Armenian cybersecurity expert warns proposed mobile phone registry could expand state surveillance

An Armenian government proposal to establish a nationwide registry of mobile phone IMEI numbers has drawn criticism from cybersecurity expert Samvel Martirosyan, who warned that the initiative could substantially expand the state's capacity to monitor citizens while introducing sweeping data collection measures.

The proposal, which the government says is intended to curb the illicit trade in mobile phones, would require the registration of International Mobile Equipment Identity (IMEI) numbers, the unique identifiers assigned to every mobile device.

Martirosyan argued that the initiative extends far beyond combating the black market and raises significant concerns over privacy, proportionality, and government oversight.

"The first issue is that citizens become considerably more traceable," Martirosyan said. "Not only can individuals be identified through their SIM cards, but the device itself becomes permanently associated with its owner."

According to Martirosyan, the draft legislation envisions the creation of a state entity responsible for maintaining an extensive database containing IMEI numbers, SIM card data, passport details and records of cross-border movement. He claimed that mobile phones not entered into the registry would eventually be blocked from operating on Armenian networks.

He also cautioned that the measure could create practical obstacles for foreign visitors.

"A tourist arriving in Armenia could find their phone disconnected after 30 days unless it is registered," Martirosyan said. "Visitors would be required to queue at a government institution simply to register their device and avoid having it blocked."

Martirosyan further contended that the proposal authorizes the collection of a disproportionate volume of personal data without establishing sufficiently robust accountability or oversight mechanisms.

"We are dealing with excessive data collection," he said. "At the very least, I do not see an effective mechanism for supervising those entrusted with this information. The question is whether placing the entire population under greater surveillance is justified merely to eliminate a relatively small segment of the gray market."

He also asserted that the system would impose additional financial obligations on consumers, noting that the measure envisions a registration fee, although the amount has not yet been specified.

"The public will ultimately bear another financial burden through an additional state levy," the expert said.

Martirosyan argued that legislation with such far-reaching implications should undergo broader public consultation beyond parliamentary debates.

Pointing to international precedents, Martirosyan said similar IMEI registration systems operate in countries including Turkey, Iran, Lebanon, Egypt, Uzbekistan, Kazakhstan, Azerbaijan, Tajikistan, Indonesia, Pakistan, Nepal, Cambodia, Bangladesh, Chile, Colombia and Mexico. He argued that these examples do not represent a persuasive model for Armenia and claimed that Russia is also preparing to introduce a similar system.