EY Law Alert: Amendments to the RA Law “On foreigners”

Facts

Subject:

Amendments to the RA Law “On foreigners”

Overview:

On 20 January 2026, the Armenian Parliament adopted amendments to the RA Law “On foreigners” which will enter into force on 1 November 2026. The legislative package aims to digitalize residence status procedures, strengthen monitoring and control over the flow of foreigners into Armenia and address existing legislative gaps.

Key changes/Implementation Details:

1. Transition to a fully digitalized system. The entire process of applying for and granting residence statuses will be conducted through a unified electronic platform. The only exception is that, once the status is granted, the foreigner shall receive the residence card in person.

2. Changes to the types of residence statuses. Currently, three types of residence status exist: temporary, permanent and special. Under the amendments, the special residence status will be abolished as the grounds for permanent and special residence statuses overlap. However, individuals who have already obtained special residence status will continue to benefit from it until its expiration. 

3. Amendments to the grounds for permanent residence status.

• New grounds for obtaining permanent residence are introduced: investment in the RA and exceptional services rendered to the RA.
• At the same time, the existing ground for obtaining permanent residence based on family ties has been revised and made more stringent. While this ground still requires the cumulative fulfillment of several conditions, those conditions are now more restrictive. In particular, the scope of qualifying family members has been narrowed to a spouse, parent or child who is an Armenian citizen. Also, the residence requirement has become stricter: instead of general residence in Armenia for at least three years, the applicant must now have held temporary residence status for at least three years within the preceding five years.
• New requirements are also introduced for permanent residence based on entrepreneurial activity. A foreigner shall have held a temporary residence status for at least three years within the preceding five years. 

4. Financial thresholds for entrepreneurial activity. A foreigner may obtain temporary or permanent residence status based on entrepreneurial activity, provided that the foreigner:

• Is a shareholder/participant in an Armenian commercial company or securities holder, and has invested at least AMD 2 million in charter capital of a commercial company or has acquired stocks/securities of the same value; or
• Is an individual entrepreneur and has at least AMD 1 million in their accounts or demonstrates business turnover of AMD 1 million (or equivalent foreign currency) within the 60 days preceding the application date.

After residence status is granted, compliance with ongoing financial requirements is required. A residence status granted on the basis of    entrepreneurial activity may be deemed invalid if:

• the investment in the charter capital of a commercial company is withdrawn or reduced below AMD 1 million;
• the value of stocks/securities falls below AMD 1 million; or
• within 180 days after the residence status is granted, the database of the RA State Revenue Committee contains no information on taxes assessed from entrepreneurial activity.

However, the residence status will not be deemed invalid if the foreigner:

• at the time of withdrawal of the charter capital has made an equivalent investment in another Armenian commercial company; or
• withdraws and reinvests the capital within one month in the charter capital of another Armenian commercial company.

5.  Introduction of a quota system. A new system will operate, under which only a predetermined by the RA Government number of foreigners will get residence statuses throughout a year. Once the quota is exhausted, the application on granting a residence status will be declined. This amendment explains the elimination of the residence status extension procedure: upon residence status expiration, the foreigner must submit a new application and restart the process. At this stage, however, the annual quota has not yet been determined, as the relevant governmental acts have yet to be adopted.

6. Changes to the concept of work permit and its exceptions. The term “work permit” is replaced with “permit to stay or reside in the RA for the purpose of employment” (the “Permit”). Under the amendments the Permit entitles foreign nationals to (i) obtain a work entry visa (further detailed) or (ii) obtain temporary residence status or (iii) work in the territory of RA during their lawful stay. 

The list of exceptions from the Permit has been revised. Under the currently effective legislation, founders and directors of commercial organizations in the RA with 50% or more foreign participation are exempt from the requirement to obtain a work permit. This exemption has now been abolished. Additionally, the exemption previously granted to employees of foreign commercial organizations working in the RA through their branches or representative offices has also been also abolished.

7. New visa category. A new visa category is introduced – a work entry visa which may be issued for single or multiple entry for up to 120 days without the possibility of extension, and may be granted only once per calendar year, for the following three purposes:

• short-term employment in the RA (up to 120 days);
• filing an application in the RA for temporary residence on the basis of employment; or
• obtaining a document confirming temporary residence granted on the basis of employment.

Foreigners who enter the RA with an entry visa other than a work entry visa and intend to apply for temporary residence on the basis of employment must first change the visa type to a work entry visa; otherwise, the application for temporary residence will be refused.

8. Revision of the grounds for invalidation and annulment of residence status. The grounds for invalidation and annulment of residence status have been revised. Under the legislative amendments these grounds are clearly differentiated, eliminating ambiguities and gaps in the current legislation.

9. Increase in state fees. Under the new approach, if an application for residence status is declined, the state fee will no longer be refunded, as the fee covers the entire application review process, not the granting of the residence status itself. In addition, state fee amounts are increased as follows:

• temporary residence: AMD 150,000 (currently AMD 105,000);
• permanent residence: AMD 250,000 (currently AMD 140,000).

Benefits: 

• Digitalization of processes: The transition to a fully digitalized system streamlines the application process, making it more efficient and accessible.
• Elimination of legislative gaps: Ambiguities and gaps relating to, inter alia, the process and grounds for the invalidation and annulment of a foreigner’s residence status have been removed.

Challenges: 

• Higher financial thresholds: The increase in the minimum investment requirement may deter potential applicants who cannot meet the new financial criteria.
• Quota system and abolition of certain Permit exemptions: The introduction of a quota system may limit the number of foreigners eligible to obtain residence status, leading to increased competition and uncertainty. In addition, employers may face challenges in hiring foreign workers due to the quota system and the abolition of certain exemptions.

Conclusion:

The amendments significantly reshape the RA’s migration and residence framework by introducing full digitalization, stricter eligibility criteria, financial thresholds and a quota-based system. While existing inconsistencies and legislative gaps are addressed, foreigners will need to reassess their eligibility for residence status and ensure compliance with the new regulations, effective 1 November 2026.

This alert does not cover all novelties proposed under the amendments, given their breadth, focusing instead on the most significant regulatory changes.

Who’s Affected:

• Employers intending to hire foreigners in the RA.
• Foreigners intending to reside or work in the RA.

How can EY help?

The amendments to the RA Law “On foreigners” require careful legal assessment and planning by foreigners, investors, employers and employees operating in the RA. EY Armenia offers integrated legal support to help clients navigate the new migration and residence framework.  EY will continue monitoring upcoming developments, in particular adoption of secondary governmental acts and will keep clients informed.

For more information or to discuss how EY Armenia can support your organization or individual circumstances, please contact EY Law. Our team is ready to assist you in navigating the new regulatory environment with confidence.

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