EU Progress Report Maps Armenia’s Path Toward Visa Liberalization

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While obtaining Schengen visas remains a difficult, and often frustrating process for many Armenians, the European Commission has published its first progress report on Armenia’s implementation of the Visa Liberalization Action Plan (VLAP) following the EU-Armenia Summit. Armenia’s Interior Ministry later released the document publicly, while the Commission also submitted it to the European Parliament and the EU Council.

To eventually secure visa-free travel for its citizens, Armenia must implement reforms across four key areas: document security, including biometrics; integrated border, migration and asylum management; public order and security; and external relations and fundamental rights.

Block 1: Document Security, Including Biometrics 

Armenia has made significant progress in overhauling its document security and identity management systems under VLAP. Authorities have adopted a new Law on the State Population Registry, launched reforms to introduce a unified digital population database and moved toward issuing International Civil Aviation Organization (ICAO)-compliant biometric passports and identity cards. The first biometric documents are expected in the second half of 2026, while the new State Population Registry is scheduled to become fully operational in 2027. 

These reforms aim to create a single, secure system for managing personal identification and civil status data, while bringing Armenia’s passport and identity infrastructure closer to European and international standards. As part of this process, Armenia has also signed a public-private partnership agreement to implement a nationwide biometric identification system and is preparing to join the ICAO Public Key Infrastructure (PKI)/Public Key Directory (PKD) system, which would allow authorities to verify the authenticity of electronic passport chips during border checks. 

At the same time, the report identifies several remaining shortcomings. Armenia has not set a deadline to fully phase out older, non-ICAO-compliant passports, and accession to the ICAO PKI/PKD system is still pending. Until that process is completed, Armenian authorities cannot reliably authenticate the chips embedded in foreign biometric passports during border checks. The report also notes that a centralized certificate management infrastructure for border and migration authorities has yet to be established. 

Gaps in oversight and accountability within Armenia’s document issuance and civil registration systems also persist. Although integrity and anti-corruption rules formally exist, the report says there is limited evidence of dedicated operational procedures to investigate misconduct, systematically document violations or mitigate corruption risks linked to civil status registration and document issuance. 

Block 2: Integrated Border Management, Migration Management and Asylum

Armenia has made uneven but notable progress in the second block of reforms covering integrated border management, migration and asylum policy. Over the past two years, Armenian authorities have gradually assumed greater control over border security. Armenia’s National Security Service and Border Guard Troops are now fully responsible for border checks at crossings with Georgia and Iran, as well as at the country’s international airports. Armenia has also laid the groundwork for an Integrated Border Management strategy for 2026–2029 with EU support, while reforms aimed at modernizing migration governance and asylum procedures are underway. 

The report highlights substantial progress in migration management. In 2024, Armenia established the Migration and Citizenship Service under the Interior Ministry, accelerated the digitalization of citizenship, residency and migration services, and adopted legislation to create a unified State Population Registry that will also include foreign residents. Electronic citizenship procedures are already operational, while the digitalization of work and residence permits is expected to enter into force in 2026. 

The report also notes Armenia’s efforts to manage the aftermath of the displacement of Armenians from Nagorno-Karabakh. Temporary protection status for more than 115,000 displaced Karabakh Armenians was extended through the end of 2026, while more than 34,000 people had acquired Armenian citizenship under expedited procedures by mid-March 2026. Armenia has continued developing reintegration programs for returning citizens and diaspora Armenians through state-backed and donor-supported initiatives. 

On asylum policy, Armenia is preparing legislative amendments to bring the system closer to EU and international standards. Authorities are also developing an Electronic Asylum Case Management System, strengthening border referral mechanisms, and constructing a new temporary accommodation center for asylum seekers near Yerevan. 

At the same time, the report identifies major structural shortcomings in border management. Border-related law enforcement bodies still operate largely separately, with limited interagency coordination and no systematic mechanisms for intelligence sharing. Operational responses remain fragmented, and a dedicated legal framework for inter-agency cooperation has yet to be adopted. International cooperation involving Armenia’s Border Guard Troops is also at an early stage, while the country’s broader Integrated Border Management strategy and training reforms are still being developed. 

Migration management reforms also remain incomplete. Armenia’s system for detecting irregular migrants is largely reactive, with weak analytical capacity, limited risk-based targeting, and low enforcement rates for return and expulsion decisions. A comprehensive national migration strategy for 2026–2031 remains in draft form. 

