EY Law Alert: Amendments Affecting Electronic Signing of Employment Contracts

Facts

Subject:

Amendments Affecting Electronic Signing of Employment Contracts

Overview:

Following the EY Law Alert regarding the transition to electronic employment contracts in Armenia dated 15 January 2025 (available at the following link: https://www.ey.com/en_am/technical/tax-and-law-alerts/transition-to-electronic-employment-contracts-in-the-ra), the RA National Assembly adopted, at the second reading and in full, amendments to the RA Law “Labor Code” on 13 February 2026.

These amendments introduce significant updates to the system for the electronic signing of employment contracts and aim to ensure uninterrupted establishment of employment relationships for individuals experiencing difficulties with electronic digital signatures, considering that not all citizens currently possess identification cards. The amendments will enter into force on the day following their official publication after signature by the RA President.

Key changes:

1. Extended Deadline for Mandatory Use of the Digital System: The mandatory execution, amendment, and termination of employment contracts exclusively through the digital system is postponed from the currently established date of 1 January 2026 to 1 July 2027. Until then, the use of the digital system remains voluntary, and contracts, agreements and orders executed through the system will have full legal force.

2. Transitional Regulation: A transitional regulation has also been introduced, pursuant to which the amendments extending the deadline will apply to employment relationships arising after 1 January 2026. In other words, this approach ensures that if, after 1 January 2026, employers and employees have concluded employment contracts in paper form, employees will retain their labor rights, no liability will be imposed, and such contracts will remain legally valid.

3. Extended Deadline for Mandatory Upload of Existing Contracts: The deadline for the mandatory upload of existing employment contracts into the digital system, previously set for 31 December 2026, has been extended to 30 June 2028.

4. No Digital Requirement for Remote Workers Abroad: For individuals located outside Armenia (i.e., where remote work will be performed outside Armenia), the conclusion, amendment, and termination of employment contracts will not be processed through the digital system and will instead be carried out in paper form (including after 1 July 2027), taking into account that persons not present in Armenia cannot obtain an electronic digital signature.

5. Paper Contracts Permitted for Certain Categories in Armenia: Even after 1 July 2027, employment contracts with foreigners, refugees and asylum seekers present in Armenia may be concluded in paper form, provided that within three months after obtaining a document confirming lawful residence in Armenia, the executed contract is entered into the digital system for employment contracts.

Conclusion:

The amendments introduce important changes to the framework governing electronic signing of employment contracts in Armenia. By extending implementation timelines and clarifying the rules applicable to foreigners and individuals working remotely from outside Armenia, they provide additional flexibility for employers and employees facing electronic signature challenges during the transition period.

Who’s Affected:

• Employers intending to hire foreigners in Armenia;
• Foreigners, refugees and asylum seekers intending to work in Armenia;
• Individuals who will work for Armenian employers where the work will be performed remotely outside Armenia.

How can EY help?

EY Law is prepared to provide comprehensive support to employers during the transition to the electronic signing of employment contracts in Armenia.

• Consultations: Offering in-depth consultations to address specific legal questions or challenges that may arise during the implementation of electronic employment contracts, ensuring that your company is well-informed and prepared.
• Implementation Support: Considering that this process can still be carried out on a voluntary basis, we are ready to review employment contract templates currently used in your company and, based on such review, advise on the required changes and develop a guide that will enable new employment contracts to be easily executed and existing ones to be entered into the system.

For more information or to discuss how EY Armenia can support your organization, please reach out to EY Law. Our team is ready to assist with navigating the updated electronic employment contract requirements and ensuring compliance.

Contacts

Inquiries may be directed to either of the following executives:

Alexey Markov | Partner | Head of Law Practice in Armenia
EY Armenia
Vazgen Sargsyan 2, Kamar Business Center, 0010, Yerevan, Armenia
Office: +374 (60) 50 7777
Alexey.Markov@am.ey.com

Kamo Karapetyan | Partner | Head of Tax Practice at EY in Armenia
EY Armenia
Vazgen Sargsyan 2, Kamar Business Center, 0010, Yerevan, Armenia
Office: +374 (60) 50 7777
Mobile: +374 (99) 88 67 00
Kamo.Karapetyan@am.ey.com  

Grigor Grigoryan | Senior Manager | Law Practice in Armenia
EY Armenia
Vazgen Sargsyan 2, Kamar Business Center, 0010, Yerevan, Armenia
Office: +374 (60) 50 7777
Mobile: +374 (77) 55 97 55
Grigor.Grigoryan@am.ey.com

Hrach Harutyunyan | Manager | Tax & Law
EY Armenia
Vazgen Sargsyan 2, Kamar Business Center, 0010, Yerevan, Armenia
Office: +374 (60) 50 7777
Mobile: +374 (44) 80 80 06
Hrach.Harutyunyan@am.ey.com