by Manishak Baghdasaryan
In the name of “regulation”, governments across the world are tightening their grip on media under the pretense of national security, morality, or sovereignty. Armenia is now preparing to join this expanding club of “digital dictatorships” with a new legislative proposal targeting audiovisual media.
The proposed amendments to the “Law on Audiovisual Media” (currently under public discussion) appear, at first glance, to align with responsible media governance: prohibiting hate speech, incitement to violence, and pornography. But looking at it closer, this is a calculated expansion of state control and legal ambiguity that collectively threaten freedom of expression, editorial independence, and Armenia’s already fragile media pluralism.
Vagueness as a Tool for Suppression
One of the most concerning aspects of the draft is its vague language. The bill would prohibit broadcasting content that “aims to overthrow the constitutional order by force” or “promotes war.” But who defines what constitutes “promotion of war”? Will critical coverage of ongoing conflicts, government failures, or even controversial opinions about policies fall under this?
Of course such open-ended terminology is not accidental, it is a strategy. Vague legal language would grant authorities power to selectively enforce law, punishing undesired speech while preserving the illusion of legality. This tactic mirrors similar strategies in authoritarian regimes, where the line between “safeguarding national security” and criminalizing opposition is blurred.
Regulating the Regulators
The bill emphasizes empowering the Television and Radio Commission (TRC) with new oversight and enforcement mechanisms. Of course, while regulatory bodies are crucial for democratic media governance, it becomes an issue when they experience “regulatory capture”, meaning the authority that’s supposed to regulate the industry in the public interest, ends up serving the interests of the government. This leads to digital authoritarianism.
In practice, the TRC’s independence has long been questioned. Under the proposed law, the commission would gain the authority to grant or deny broadcasting rights to foreign and domestic distributors based on vague content assessments, including “impact on the citizen’s mental health” and “manipulation of public behavior.” This is hardly regulation, but rather content control disguised as protection.
Foreign Media Under Lock and Key
A separate clause mandates that all foreign audiovisual programs undergo pre-broadcast review by the TRC to ensure compliance with Armenian law. While some countries apply similar policies to counter foreign propaganda, Armenia’s proposal grants near-unilateral discretion to the commission. Programs can be denied or halted on grounds as vague as “ownership change” or “political shift.”
Such gatekeeping over international content risks reducing Armenia’s media landscape to an echo chamber. It also raises significant concerns about censorship of foreign perspectives, particularly those critical of the Armenian government or sympathetic to opposition movements.
Control of Information Flow
The law also directly targets distributors and network operators, imposing licensing constraints, punitive fines, and even temporary license suspension for non-compliance. Distributors must submit every new content contract for approval, and network operators can be shut down for up to 30 days for technical or procedural “violations.”
This is a classic pattern in digital authoritarianism: when you control the infrastructure, you control the flow of information. Just as Azerbaijan maintains strict state control over internet infrastructure and suppresses dissenting voices through licensing and censorship, Armenia’s government now appears to be adopting a similar strategy, to monitor and discipline every part of media transmission.
“National Security” with Authoritarian Consequences
The government justifies these changes by citing Armenia’s “information sovereignty,” a phrase used worldwide to rationalize surveillance, censorship, and media control. While media regulation is not inherently authoritarian, the context and implementation matter.
In Armenia’s case, the backdrop is worrying. Independent media are under pressure– especially with some even being evicted from their headquarters– courts remain politicized, and public trust in state institutions is eroding. In this climate, giving a politically vulnerable regulatory body vast authority to define and punish “harmful” content creates an effect that risks silencing both journalists and citizens, this way, the government is exploiting digital regulation to consolidate power and suppress dissent.