The regulation of the IMEI system in Armenia should be based not on technological solutions, but on the quality of public administration and the depth of legal analysis. This opinion was expressed by Tigran Jrbashyan, Director of Ameria's Management Consulting Service, commenting on the draft law on the creation of a unified mobile device registration system.
According to him, the state has the right to combat smuggling, shadow imports, tax losses, and fake IMEI codes. However, the key question is not the goal of regulation itself, but the chosen model for achieving it and the consequences for the market and users.
The expert noted that different approaches are used in different countries. In most EU states, such tasks are solved through customs control, interaction of communication operators, the GSMA system, and criminal liability for IMEI counterfeiting, without mandatory registration of each device. At the same time, in EAEU countries – including Russia, Kazakhstan, Belarus, and Kyrgyzstan – state IMEI registries and mechanisms for restricting the operation of unregistered devices are being actively introduced.
Jrbashyan emphasized that the Armenian draft law is closer to the EAEU model, but no decisions of the Eurasian Economic Commission have been found that would oblige the union countries to implement such systems. In his opinion, this means that it is an independent national choice.
The expert also stated that the deeper the state interferes in the digital infrastructure and the device market, the higher the requirements for transparency, quality of analysis, and public discussion of the decisions made.