The report also points to continuing gaps in Armenia’s asylum system. Amendments to the Law on Refugees and Asylum have not yet been adopted, the Electronic Asylum Case Management System remains in the preparatory stage, and the new temporary accommodation center for asylum seekers, expected to house up to 100 people, is still under construction. A separate draft law on stateless persons is also still being finalized. 

Block 3: Public Order and Security 

Armenia has made substantial progress in overhauling its public order, security and anticorruption frameworks in line with European and international standards. Since 2018, the country has expanded corruption-related criminal legislation, introduced criminal liability for legal entities, strengthened the powers of specialized anticorruption bodies, and launched broad reforms in policing, crime prevention and financial oversight. The report notes that Armenia is now party to the main international conventions on corruption, organized crime, money laundering, trafficking, and terrorism financing, and that cooperation with European institutions, including Europol, CEPOL and MONEYVAL has also deepened. 

The report highlights several institutional reforms already underway. Armenia established a Crime Statistics and Research Center within the Interior Ministry in February 2026 to strengthen analytical capacity and support evidence-based policymaking. Authorities are also drafting a national crime prevention strategy for 2026–2033 focused on cybercrime, domestic violence, youth crime prevention and intelligence-led policing. Armenia has additionally expanded integrity checks for judges, prosecutors and investigators; strengthened asset declaration requirements for public officials; and introduced new police integrity and disciplinary mechanisms. 

In the area of trafficking and organized crime, Armenia has continued to implement national action plans aligned with international standards, and has participated in regional and EU-backed initiatives targeting migrant smuggling and human trafficking. The report also points to reforms in anti-money laundering and counterterrorism financing, including updates to Armenia’s Anti Money Laundering (AML) legislation, a new national AML/CFT (Countering the Financing of Terrorism) strategy for 2025–2028 and tighter regulation of cryptocurrency transactions beginning in 2027. 

The report notes growing cooperation with Europol and CEPOL. Armenia’s liaison officer to Europol was deployed in April 2026, and Armenian law enforcement officials have participated in multiple EU-led training programs on cybercrime, trafficking, drug smuggling and organized crime. Authorities are also preparing major digital reforms, including a unified State Population Registry and a future electronic criminal case management system to modernize criminal investigations and improve coordination between agencies. 

Serious structural shortcomings remain, however. Data systems used by Armenian law enforcement agencies remain fragmented and poorly interconnected, and investigations are still largely reactive rather than intelligence-led. Armenia has not yet developed a national serious and organized crime threat assessment, and the country’s broader crime prevention strategy remains in draft form. 

The report also points to persistent weaknesses in Armenia’s anticorruption architecture. Although corruption convictions have increased, suspended sentences remain widespread, raising concerns about the deterrent effect of prosecutions. In 2024, only 37 individuals received prison sentences in corruption cases, while 185 received suspended sentences. The Corruption Prevention Commission is described as understaffed and lacking sufficient financial and legislative resources, and its integrity opinions can still be ignored by appointing authorities. The report further notes that Armenia’s Anticorruption Committee lacks a comprehensive strategic framework for investigating corruption in high-risk sectors, particularly cases involving senior officials. 

Asset recovery also remains weak. While Armenia has introduced civil forfeiture mechanisms, systematic tracing and recovery of illicit assets remain limited, and there is still no centralized asset recovery office. Despite formal whistleblower protections being in place since 2018, the report says no practical whistleblower protection cases have yet been recorded. 

On anti-money laundering oversight, tthe number of suspicious transaction reports and referrals to law enforcement remains relatively low. Armenia’s broader asset recovery framework also remains only partially aligned with EU standards. 

Armenia’s current Personal Data Protection Agency still operates within the Justice Ministry and therefore does not meet European standards for institutional independence. A new independent Data Protection Authority is planned, but is not expected to become operational until mid-2027. 

Block 4: External Relations and Fundamental Rights

On fundamental rights and external relations, the report notes gradual progress on anti-discrimination, minority rights, child protection and the integration of displaced Karabakh Armenians, while also highlighting major legislative and institutional gaps that remain. Armenia is preparing draft laws on discrimination and national minorities to align domestic legislation with European and international standards, alongside reforms in gender equality, justice and child protection. 

