EY Law Alert: Implementation of the Universal Health Insurance System

Facts

Subject:

Implementation of the Universal Health Insurance System

Overview:

The RA Law “On Universal Health Insurance” (Law) came into force on 25 December 2025. The legislation introduces a universal health insurance system aimed at providing equal access to high-quality healthcare services, medicines, and medical supplies, while improving the financial affordability of essential health services.

The reform seeks to enhance the overall quality of healthcare delivery, improve key public health indicators (including morbidity, mortality, and life expectancy), and promote social solidarity through a more sustainable and inclusive healthcare financing model.

Implementation Details:

1. Insurance mechanism: 

Insured individuals shall make monthly insurance contributions to the Universal Health Insurance Fund (Fund). For the purposes of this law, an insured event is when an insured person seeks medical care or services from or obtains medicines at a medical care and service provider or pharmacy that has signed a relevant contract with the Fund. Upon provision of services or medicines by such contracted entities, the Fund will make the corresponding payments directly to the medical institutions or pharmacies to cover the insured event.

Insured individuals will be entitled to receive bonuses that may be used to cover insurance premium payments, obtain medical assistance packages under voluntary health insurance, obtain gym or swimming pool membership and pay for medical services and assistance not covered by the universal health insurance. The bonus system will become effective upon the full implementation of the health insurance system in 2029.

The scope of medical services and medicines that are subject to reimbursement is available through the ArMed eHealth application and is easily accessible to individuals via their personal accounts.

2. Phased implementation timeline:

The universal health insurance system will be implemented gradually over three phases, with the objective that all RA citizens who are residents, as well as certain groups of foreign nationals holding a relevant residence status are covered by an insurance package by 2029.

Phase 1, effective from 1 January 2026

I.    Coverage is extended to the following groups:

• Individuals aged 0–18;
• Individuals aged 18–23 who have been left without parental care
• Individuals aged up to 26 who were left without parental care and are enrolled in on-site education;
• Individuals aged 65 and above;
• Individuals with disabilities of groups I, II and III; 
• Individuals with severe, moderate, or mild functional limitations;
• Former servicemen receiving a military disability pension;
• Individuals who participated in the liquidation of the consequences of the Chernobyl accident;
• Employees (including foreigners) with a monthly salary of AMD 200,001 (gross) and above;
• One of the parents, trustees, guardians or adoptive parents of a child with a disability;
• Families of missing or fallen participants in the April 2016 and September 2020 defense operations of the RA,
• Great Patriotic War veterans and persons equated thereto, repressed persons;
• Members of families classified as socially vulnerable;
• Individual entrepreneurs (including foreigners) and notaries whose gross revenue for 2025 is AMD 2,400,001 and above.

It should be noted that, for the above-mentioned individuals, the Law enters into force as of 1 January of the current year, with the exception of the individuals referred to in point (ix) above (i.e., individuals whose monthly gross salary is AMD 200,001 and above). For this group (individuals with a monthly salary of AMD 200,001 (gross) and above as of 25 December 2025), the Law enters into force on 25 December 2025, and deductions are made from the salary for December 2025 and subsequent months. With respect to these individuals, insurance contributions continue to be calculated in accordance with the procedure established by the Law, regardless of any reduction in salary during the subsequent 12 months.

Phase 2, effective from 1 January 2027

II.  Coverage will be expanded to include:

• Employees (including foreigners) with a monthly salary of up to AMD 200,000 (gross);
• Individual entrepreneurs (including foreigners) and notaries whose gross revenue for 2025 does not exceed AMD 2,400,000;
• Individuals performing work or providing services under civil law contracts;
• Individuals receiving royalties, rental payments, dividends
• Employees whose salaries are paid by persons or entities not recognized as tax agents.

Phase 3, effective from 1 January 2028

III. Coverage will further extend to:

• Mothers (including adopters) taking care of a child up to 2 years of age;
• One of the parents or guardians taking care of 3 or more minor children within the same family;
• Individuals (including foreigners) not included elsewhere and performing individual agricultural activities;
• Voluntary insurance coverage for individuals (including foreigners) affiliated with certain eligible groups.

Groups fully covered by the state:

The following categories will have their insurance premiums fully financed by the RA Government:

I.  All individuals included in Phase 1, except:

• employees whose monthly gross salary is AMD 200,001 or above; and
• individual entrepreneurs and notaries whose gross revenue for 2025 is AMD 2,400,001 or above.

II. The following individuals included in Phase 3:

• mothers (including adopters) taking care of a child up to 2 years of age;
• one of the parents or guardians taking care of 3 or more minor children within the same family.

Insurance premiums:

The insurance premium is set at AMD 129,600 per year and AMD 10,800 per month.

For employed individuals, the premium shall be paid directly by their employers acting as tax agents.

Conclusion:

Implementation of universal health insurance system marks a significant step toward ensuring equitable access to quality healthcare in the RA. The broad coverage of eligible groups ensures that by 2029 all RA citizens who are residents, as well as certain groups of foreign nationals holding a relevant residence status are guaranteed a coverage for their basic healthcare needs.

This alert does not cover all novelties proposed under the law, given their breadth. Accordingly, it focuses only on the most significant regulatory changes.

Who’s Affected:

1. Legal Entities: Employers engaging employees in the territory of the Republic of Armenia, particularly those with a monthly salary of AMD 200,001 (gross) and above, as well as those with lower salaries in subsequent phases.
2. Physical Persons: Individuals listed in Phases 1, 2 and 3 in the “Phased Implementation Timeline” section of this Alert.

How can EY help?

EY Law is prepared to provide comprehensive support to stakeholders during the implementation of the Universal Health Insurance System.

Our services include:

• Legal Assistance: Navigating the legal requirements related to the new health insurance system and advising on employer responsibilities regarding insurance premiums.
• Consultations: Offering in-depth consultations to address specific legal questions or challenges that may arise during the transition to the universal health insurance system.
• Compliance Support: Ensuring adherence to legal regulations associated with the new insurance system.

For more information or to discuss how EY Armenia can support your organization, please reach out to EY Law. Our dedicated team of legal professionals is ready to assist you in navigating this process.

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

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