New Law on Higher Education: Meaningful Reform or Top-Down Policy?

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A new Draft Law on Higher Education and Science has sparked extensive public debate in Armenia. Promising some much-needed regulatory changes, the proposal has also set off alarm bells among education experts who worry that key amendments could compromise the core principles of Armenia’s higher education system. 

The Draft Law—introduced jointly by the Ministry of Education, Science, Culture, and Sport and the Higher Education and Science Committee—will significantly contribute to the system’s development through a more progressive trajectory. Notable highlights include:

• Establishing a tertiary education framework that includes Bachelor’s, Master’s and PhD qualifications;
• Creating a legal framework for cooperative education programs, micro-credentials, and integrated education programs;
• Introducing legal measures to support innovation promotion and commercialization;
• Provisions for the internationalization of higher education.

Previously, the lack of such regulations had significantly hindered the progress of Armenia’s higher education system, widening the quality gap with countries that have well-established education systems.

Alongside these positive reforms, the Law also proposes some radical amendments that may not have been fully researched or carefully considered. These changes could jeopardize key principles of the higher education system, such as democratic values, free competition, university autonomy (despite being highlighted as a core principle), balanced regional development, national security, innovation and flexibility within the system.

Forced Mergers

Mergers and the enlargement of universities have become key components of higher education policies worldwide. The Chronicle of Higher Education has dubbed this trend “merger mania.” In recent years, mergers have spread across Asia and Europe, driven by internal and external pressures, financial crises, and the need for more efficient management of public funds. For example, China recorded over 400 mergers in the late 2000s, consolidating around 1,000 public universities.

Initially, the primary aim of these mergers was to improve the management of public resources, particularly financial ones. Today, however, a major goal is to enhance international competitiveness and reputation, helping universities climb global rankings. This shift in focus is clearly reflected in the rhetoric of higher education policymakers in Armenia. The “State Program for the Development of Education in the Republic of Armenia until 2030” aims to position four Armenian universities within the top 500 of the World University Rankings.

Elimination of Multiple Mission Universities

International practice shows that mergers of higher education institutions can significantly enhance a university’s international recognition and competitiveness, provided the full range of resources is utilized and adequate funding is provided. These mergers often lead to improved rankings, particularly through the integration of scientometric indicators.

However, an excessive focus on improving rankings can lead to the concentration of financial resources in research, at the expense of educational innovations. Universities, driven by the pursuit of measurable targets, may overinvest in research, compromising teaching quality. International ranking systems tend to favor research output, citation counts, and global research collaborations. Meanwhile, criteria related to teaching quality are limited, often restricted to student-to-faculty ratios and academic reputation surveys.

The new regulations under the Law, particularly those promoting enlargement and centralization, risk sidelining the core mission of “teaching universities”. These institutions are crucial for developing practical student skills in smaller classrooms with low professor-student ratios, meeting local labor market needs, and supporting sustainable community development. Not all universities should aim to become “research universities”—both “research” and “teaching” institutions have distinct and vital roles in the educational ecosystem.

Moreover, the “State Program for the Development of Education until 2030” sets a key indicator that “90% of alumni will work in their field upon graduation.” But is it realistic to achieve this goal by focusing solely on a research-oriented higher education system dominated by large universities?

The Standards and Guidelines for Quality Assurance in the European Higher Education Area (ESG 2015), overseen by the Committee of Ministers of the Council of Europe, outline multiple purposes for higher education. These include preparing students for active citizenship and future careers, enhancing employability, fostering personal development, building a broad knowledge base, and driving research and innovation. These guidelines acknowledge that stakeholders, including universities, may prioritize different goals and view quality from various perspectives. However, the proposed Draft Law diverges from this diverse, multifaceted approach to higher education. Instead, policymakers emphasize a “research-based higher education system,” which risks creating polarization, hastening the development of multi-mission universities, and imposing potential limitations.

In educational reforms, the quality of teaching must be prioritized to preserve the primary mission of universities—ensuring effective, student-centered education alongside academic achievements. This important lesson from global practice should remain in focus to ensure a balanced policy.

Is Large Really More Effective?

