In 2025, a legislative package was circulated on the Unified Website for Publication of Draft Legal Acts, proposing to simplify procedures for granting land-use rights and acquiring land for mining activities.
However, the proposed amendments - particularly the draft law “On Amendments and Additions to the Land Code of the Republic of Armenia” - contradict the draft Government Decision “On Approving the National Biodiversity Strategy and Action Plan of the Republic of Armenia (2025–2030).”
According to Point 1 of Annex 2 of the Strategy draft, Armenia is required to prevent the loss of biodiversity-rich areas located outside specially protected nature areas by integrating them into effective spatial and land-use planning processes by 2030. By contrast, the new legislative package proposes a regulation under which, following the first public hearing within the Environmental Impact Assessment (EIA) process, the community council grants consent for the use of state and municipal land plots for mineral extraction purposes. This decision would be made at a stage when complete and reliable information on the biodiversity value of the area is not yet available.
The proposed regulations may have long-term implications for potential biodiversity loss in the affected areas, as well as for spatial planning at the micro-regional level. Moreover, they may affect the demarcation and clarification processes of candidate Emerald Network sites and potentially lead to their degradation or loss.
Regarding the draft legislation, during the discussion titled “Implementation of CEPA from Civil Society Perspective: From Challenges to Opportunities,” held in Yerevan on February 18, 2026, Arthur Grigoryan, President of “Ecological Law” NGO, stated:
“Communities have been granted decision-making authority. In practice, this is a double-edged sword. Under the legislative package developed by the Ministry of Territorial Administration and Infrastructure, communities are effectively obliged at the first stage to allocate land under a simplified procedure. If preliminary consent is granted at the first stage, land allocation to the mining operator must occur simultaneously. Later, at the second stage, even if the community expresses opposition to the project, it can no longer withdraw from its initial decision. Furthermore, refusal to provide land may result in financial liability, including the imposition of fines.
The core issue concerns the scope of information available at the first stage. Article 28 of the Law on Environmental Impact Assessment defines the information that the subsoil user must provide, and this information is general in nature — including the name, address, and a general description of the project. Based on this limited information, the community must decide not only whether to grant permission but also whether to allocate land. However, comprehensive information about the project’s potential impacts and risks is provided only later, at the second stage. At that point, even if significant risks are identified, the community — having already granted preliminary consent and adopted a land allocation decision — cannot reverse its position.”
February 21, 2026 at 14:59