementing clarification. Given the sums, the payable amount for a specific structure has to be worked out against the applicable community-council decision and any later official guidance.

On timing of payment, Article 15 provides that the local duty is collected before the relevant action is performed or validated and before the permit issues. No statutory entitlement to pay by installments has been identified in HO-332-N or in Articles 15 and 16. Whether a municipality can authorise a payment arrangement under some other budgetary power is unsettled.

What keeps a structure off the list

Government Decision N 912-N currently excludes from legalization any structure whose preservation violates other persons’ rights or legally protected interests or threatens life or health; any structure on land described in Land Code Article 60; any structure inside engineering or transport exclusion or safety zones; any structure erected with material urban-planning violations that give rise to a right to demand compulsory servitude; and any structure not accounted within the statutory accounting deadlines.

Land Code Article 60 is narrower than a general reference to land-use breaches. It identifies state or community land that may not be transferred into private ownership, and its categories include historical and cultural objects, specially protected natural territories, state forests, specified water-fund land, public streets and parks, and transport or utility corridors.

For a structure going down the Article 2(3.2) route, the practical barriers are a failed technical, load-bearing or seismic assessment, a failed fire-safety assessment, a threat to life or health, material urban-planning violations as distinct from minor technical ones, and interference with third-party, state or community rights. Government Decision N 912-N is itself scheduled for amendment in December 2026, so the final refusal grounds for this route may differ from the list above.

Demolition powers run in parallel

Law HO-405-N amended Civil Code Article 188(3) with effect from 30 August 2026. For unauthorized and unlegalized structures on privately owned land, and for unauthorized unlegalized portions attached to lawful structures, the community head or an authorized official may issue a written demand requiring the owner to demolish the structure and restore the previous condition at the owner’s expense within one month of receipt, unless the demand allows a longer period.

Law HO-406-N added Article 154.6 to the Code of Administrative Offences on the same date. Failure to comply with that demand carries a fine of 2,000 to 2,500 times the statutory minimum-wage unit. Continuing the violation after the first sanction carries 2,500 to 3,000 units.

Law HO-398-N changed the litigation position twice over. Challenges to a community head’s refusal to legalize a structure on privately owned land, and challenges to the statutory written demands, now sit within the exceptions in Administrative Procedure Code Article 83(1), so filing an administrative claim does not carry the ordinary automatic suspensive effect. The new Article 91(6) prohibits courts from granting an interim measure that would prevent demolition, and that prohibition is confined by its own text to structures on state or community land. It does not reach Article 2(3.2) structures, which by definition sit on private land. Law HO-397-N of 3 July 2026 made the parallel amendment to Civil Procedure Code Article 129(4), also in force from 30 August 2026.

Missing a deadline does not itself demolish anything. Deadline expiry may leave a structure outside the available route or supply a refusal ground, and it is not the written demand that Civil Code Article 188(3) requires. Demolition on private land still needs the separate written-demand procedure introduced by HO-405-N.

Whether a pending filing protects a structure is the open question. No provision in HO-331-N, HO-405-N, HO-398-N or HO-406-N states that cadastral accounting, submission of the Ministry package, pending list consideration, or a pending legalization application stays, suspends or tolls a demolition demand that has already issued. On a literal reading, a structure with a package in transit is still unauthorized and unlegalized for the purposes of HO-405-N. Requirements in this area may be settled by the forthcoming amendments to Government Decisions N 14-N and N 912-N or by administrative and judicial practice, and the position for a specific structure should be confirmed before relying on a filing as protection.

The procedure is not finished

Prime Minister Decision N 852-A of 2 September 2026, effective 3 September 2026, schedules the amendment to Government Decision N 14-N on accounting for October 2026 and the amendment to Government Decision N 912-N on legalization for December 2026. The Government list is due by 20 February 2028.

Three things follow. The accounting evidence specific to Article 2(3.2) is not yet prescribed. The post-list sequence, including the filing form, the decision period and the payment mechanics, is not yet set. And HO-331-N prescribes no separate owner deadline for the municipal application or for paying the duty, so the only hard date an owner controls is 30 December 2027.

How this differs from the cadastral correction law

Law HO-319-N adds Articles 34.1 and 34.2 to the Law on State Registration of Rights to Property and enters into force on 18 October 2026. It addresses a property unit missing from the cadastral map, an incorrect location, incorrect dimensions, area or geometry, incorrect designated or functional use, and incorrect owner or right-holder information, and it creates a cadastral-quarter review where actual boundaries do not match the registration documents. It corrects the record and cannot retrospectively supply a construction permit.

HO-331-N and HO-332-N address the absence of construction authorization itself. HO-405-N, HO-398-N and HO-406-N regulate demolition demands, suspensive effect and penalties, and create no alternative legalization route. A related reform from the same July 2026 package, on administrative silence in Armenian property law, changes how a municipality’s failure to respond is treated.

What buyers and lenders should check

An unaccounted structure on an otherwise clean parcel now carries a quantifiable exposure: a one-month demolition demand available to the community head, a fine of 2,000 to 2,500 minimum-wage units for ignoring it, and a cure cost that starts at AMD 50,000,000 before the tripled permit fees are added. That belongs in the price, and it belongs in a lender’s security assessment.

• Compare the structures physically standing on the parcel against the ones shown in the cadastral extract. A title and encumbrance check in the cadastre is where that gap shows up.
• Ask the seller for the measurement code for every structure. Absence of a code means no accounting, which means the Article 2(3.2) clock applies.
• Establish which route a structure is eligible for. A structure that merely missed an earlier accounting deadline may still fit Article 2(3.1) and its 31 December 2026 filing date, which is a materially cheaper outcome.
• Check the community-council decision that sets the construction-permit duty in the relevant community, since two of the three components of the legalization duty are calculated from local rates.
• For a structure with no registration history at all, the first-time property registration procedure sets out how the cadastral record is opened.

Frequently asked questions

Sequence for the 2027 deadline

1. Pull the cadastral extract and identify which structures on the parcel have no entry.
2. Engage a certified geodetic surveyor to measure and account the structure under Government Decision N 14-N, and obtain the measurement code.
3. Commission the technical-condition conclusion from a holder of the urban-planning licence with the examination and passporting annex.
4. Obtain the fire-safety conclusion from the Urban Development, Technical and Fire Safety Inspectorate.
5. Request the written preliminary assessment from the community head as legalization authority.
6. File all four documents with the Ministry of Territorial Administration and Infrastructure before 30 December 2027.
7. Obtain the community-council decision setting the construction-permit duty so the payable amount can be modelled before the Government list is approved in February 2028.

Last updated: 4 September 2026