At its sitting on 6 August 2026, the Government of the Republic of Armenia approved the decision designating Random Systems International Limited, a company registered in Malta, as the gaming regulation operator for Armenia. The company was selected through the competitive procedure prescribed by the Law “On Regulation of Gaming Activity” (adopted 12 June 2024), with three foreign organisations having submitted applications.
Key Takeaways
- The Government of the Republic of Armenia has designated Random Systems International Limited, a company registered in Malta, as the gaming regulation operator for Armenia.
- Under Article 58(4), the provisions of the Law are put into effect on the day following the expiry of the sixth month from the date the operator is designated. On the basis of a 6 August 2026 designation, the substantive regime would become operative in early February 2027.
- Under Article 58(9), the two 2003 laws that currently govern the sector are repealed as of that same date.
- Licences issued under the pre-2024 framework must be brought into conformity with the new Law within six months after the Law is put into effect. Licences not brought into conformity within that window are deemed terminated – around August 2027 on the timeline above.
- Territorial restrictions, product certification, monitoring-centre connection, player restrictions and the new sanctions regime all begin to bite when the Law becomes operative.
Presenting the draft, the Acting Chairman of the State Revenue Committee noted that the winning company already performs an analogous function in neighbouring Georgia, and that the company must fully deploy the electronic management system within six months of the decision entering into force.
At first glance, this reads as a procurement outcome. In substance, it is the single event the 2024 gaming reform has been waiting on for over two years – and it starts a series of statutory clocks that will reshape how every licensed operator in Armenia does business.
For advice on how the new gaming regulation framework applies to your operation, our licensing and regulatory team is available to discuss it. Contact our team
When Does Armenia’s 2024 Gaming Law Come Into Effect?
The 2024 Law has been formally in force since 1 July 2024, but most of it has not been operative. Article 58 draws a deliberate distinction between the Law entering into force and its provisions being “put into effect”.
Under Article 58(4), the provisions of the Law are put into effect on the day following the expiry of the sixth month from the date the operator is designated under Article 23(1). Under Article 58(9), the two 2003 laws that currently govern the sector – on games of chance, internet games of chance and casinos, and on lotteries – are repealed as of that same date.
In other words, this decision converts an abstract reform into a dated one. On the basis of a 6 August 2026 designation, the substantive regime would become operative in early February 2027, with the 2003 framework falling away at the same moment.
Key Dates: Three Deadlines, Not One
| Milestone | Basis | Timing |
| Operator designated | Government decision | 6 August 2026 |
| State Revenue Committee concludes the contract with the operator | Within ten days of designation | August 2026 |
| Winner incorporates and registers the Armenian commercial entity that holds operator status | Within ten working days from publication of the competition results | August 2026 |
| Two-month window to challenge the commission’s decision closes | Two months from notification or publication | Approximately October 2026 |
| Electronic management system, including the monitoring centre, fully implemented | Approximately six months | Approximately February 2027 |
| Law put into effect; 2003 laws repealed | Article 58(4), Article 58(9) | Early February 2027 |
| Pre-2024 licences to be brought into conformity | Article 58(6) – six months after the Law is put into effect | Around August 2027 |
1. Operator deployment – approximately six months
The designated company must have the electronic management system, including the monitoring centre, fully implemented. In parallel, the State Revenue Committee must conclude the contract with the operator within ten days of designation, and the winner has ten working days from publication of the competition results to incorporate and register the Armenian commercial entity that actually holds the operator status.
2. Law fully operative – the day after month six
Territorial restrictions, product certification, monitoring-centre connection, player restrictions and the new sanctions regime all begin to bite.
3. Licence conformity – a further six months
Licences issued under the pre-2024 framework must be brought into conformity with the new Law within six months after the Law is put into effect. Licences not brought into conformity within that window are deemed terminated. On the timeline above, that outer deadline lands around August 2027.
Who Regulates Gaming in Armenia? What the Operator Is – and What It Is Not
The operator is not a regulator. Licensing and policy remain with the Ministry of Economy; supervision remains with the State Revenue Committee as Controlling Body. The operator is a private compliance and technology layer inserted between them and the market, on public-private partnership logic.
The Law contains several structural safeguards worth noting:
- Exclusivity of purpose. The operator may not engage in any activity outside the subject matter of the Law.
- Independence from the market. An application is rejected if the applicant’s founder, shareholder, participant or beneficial owner – or an affiliated person – is a gambling organiser or a manufacturer of gaming products.
- State retention of control. From the moment the contract is signed, the Controlling Body acquires the right to administrative access to the electronic management system, including credentials. If the operator’s authority is terminated and no successor is designated, operation of the system passes to the Controlling Body.
- Read-only market access. The operator has full real-time access to organisers’ information systems regarding chips purchased, winnings, gaming products and in-game events – expressly without any possibility of making changes or intervening.
Operators considering entry rather than conformity will need an Armenian commercial entity before a licence application can proceed.
The Practical Impact on Licensed Organisers
For companies operating in the Armenian market, the operator’s arrival changes day-to-day compliance in five concrete ways.
Monitoring centre connection becomes a condition of lawful operation
Organising gaming activity with products that are not connected to the operator’s monitoring centre, where connection is required, is prohibited. Connection is applied for by the organiser, supported by a product list, conformity certificates, taxpayer details, the physical location of the interactive platform and hardware, and the licence itself. Connection is terminated automatically if the licence is terminated.
Product certification runs through the operator
The operator either issues conformity certificates itself, where it holds the relevant ISO accreditation, or validates certificates issued by internationally accredited laboratories. Certificates can be invalidated where a certified product is materially modified.