The report also notes that Armenia’s future digital identity and population registry systems are intended to include foreign nationals, stateless persons, refugees, and asylum seekers under the same framework as Armenian citizens. 

Armenia has also expanded protections for children and vulnerable groups. A new Law on Child Rights and the Child Protection System, adopted in 2025, introduces legal definitions for abuse, exploitation, neglect, and bullying, while broadening safeguards for children. Authorities have continued efforts to integrate more than 115,000 displaced Armenians from Nagorno-Karabakh through housing assistance, healthcare, access to education, and expedited citizenship procedures. More than 16,000 displaced children have enrolled in Armenian schools. 

The report highlights reforms that have been implemented to improve access to justice and advance gender equality. Armenia adopted a new gender policy strategy for 2025–2028 and a women, peace and security action plan in 2025. Judicial reforms have introduced electronic justice systems, mediation mechanisms, and additional safeguards in criminal proceedings, including mandatory video recording of interrogations and stronger protections for minors and persons with disabilities. 

Many regional offices responsible for issuing identity documents, however, are still inaccessible to persons with disabilities, and current procedures continue to create barriers for individuals with psychosocial or intellectual disabilities seeking access to civil registration and identity services. 

Several major legislative reforms also remain incomplete. Draft laws on anti-discrimination and national minorities have not yet been adopted by Parliament, and Armenia has yet to ratify the Istanbul Convention on preventing violence against women and domestic violence. The government’s broader child rights protection program for 2024–2029 also remains pending approval, and no comprehensive strategy to combat child sexual abuse and exploitation has yet been adopted. 

The report also raises concerns about Armenia’s citizenship and justice systems. Although citizenship procedures have been partially digitalized, the current Law on Citizenship still grants broad discretionary powers in exceptional cases and contains ambiguities around dual citizenship rules. The continued extensive use of pre-trial detention also remains a major concern. As of October 2025, more than half of Armenia’s prison population consisted of pre-trial detainees, contributing significantly to prison overcrowding. 

The report further notes that Armenia’s 2023–2025 human rights strategy expired at the end of last year, while its replacement, expected to be incorporated into a broader justice sector reform strategy, has not yet been adopted. 

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Armenia must address the shortcomings and recommendations outlined in the first VLAP progress report before it can move to the next phase. Armenia and the EU expect the country to complete the required reforms by the end of the decade.

Overall, the first European Commission progress report concludes that Armenian authorities have shown strong political commitment to implementing the reforms required under the VLAP. Although the action plan was only recently presented to Armenia, many of the required reforms have already been launched or are in preparation.

The Commission will publish regular progress reports. Armenia’s implementation of the first set of benchmarks will be closely monitored by the Commission and EU member states before a decision is made on advancing to the second phase, which will assess how the reforms will be implemented in practice.

Meanwhile, as obtaining Schengen visas remains a stressful and frustrating experience for many Armenian citizens, the report notes a steady increase in the number of visas issued, and in the share of multiple-entry visas. In 2019, Armenian citizens received 51,000 Schengen visas, 34.8% of them multiple-entry. By 2024, that number had risen to 86,300, with multiple-entry visas accounting for 43.5%.

At the same time, the report identifies unfounded asylum applications by Armenian nationals in some EU countries as an ongoing concern, particularly cases linked to medical treatment. In 2024, 5,130 Armenians applied for asylum in the EU, compared to 5,240 in 2022. However, the report notes that asylum applications declined significantly in 2025, falling to 3,535. Armenian authorities expect the country’s universal healthcare insurance system, introduced in 2026, to further reduce asylum-related migration.

Among former Soviet states, Moldova, Georgia and Ukraine have already secured visa-free travel with the EU.

Moldova launched its visa liberalization dialogue in 2010, received its VLAP in 2011, and secured visa-free travel in 2014, making it the fastest country to complete the process. Georgia launched its dialogue in 2012, received its VLAP in 2013 and achieved visa-free travel in 2017. Ukraine formally launched the process in 2008, received its VLAP in 2010, and secured visa-free travel in 2017, after delays caused by major political upheaval and the outbreak of war following the 2014 Maidan Revolution.

The EU-Armenia visa liberalization dialogue officially began in September 2024. The VLAP was prepared by the Commission with support from EU member state experts, following two scoping missions to Armenia in February and April 2025, before being formally handed over to Armenian authorities in November 2025.

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