University mergers, including the integration of National Academy of Sciences institutes into universities, will introduce a more complex and bureaucratic management structure. This change will likely reduce flexibility, slow internal reforms, and delay decision-making. Such a system risks hindering meaningful adaptation in our rapidly evolving world, increasing the likelihood that reforms will remain structural and superficial, overlooking the need for quality-driven change.

International experience shows that national plans often prompt voluntary or mandatory university mergers. However, the participatory process and stakeholder engagement prior to a merger are typically more impactful for long-term improvements than the merger itself. Philip Altbach, Professor Emeritus and Distinguished Fellow at Boston College’s Center for International Higher Education, highlighted the significance of these pre-merger discussions in driving genuine reform:

“Mergers of universities happen for various reasons, including demographic decline, financial efficiency, and benefits from scaled effects. For instance, the latest mergers in France have led to the establishment of excellent universities. However, the mergers need to be implemented with great caution and with the participation of all stakeholders.”

The new Law’s regulations could limit the participatory process in mergers, potentially sacrificing long-term benefits. Specific provisions prevent voluntary mergers, mandating instead a minimum enrollment of 4,000 students per university. This requirement is problematic, as it forces mergers not only on public universities but also on interstate and private institutions. Smaller institutions are left with the sole alternative of rapid enrolment growth, which may compromise educational quality.

Unlike public universities, interstate and private institutions receive minimal government funding—often limited to covering a few student tuitions per year. While consolidating resources to enhance financial management and international competitiveness may be justifiable for public universities, forced mergers among interstate and private institutions seem arbitrary and could raise both quality and legal concerns. The enrolment threshold ignores the established diversity within the country’s higher education landscape and lacks any projection or rationale for future impacts. Additionally, no assessment of the effectiveness of existing university models has been conducted, leaving a critical gap in planning and foresight.

This regulation poses significant challenges to ongoing reforms within the higher education system, especially regarding quality. Our research and available data show no international precedent for setting a minimum student enrollment threshold to determine a university’s viability. Instead, countries generally ensure higher education quality through qualitative criteria and standards, not by mere “headcount”. According to Philip Altbach, “Countries ensure quality in higher education based on qualitative requirements, not quantitative, through independent accreditation institutions. To achieve success, universities need to be autonomous; in these proposals, government intervention exceeding the current amount will not ensure success. I don’t know any country where there has been an attempt to set the minimum number of students in order to be referred to as a university.”

Both national and international examples show that smaller universities can create competitive educational programs, foster student success, and achieve high employment outcomes. These institutions use flexible management, quickly adapt to labor market needs, collaborate closely with employers, attract top faculty, and offer student-centered services. For instance, the American University of Armenia had around 300 students before introducing bachelor’s degree programs. Yet, despite its small size, it developed innovative programs with international appeal, leading to strong job placement rates for graduates in Armenia and abroad.

Conversely, several larger Armenian universities (those with over 4,000 students) to stay competitive, update curricula, and align their programs with job market needs. Many of their graduates face unemployment. Official statistics from December 2023 show that 12% of the unemployed have higher or postgraduate degrees. This highlights that a university’s size does not guarantee educational relevance or graduates’ success in finding jobs.

Despite mergers over recent decades, the European Higher Education Area (EHEA) still boasts diverse universities of various sizes and forms. According to the European Tertiary Education Register, EHEA universities are categorized as follows: 

• 8% are very small to small institutions (up to 500 students) 
• 26% are small (500-2,000 students) 
• 42% are medium-sized institutions (2,000-20,000 students) 
• Out of the 10 higher education institutions, only one is large (with over 20,000 students) 
• 2% (40 universities) are very large (over 50,000 students) 

Notably, one Turkish institution, Anadolu University, has over 2,000,000 students. The optimal size of a university, however, varies depending on its type and mission.

Requiring universities to meet a minimum student enrollment for licensing undermines their autonomy, forcing them to prioritize meeting quantitative targets over pursuing their strategic goals. This focus on numbers can stifle educational innovation and restrict the growth of universities with diverse missions. For instance, it may impede research-oriented institutions that generate knowledge and student-centered institutions that transmit it. This requirement could reduce the inclusion of various groups through alternative education models.

