Armenia's FRT Expansion Raises Privacy Concerns and Legal Questions

Published Date : 7/8/2025 

Armenia's recent approval of real-time facial recognition technology (FRT) surveillance has ignited widespread concerns about privacy, civil liberties, and the lack of regulatory oversight. The new law, set to take effect in August, grants police unrestricted access to biometric cameras across public spaces, raising questions about its impact on democratic principles. 

Armenian lawmakers recently passed controversial amendments to the country’s Law on Police, allowing the Ministry of Internal Affairs to deploy a nationwide network of real-time biometric surveillance cameras. The law, which takes effect on August 9, has sparked a firestorm of debate over its potential to erode privacy rights and suppress free expression. Critics argue that the measure lacks clear safeguards and could enable mass surveillance, particularly in public spaces where protests and civic activities traditionally occur. n nThe surveillance system, equipped with facial recognition technology (FRT), will monitor state and municipal buildings, public transport, airports, parking areas, and cultural institutions. According to the amended law, FRT will automatically identify individuals for both serious offenses and minor violations, with automated penalties. However, the absence of a comprehensive legal framework for AI and biometric data use has left many questions unanswered. The only existing provision for biometric surveillance is found in Article 19 of the Police Law, which mandates personnel identification, electronic logs, and timestamps on footage. Yet, the language is vague, allowing police to justify surveillance based on 'reasonable suspicion' of any offense. n nCivil society organizations (CSOs) like CSO Meter, an EU-funded watchdog, have raised alarms about the law’s potential for abuse. They argue that the lack of oversight and the broad interpretation of 'reasonable suspicion' could lead to disproportionate targeting of individuals, particularly for minor infractions. The CSO also criticized the law for leaving critical implementation details to ministerial discretion rather than enshrining them in primary legislation. This ambiguity has drawn comparisons to similar laws in other countries, where FRT has been linked to restrictions on freedoms, such as Hungary’s controversial use of facial recognition for LGBTQ+ surveillance. n nThe EU-Armenia Comprehensive and Enhanced Partnership Agreement (CEPA), which came into effect in 2021, has added another layer of scrutiny. While the agreement emphasizes human rights and democratic values, the new surveillance law appears to contradict its principles. Human rights advocates warn that the system could create a 'chilling effect' on public assembly, deterring peaceful protests and stifling dissent. This concern is amplified by the fact that the law was pushed through Parliament by the ruling Civil Contract party without significant opposition, raising questions about transparency and democratic accountability. n nIn addition to the police surveillance expansion, Armenia’s justice system is also moving toward biometric integration. The Probation Service has launched a tender to introduce automated visit recording systems using smart biometric devices for fingerprint and face scanning. The system aims to streamline court-mandated check-ins for probation beneficiaries, with data stored in a centralized database. While the tender highlights the government’s push for digital efficiency, critics argue that such measures could further entrench surveillance practices without adequate safeguards. n nThe debate over FRT in Armenia mirrors global trends, where countries like the UK and parts of the Balkans are grappling with similar issues. In the UK, police use of FRT has faced legal challenges over its accuracy and potential for racial bias. Meanwhile, in Hungary, the technology has been criticized for targeting marginalized groups. These examples underscore the need for robust legal frameworks to prevent misuse. Without independent oversight, experts warn that Armenia’s new law risks normalizing mass surveillance, undermining the very democratic principles it claims to protect. n nCalls for a suspension of the law have grown, with activists urging the government to involve bodies like the OSCE/ODIHR and the Venice Commission in a thorough review. They argue that the current timeline is too rushed to address the complex ethical and legal challenges posed by FRT. Meanwhile, the public remains divided, with some supporting the law as a tool for crime prevention and others condemning it as a threat to civil liberties. n nAs the August 9 deadline approaches, the tension between security and privacy continues to escalate. The Armenian government maintains that the law is necessary to enhance public safety, but critics fear it could set a dangerous precedent. With no clear path for accountability or redress, the future of biometric surveillance in Armenia remains uncertain, leaving citizens and international observers to grapple with the long-term implications of this contentious policy. 

Frequently Asked Questions (FAQS): 

Q: What does the new Armenian law on FRT entail?

A: The law grants police real-time access to biometric surveillance cameras across public spaces, allowing automated identification of individuals for both minor and serious offenses.

Q: Why are civil society groups opposing the law?

A: Critics argue the law lacks clear legal safeguards, enabling potential abuse of power and eroding privacy rights, particularly for minor infractions.

Q: How does the EU-Armenia partnership affect this law?

A: The EU-Armenia CEPA emphasizes human rights, but the new surveillance law has drawn criticism for contradicting these principles and lacking oversight.

Q: What role does the Probation Service play in this context?

A: The Probation Service is introducing biometric devices for automated check-ins, raising concerns about expanding surveillance into the justice system.

Q: What are the global implications of Armenia’s FRT expansion?

A: The law mirrors similar debates in countries like the UK and Hungary, where FRT has faced scrutiny over privacy and potential misuse. 

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