Fintech & payments regulation in Armenia (2026)
Fintech and digital payments in Armenia: licensing regime.
Armenia operates a functioning licensing regime for payment institutions and electronic money institutions, administered by the Central Bank of Armenia under the Law on Payment Systems and Payment Organizations. Three distinct licence categories exist, Payment Organisation (PO), Electronic Money Institution (EMI), and Money Transfer Organisation, with a two-month CBA review period. As of April 2026, a new, PSD2-aligned payment services law is under active development to modernise the framework for instant payments and real-time settlements.
Legal framework
Law of the Republic of Armenia on Payment Systems and Payment Organizations (HO-150, 21 Dec 2004, as amended); CBA Regulations 17/01-17/03 (payment org licensing), 16/1-16/2 (e-money); supervised by the Central Bank of Armenia (CBA)
Key points: digital payments & fintech in Armenia
Payment org licensing
Any legal entity wishing to provide payment services must first register with Armenia's State Register of Legal Entities and then obtain a CBA licence under Regulations 17/01-17/03. The CBA grants or rejects a licence within two months of receiving a complete application.
E-money / EMI regime
Instant payment rail, ArCa Pay
ArCa Pay, operated by Armenia Card CJSC (co-founded by commercial banks and the CBA), provides interbank instant transfers identified by phone number. Development began in 2023; Ameriabank, Evocabank, and Converse Bank are among early participants. The government approved a cashback scheme for cashless ArCa transactions in December 2025 to drive adoption.
Open banking, not yet mandated
No open banking or mandatory third-party API access framework is in force. The CBA joined the Global Financial Innovation Network (GFIN) in July 2025 and is running sandbox pilots on open banking, digital identity, and blockchain; a CBDC pilot is planned within 12-24 months.
New payment services law in development
As of April 2026, the CBA's Deputy Governor confirmed that a new Law on Payment Services is being drafted, explicitly drawing on European (PSD2-era) directives and targeting instant payments and real-time settlement coverage. The existing 2004 law remains in force pending enactment.
Crypto-asset service providers, new licensing
Timeline of decisions
- GuidanceCBA Announces Draft New Payment Services Law Modelled on EU Directives
The Deputy Governor of the Central Bank of Armenia disclosed that a comprehensive new Law on Payment Services is in development, benchmarked against PSD2/PSD3 and targeting instant payments, open banking, and real-time settlement. It would replace the 2004 foundational law and overhaul the licensing taxonomy for payment organisations.
ArmBanks.am
- Decision · officialCBA Joins Global Financial Innovation Network (GFIN)
The Central Bank of Armenia became a member of GFIN, gaining access to cross-border sandbox pilot projects and the regulatory experience of leading global authorities. Membership accelerates CBA's open-banking, digital-identity, and CBDC pilot agenda.
Central Bank of Armenia
- Guidance · officialCBA Launches Financial Sector Development Strategy 2024-2026
The Central Bank published its three-year strategic roadmap prioritising payment-system modernisation, universal QR, instant payments, strong authentication, and data interoperability. The strategy formalised a technology-neutral regulatory philosophy and set out planned CBDC pilots for the following 12-24 months.
Central Bank of Armenia
- LawLaw 'On Cashless Operations' Enters into Force, Mandating Electronic Payments
Armenia's parliament enacted restrictions requiring all transactions above AMD 300,000 (~$720) to be settled electronically, phased geographically from Yerevan (2022) to provincial towns (2023) and nationwide (2024). Zero cash thresholds applied immediately to government receipts, healthcare, education, and legal services to improve tax compliance and reduce illicit finance.
Armenpress (Official State News Agency)
- Decision · officialState e-Payments Portal Launched; CBA Grants Idram E-Money Licence
The Armenian government launched e-payments.am, enabling citizens to pay taxes, state duties, and over 1,500 government fees electronically via ArCa and MasterCard. Concurrently, the CBA issued Idram its first formal permission to issue electronic money, establishing the first regulated e-money institution in the country.
Government of the Republic of Armenia
- Law · officialLaw on Payment and Settlement Systems and Organisations Enacted
Armenia's foundational payment regulation created the legal basis for payment and settlement systems (PSSs) and organisations (PSOs), established CBA licensing authority over all PSOs, introduced settlement-finality protections, and set the supervisory framework still underpinning the sector today.
National Assembly of the Republic of Armenia
- DecisionArCa (Armenian Card) National Payment Scheme Founded by CBA and Commercial Banks
The Central Bank of Armenia and ten commercial banks, with USAID support, established ArCa as the country's domestic interbank card payment scheme. ArCa holds Licence No. 1 for payment-card processing and clearing and became the backbone of card acceptance infrastructure; 19 of 21 Armenian banks currently participate.
Wikipedia (citing ArCa corporate history)
Sources
- cba.am/en/payment-organizations-licensing
- parliament.am/law_docs/211204HO150eng.pdf
- cba.am/en/payment-system-operators-and-participants/
- cba.am/en/how-payments-and-transfers-are-executed/
- armbanks.am/en/2026/04/28/272559/
- cba.am/en/Publication/8687/
- en.armradio.am/2025/12/25/armenian-government-approves-cashback-scheme-for-cashless-
- cba.am/en/News/regarding-the-publication-of-certain-regulations-governing-th
- cba.am/en/board-documents/9430
- openbankingtracker.com/country/armenia
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Next topicOrientation, not legal advice: verify against the primary sources linked above. Last verified 24 May 2026. Methodology & how to cite · State of Technology Regulation 2026