Universities offering specialized programs or teaching in small, focused cohorts—such as those in the fields of arts and culture, as well as regional, private, and interstate institutions—struggle to meet the 4,000-student threshold. Our research shows that none of these types of universities in Armenia currently meet this requirement, which would hinder the creation of modern, specialized institutions. These limitations contradict the evolving educational trends seen in advanced countries.

Armenia’s Statistical Committee reports 53 active higher education institutions in the country, including public and private universities, with 42 located in Yerevan. In comparison, Estonia, with a population of approximately 1.5 million, has 19 universities. These comprise six public research universities, one private research university, seven state professional higher education institutions, and five private, non-research institutions. The latter group focuses on innovative programs that blend theoretical knowledge with practical skills, emphasizing internships, close collaboration with employers, and student career development.

Estonia has one university ranked among the world’s top 500, while Armenia does not.

This comparison highlights key issues in Armenia’s higher education system: too many universities for its population, a concentration of institutions in Yerevan, and challenges with international competitiveness. These problems need urgent attention, but is the proposed solution the right one?

Armenia’s higher education system clearly needs substantial improvement. However, what conceptual frameworks and analyses support the proposed reforms? Is the chosen strategy based on proven international methods? Given that other countries have faced similar challenges, what alternative solutions might be more effective?

Moreover, is it prudent to adopt global models without careful assessment, especially when they could lead to significant financial, material, and human costs for Armenia in the long term?

We believe that emphasizing enlargement as a central policy goal risks undermining the quality and substance of higher education reforms in Armenia. This approach rests on the questionable assumption that “bigger is better.” Instead, Armenia should align with global trends by fostering an environment where institutions with diverse missions and goals can thrive.

A critical step toward this goal is differentiating quality standards for institutions with distinct missions. Licensing and accreditation requirements should clearly distinguish between “research universities” and “teaching universities” to meet both educational and economic needs. Research shows that larger research universities often rely heavily on teaching assistants, limiting students’ direct contact with professors and increasing dropout rates, especially among underrepresented groups. Smaller teaching-focused universities, by contrast, offer closer faculty engagement, hands-on skills development, and greater student involvement, which help reduce dropout rates. Notably, Armenia faces a significant dropout challenge, averaging 4,500 students leaving higher education each year, primarily due to poor academic performance.

We recommend exploring international practice and applying a more democratic toolkit that encourages mergers through incentives, rather than imposing them. These tools may include grants for infrastructure development, targeted programs, and privileges. For instance, in Poland, even public university mergers have been conducted voluntarily, using various incentives.

Location and Proportional Development of Universities: Academic City

Article 40 of the Law introduces the concept of an “Academic City,” a centralized hub that the government envisions as a focal point for higher education in Armenia. However, the proposed regulation effectively restricts universities from operating or expanding outside this designated area, stating:

“Establishing infrastructures of academic units of universities beyond the territory of the Academic City shall be prohibited, unless it is conditioned by the specific climatic or geographical characteristics of the infrastructure.”

This approach, which consolidates educational facilities into a single location, raises significant concerns. Establishing a monopoly on university development within the Academic City could hinder Armenia’s commitment to “proportional territorial development”—a principle protected under Article 86 of the Constitution, which identifies balanced regional growth as a core state objective. Policies like the Academic City, combined with measures such as the proposed minimum enrollment requirement of 4,000 students (which may lead to the closure of regional institutions), seem at odds with the government’s stated goals of equitable development. Instead of fostering diverse educational ecosystems across the country, this centralized model risks creating disparities and neglecting the unique needs of Armenia’s regions.

Is this approach genuinely supportive of the long-term goals of balanced development, or does it undermine regional growth in favor of a centralized vision?

Further research is essential to understand the impact on regional students who may be required to leave their communities for long stretches to study at the “Academic City” or alternatively, rely exclusively on vocational education. Evaluating the social, economic, and security implications of this shift could reveal unintended consequences for both students and their home communities. Additionally, it’s important to assess the effectiveness of current regional educational initiatives, such as those by the TUMO Center for Creative Technologies, the Children of Armenia Foundation (COAF), and various programs from the Ministry of Education, Science, Culture, and Sport. These initiatives aim to empower regional youth, foster local talent, and support broader regional development. What will happen to these valuable programs and the communities they serve if higher education becomes centralized? Understanding these dynamics is critical to shaping a balanced educational policy that genuinely supports all regions.

