Ex-minister questions IMEI registration choice

PanARMENIAN.Net - Former Justice Minister Arpine Hovhannisyan presented her assessment of the proposed IMEI registration system for mobile phones in a Facebook video, arguing that personal data "will indeed be collected, and this is not solely for combating smuggling."

She also said that the authorities had chosen Cambodian, Turkish and Russian models instead of the European approach, asking why that decision had been made.

"Every mobile phone has what is essentially a unique identification number. You could roughly describe it as the phone's passport. Now the Armenian government says: 'We want to fight smuggling, prevent phones from entering the country through illegal channels, stop devices with counterfeit identification numbers, and protect the interests of lawful importers.' At first glance, that appears to be a legitimate objective. That is what they themselves have declared, insisting that it has nothing to do with personal data. They all keep saying it has nothing to do with personal data, but in reality, that is not the case.

First, if they are introducing this tool as part of the fight against smuggling, they are effectively admitting that they have not been carrying out that fight properly. In 2023, they passed a law allowing the State Revenue Committee, starting from January 1, 2025, to conduct inspections at businesses, verify sales and purchase volumes, compare the figures, and determine whether businesses had sold more than was reflected in their procurement documents. They have not done that.

For a year and a half, they have not carried out any administrative enforcement under the framework of that law, which they claimed had been adopted precisely for that purpose. There has been no admission of responsibility, no political or legal accountability, and then suddenly they introduce this new tool.

In Europe, within the existing GSM system, the State Revenue Committee could create a database, register those unique identifiers, provide them to mobile operators, and instruct them to provide service only to those numbers. In that case, one could at least understand the logic. But they are not stopping there. They want information showing that this phone belongs to a specific individual, who uses a particular phone number, while also being able to see the entire history, including when the SIM card was inserted into the device, and so on," Hovhannisyan said.

She added that supporters of the proposal argue it will not apply to phones already in use, but people constantly replace and purchase new devices. In her view, that is a very weak argument.

"You want the user's data, yet you do not even specify what data or why you need it. Why do you want personal data? Your objective is to make the work of law enforcement agencies easier from the outset. In other words, you have chosen the Cambodian, Turkish, Indian and Russian model instead of the approach most commonly used in Europe. Why? And why are you not telling Armenia's citizens the truth—that you are collecting personal data and that this is not only for combating smuggling," she said.

The government has stated that IMEI registration is unrelated to the collection of personal data or surveillance.

The proposed regulation provides for the creation of a unified state IMEI database and interoperability with the databases of customs authorities, telecommunications operators and other government agencies. The system would make it possible to match customs records, operator activation data and international registries, allowing only legally imported or properly registered devices to be activated.

The draft legislation also envisages an online option enabling individuals to register the IMEI code of their new mobile phone.