New Restrictions: Anonymous Opinions Will Not Be Accepted

The Republic of Armenia's Ministry of Justice has put forward a draft governmental decision for public discussion on the unified platform for the publication of legal acts (e-draft.am), proposing that individuals and legal entities can submit their suggestions regarding the drafts exclusively through the "I Am" national identification platform.

In this regard, the Vanadzor office of the Helsinki Civil Assembly has expressed its views, stating, "Such a regulation significantly restricts citizens' ability to present their suggestions using the only current tool available for public discussion of legal act drafts. It is problematic that instead of implementing new tools and methods that would maximally ensure public participation when drafting legal acts, the state is moving towards limiting existing imperfect working tools and creating artificial obstacles."

The statement raises concerns about the lack of information regarding what percentage of the population can currently use the "I Am" national identification platform, which is one of the most pressing issues under discussion for this draft. The justification for the project states that the regulation aims to modernize electronic tools.

It should be noted that the ongoing reforms in the development of electronic tools should never supersede the state's obligation to actively engage citizens in the legislative process and consult with them on the adoption of laws and other legal acts.

Moreover, the regulation concerning the use of the system through the "I Am" national identification platform does not pertain to the exercise of the right to propose legislative initiatives via the platform—where an electronic signature might logically be required—but rather to the right to present opinions on legal draft acts and vote for or against them.

Additionally, there are many instances where individuals wish to submit their proposals regarding legal drafts anonymously. Therefore, considering that the proposed regulation will deprive a significant portion of the public of the opportunity to utilize the public discussion platform for legal draft acts, we suggest withdrawing the draft decision on amending the Government's decision No. 1146-N of October 10, 2018, from circulation.