Foreign ownership restrictions / limitation of foreign investments and equity in corporations in Armenia
1) Are there any restrictions on foreign ownership in companies?
The RA legislation , specifically the law on Limited Liability Companies and joint-stock companies does not stipulate any difference between RA citizens and foreign citizens in terms of company ownership. Furthermore, foreign individuals and legal entities hold the right to own 100% of companies in the RA. However, there are ownership restrictions on the strategic companies set by the RA legislation.
2) Is government approval required for foreign investment in local companies?
According to the “Open door” policy implemented in 2019, Armenia welcomes foreign investors, and no pre-authorization or prior government approval is required for foreign investment in local companies.
3) Which sectors are subject to special rules or restrictions for foreign investors?
Under the legislation of the Republic of Armenia, certain areas may be designated where, based on the national security requirements, the activities of foreign investors and enterprises with foreign investment may be restricted or prohibited. Such sectors are: Air transport (aviation), Railways and airport infrastructure, Television and radio broadcasting, Agricultural and forest lands, Defense and military production etc.
4) Can foreign persons own 100% of a limited liability company or joint-stock company?
One of the key advantages of Armenia’s business climate is its welcoming approach to foreign ownership. Both individual investors and entities or legal entity have the right to own 100% of a limited liability or joint-stock company. There is no obligation to involve a local partner, appoint an Armenian shareholder, or meet any residency requirements.
5) Are beneficial ownership rules applicable to foreign participants?
Armenia’s beneficial ownership laws apply to both foreign and domestic participants equally per the Law on Anti-Money Laundering and combating terrorist financing . Any foreign shareholder, investor, must ensure that their ultimate beneficial owners (UBOs) are properly identified and disclosed to RA Ministry of justice agency for state register of legal entities. This is essential for transparency, AML/CTF compliance, and to maintain lawful operations in Armenia.
6) Are there any quotas or thresholds on foreign ownership in strategic companies?
According to Armenian law and regulatory practice, foreign ownership is subject to quotas in strategic sectors. For example, foreign investors are limited to 50% in media broadcasting organizations. In sectors like energy, telecom, mining, and banking, there is no fixed quota, but participation is regulated through mandatory licensing and government approval.
7) Is disclosure of foreign shareholders/participants required when registering a company?
Under the Law on State Registration of Legal Entities and relevant government decisions, foreign shareholders or participants must be fully disclosed during company registration in Armenia. This includes their identity, nationality or jurisdiction, ownership percentage, and ultimate beneficial owner (UBO) information.
8) Are there any restrictions on the acquisition of real estate by foreign legal entities?
According to the Constitution of the Republic of Armenia, all individuals holding foreign citizenship in Armenia are not permitted to ownership of land on the territory of the Republic of Armenia. However, the restriction does not apply to land ownership for specific reasons like, homestead use, horticultural use, as well as for the construction and maintenance of individual residential houses, public and industrial facilities, and multi-apartment residential buildings.
9) Are there any business or office localization requirements for foreign investors?
The requirement of office localization depends upon the activity of the business regardless of the fact of being foreign or local investor.
10) Are sanctions or other restrictions applied to investors from specific countries?
Currently according to the legislation of RA there is no investor from any specific country that falls under any sanctions or other restrictions.
Author: Hasmik Martirosyan