The elimination of regional universities—and the shift to a centralized Academic City model—directly contradicts the government’s own program priorities and may create serious national security risks. The weakening or closure of regional universities will likely accelerate urbanization over time, widening the existing gap between Yerevan and the regions.

In contrast to the untested concept of centralizing universities in one area, research such as the Lumina Foundation’s 2018 report shows that developing higher education institutions across regions is essential for including underrepresented groups and expanding access to higher education. Estonia, a country with a similar population, demonstrates this through its decentralized higher education model. Professional universities and University of Tartu branches are spread across various regions—Viljandi, Kohtla-Järve, Pärnu, and Narva—offering inclusive, profession-oriented education that meets local economic needs, while research universities remain in Tallinn and Tartu.

The proposed Draft Law, which aims to centralize universities in an Academic City and establish a minimum student enrollment requirements, would create new challenges for specialized public, regional, private, and interstate universities. This approach would limit students’ choices and reduce competition in higher education. Such changes are ill-suited to democratic countries with market-driven economies. International practice—as demonstrated in Estonia—shows that quality and global competitiveness in higher education can be achieved through qualitative standards alone, without imposing restrictive enrollment thresholds.

The proposed amendments require thorough reassessment in light of Armenia’s goals for balanced and sustainable development. Transforming the higher education system calls for a collaborative, research-based approach guided by international best practices. This approach should aim to expand access for all, especially underserved groups. Such a balanced strategy would support Armenia’s equitable socio-economic development and address demographic challenges sustainably. Higher education policy must be based on scientific evidence and the successful practices of other nations. This ensures that it not only strengthens the education sector but also contributes positively to Armenia’s socio-economic stability and national security. Experimentation in this crucial sector lacks justification and may lead to unintended long-term consequences.

The two aforementioned radical amendments in the Draft Law lack sufficient reasoning. As an alternative, we recommend considering and exploring the following possibilities:  

• At this stage, the Academic City should be viewed as a key initiative for developing infrastructure related to universities (including dormitories), research, technology, culture, regional connectivity, and transportation, without establishing a monopoly.
• The Academic City can serve as a framework for infrastructure development, attracting foreign investment and supporting grant organizations. Its development should be seen as a long-term (20-30 years) program, with a focus on creating an engaging, efficient environment and offering incentives, such as tax privileges, grants, government funding, and the establishment of a ‘free economic zone’ for startups. This approach would facilitate the country’s strategic goals in a more collaborative, participatory, and voluntary manner for universities.
• The Academic City should not hinder the development of university complexes in remote or border regions (e.g., Shirak and Syunik). Instead, it is essential to promote the dynamic growth of specialized higher education institutions in these areas. This should be done using innovative approaches that align with societal needs, economic demands, and national security concerns.
• For university enlargement and mergers, we recommend exploring international practice, and applying democratic tools instead of forcing and encouraging mergers through promotion (grants for development of infrastructures, target programs, tax privileges, etc.). Imposing a management model on non-government-established, privately funded educational institutions––a direct result of setting minimum student numbers–– will reduce diversity in the system. This approach threatens specialized universities, interstate institutions, private colleges, and teaching and research universities. It will limit the management flexibility of interstate and private universities, hindering their ability to quickly adopt innovations and achieve dynamic growth, as it focuses solely on quantitative growth. Over time, this policy may lead to the elimination of specialized and regional universities. 
• When developing higher education policy, it is essential to distinguish between reforms for government-funded and private universities. State-funded institutions use public resources and receive significant government support, while private universities rely on private funding. Both must meet minimum quality standards and have legal equality and fair competition ensured. However, different approaches are needed for defining missions, assessing public responsibility, regulating financial management, and determining locations—including licensing requirements for minimum student numbers and Academic City operations. This differentiated approach is crucial for leveraging the potential of different universities and ensuring a balanced, high-quality higher education system. It is important to recognize that strategies effective for public universities may not suit self-financing institutions, including private, interstate, and international universities, as applying a one-size-fits-all model could undermine the private university system.

We want the key objectives of higher education reforms in the country to ensure quality through free competition. This approach is preferable to over-centralization of territories and management of higher education at any cost—a strategy that could have severe consequences and further slow the development of higher education.

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