Individual staff need operational certificates
Gaming operations may only be carried out by individuals holding a valid operational certificate. Applicants must be over 21, free of convictions for fraud, money laundering, organised crime or terrorism, and must not have served in the Controlling Body or Authorised Body in the relevant supervisory or licensing role – or worked for the operator – in the preceding two years. Certificates are valid for two years, and renewal applications must be filed at least three months before expiry. Workforce planning should start well before the trigger date.
A new mandatory contractual and cost relationship
The operator concludes a services agreement with each organiser and sets its own prices, capped by a Government decision and published on its website. This is a new recurring cost line that does not exist under the 2003 regime. The Georgian precedent is instructive: there, certification and monitoring-connection fees are set as capped maxima per activity type and vary with system complexity. The Armenian caps are a commercial variable to watch closely.
Player restriction infrastructure becomes centralised
The operator maintains the databases required for the participation restrictions under Articles 47-49 and makes them accessible to organisers, who must in turn maintain an operator-approved hardware and software system for identification. Self-exclusion, restrictions on socially vulnerable and bankrupt persons, and the 21/18 age thresholds all run through this layer.
What Else Switches On at the Same Time
Because the designation activates the Law as a whole, a number of substantive restrictions that the market has been anticipating since 2024 arrive together:
| Restriction | What it provides |
| Territorial limits | Gaming halls are confined to Tsaghkadzor, Jermuk, Sevan and Meghri; slot and hall-based internet gaming is additionally permitted at Zvartnots Airport; bookmaker and lottery halls are limited to one per marz administrative centre and one per Yerevan administrative district, each capped at 200 m². A carve-out exists for approved investment programmes exceeding AMD 40 billion at a single location. |
| Minimum return to player | 90% for RNG-based products, to be confirmed by the conformity certificate. |
| Domain rule | Activity on an interactive platform is treated as organised abroad – and therefore blockable – if the organiser’s information resources are not in the “.AM” domain. |
| Payment flows | Cashless, AMD-denominated flows through the player’s own bank account, with defined exceptions for identified foreign players. |
| Lotteries | Prohibition on electronic and online lotteries in Armenia. |
| Audit | Enhanced audit requirements, including a three-year cap on engaging the same audit firm and mandatory publication on azdarar.am. |
| Sanctions | A recalibrated sanctions regime, including fines rising on repeat breach, licence suspension and termination, and confiscation of gaming products where activity is carried out without a licence. |
Open Questions
The two-month challenge window
The law gives any interested person the right to challenge in court the commission’s decision rejecting a qualification application or declaring a winner, within two months of notification or publication. With three bidders and one winner, this window – running to approximately October 2026 – is a live source of timeline risk.
Pricing caps
The Government decision setting maximum operator fees is the most commercially consequential piece of subordinate legislation still to be finalised.
What to Do Now
Licensed organisers and prospective market entrants should be using the next six months, not the six months after that:
- Confirm the exact trigger date from the published text of the Government decision.
- Audit the existing licence against Article 5 and Article 51 requirements and identify what must change for the Article 58(6) conformity exercise.
- Assess whether current premises survive Article 9, and model the cost of relocation or closure.
- Inventory gaming products and identify which require conformity certificates and monitoring-centre connection.
- Map responsible persons and gaming staff against the Article 37 operational certificate criteria – including the two-year cooling-off rules.
- Review internal rules against Article 11(3) and prepare for re-approval.
- Budget for operator fees, ISO-accredited testing and system integration work.
- Prepare AML/CFT, advertising and personal data compliance for supervision that will be evidence-rich rather than sample-based.
FAQs
Who is Armenia’s gaming regulation operator?
The Government of the Republic of Armenia has designated Random Systems International Limited, a company registered in Malta, as the gaming regulation operator for Armenia. The company was selected through the competitive procedure prescribed by the Law “On Regulation of Gaming Activity”, with three foreign organisations having submitted applications. The Acting Chairman of the State Revenue Committee noted that the winning company already performs an analogous function in neighbouring Georgia. The company must fully deploy the electronic management system within six months of the decision entering into force.
When does Armenia’s 2024 gaming law take effect?
The 2024 Law has been formally in force since 1 July 2024, but most of it has not been operative. Under Article 58(4), the provisions of the Law are put into effect on the day following the expiry of the sixth month from the date the operator is designated under Article 23(1). On the basis of a 6 August 2026 designation, the substantive regime would become operative in early February 2027. Under Article 58(9), the two 2003 laws that currently govern the sector are repealed as of that same date.
Is the gaming regulation operator a regulator?
The operator is not a regulator. Licensing and policy remain with the Ministry of Economy, and supervision remains with the State Revenue Committee as Controlling Body. The operator is a private compliance and technology layer inserted between them and the market, on public-private partnership logic. It has full real-time access to organisers’ information systems regarding chips purchased, winnings, gaming products and in-game events – expressly without any possibility of making changes or intervening.
What happens to existing Armenian gaming licences?
Licences issued under the pre-2024 framework must be brought into conformity with the new Law within six months after the Law is put into effect. Licences not brought into conformity within that window are deemed terminated. On the timeline set by a 6 August 2026 designation, that outer deadline lands around August 2027. Organisers should audit the existing licence against Article 5 and Article 51 requirements and identify what must change for the Article 58(6) conformity exercise.
Where can gaming halls operate in Armenia?
Gaming halls are confined to Tsaghkadzor, Jermuk, Sevan and Meghri. Slot and hall-based internet gaming is additionally permitted at Zvartnots Airport. Bookmaker and lottery halls are limited to one per marz administrative centre and one per Yerevan administrative district, each capped at 200 m². A carve-out exists for approved investment programmes exceeding AMD 40 billion at a single location.
For advice on how the new gaming regulation framework affects your business, please contact our team.
