Helsinki Citizens' Assembly-Vanadzor

CSOs propose to withdraw from circulation the RA Draft Law on Making Amendments to the RA Law on Freedom of Information

January 9, 2024

Activities | Law Enforcement Practice Analysis | Rights | Joint | Announcements | Publications | Right to Seek and Receive Information | Legislative Proposals and Analysis

On 19․12․2023, the RA draft law on “Making amendments to the RA Law on Freedom of Information” was put for discussion on the unified website for publication of draft legal acts. 


We, the undersigned organizations, find this draft extremely problematic, considering definitions of certain regulations therein, which make the draft of regressive nature as compared to the acting law. At the same time, it is noteworthy that the acting law itself is quite flawed given the existing international standards and best practice.


We find the following regulations to be particularly problematic.


  • narrowing of the notion of information (public information): it is limited to the data obtained for the purpose of or during performance of functions envisaged by law for state and local government bodies and officials,

  • further narrowing of the incomplete definition of “information holder”,

  • establishing longer periods for providing certain types of information,

  • incompliance of the list of information not subject to restriction with international practice,

  • lack of a regulation regarding peculiarities of providing user-friendly information to persons with disabilities, including persons with vision and hearing impairments.


At the same time, while the draft envisages a function of oversight over observance of the sector legislation, the body authorized to develop and implement policy of digitalization and cybersecurity is responsible for its performance. This is one, yet not the main function of this body. Moreover, there are also no established safeguards for independence and autonomy of this body. 


Along with the aforementioned, it should be noted that the draft is a cornerstone document in terms of enjoyment of the constitutional right to freedom of information, yet it was not put for broader professional and public discussion prior to being published on the e-draft platform.


Based on the aforementioned, we recommend removing the draft from circulation and carrying out comprehensive discussions with sector experts and non-governmental organizations.



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