Armenia may be attractive to foreign investors in the iGaming sector as a country with an active technological infrastructure in the region. However, iGaming licensing in Armenia and obtaining an internet gambling licence should not be regarded as a simple or low-cost way to enter the international market.
Rather, Armenia’s iGaming regulatory framework should be viewed as a relatively strict licensing regime, where requirements related to state fees, KYC/AML procedures, domain structure, advertising restrictions, and new legislative changes (hereinafter also referred to as the “New Law”) may create practical challenges for investors.
In Armenia, gambling, internet gambling, and casino activities may be carried out by commercial organizations registered in Armenia based on the relevant licence. In the case of internet gambling, activities may also be conducted based on the right to accept bets.
Armenian gaming law establishes specific compliance requirements for iGaming businesses, and foreign investors should conduct legal due diligence before entering the Armenian market.
1. Product classification must be determined before filing the licence application
The first question for a foreign investor should not only be “how to obtain a licence,” but also “which activity requires a licence.”
Armenian regulations distinguish between internet gambling, bookmaker activity, lotteries, and other types of gaming activities.
Under the New Law, a separate licence is required for each type of gaming activity, while bookmaker activity is regulated separately from internet gambling.
This is particularly important for investors planning to combine casino games, live casino, sportsbook, betting, or other hybrid products on a single platform.
An internet gambling licence alone is not sufficient to conduct bookmaker activity.
Accordingly, the product structure and classification should be legally determined before submitting the licence application. Otherwise, the investor may face additional licensing requirements, business restructuring, delays, or potential liability risks.
Proper product classification is one of the most important stages of obtaining an iGaming licence in Armenia.
2. The licence is indefinite, but the financial burden is continuous and increasing
An internet gambling licence is issued for an indefinite term. However, maintaining the licence requires significant annual state payments.
As of the date of this publication, the annual state duty amounts to AMD 600,000,000.
In addition, an internet gambling operator must obtain the right to accept bets.
For each AMD 100 billion in accepted bets, the state duty is calculated as the product of 175,000 times the base duty, amounting to AMD 175,000,000, multiplied by the applicable coefficient.
The coefficients are established as follows:
- 2.0 from 1 April 2025;
- 3.0 from 1 January 2026;
- 4.0 from 1 January 2027;
- 5.0 from 1 January 2028.
The duty must be paid by the fifth business day following the date on which the relevant threshold is reached. The payment is not refundable if the acquired right is not used.
In practical terms, this means that investors must calculate in advance not only the cost of an Armenia iGaming licence, but also the fees connected with betting volume.
Under this system, costs are directly linked to the amount of accepted bets rather than only to profit or margin.
Therefore, high-turnover but low-margin business models require specific financial stress testing before entering the Armenian market.
3. The “.am” domain and website structure are key components of the licensing framework
The New Law also provides that internet gambling may only be organized through the official website and gaming applications specified in the licence.
Operating through websites or applications that are not listed in the licence may be considered conducting licensable activity without a licence.
For foreign investors, this means that the domain strategy, brand strategy, and website or application structure must be planned in advance.
An operator licensed in Armenia may provide services to non-Armenian residents; however, this must be done under the same brand name and through the “.AM” domain.
A new domain may be considered a new website and may therefore require separate licensing.
Therefore, when entering the Armenian iGaming market, investors must consider not only obtaining a gambling licence, but also properly structuring the technical and legal infrastructure of the business.
4. An Armenian licence is not an international “passport”
In substance, Armenian legislation does not establish a general prohibition preventing an internet gambling operator licensed in Armenia from providing services to foreign players.
However, this does not mean that an Armenia gambling licence automatically authorizes services in every jurisdiction worldwide.
Investors must separately assess the regulations of the countries where players are located or where they are considered residents.
This issue is particularly important from the perspective of:
- marketing activities;
- payment routing;
- player onboarding.
Even where the activity is legally licensed in Armenia, violating the laws of the target jurisdiction may create legal risks in that country.
Accordingly, Armenian iGaming licensing should be viewed as the legal basis for operating from Armenia, rather than as a worldwide authorization.
5. KYC and payment models for foreign players must be structured before launch
Armenian law requires operators, before granting access to internet gambling services, to identify customers and register their information in order to prevent participation by persons under the age of 21.
In addition, customers conducting transactions exceeding AMD 1 million must undergo identification procedures, and the operator must create and maintain a database containing their information.
The payment model for foreign players is subject to specific requirements.
Under the current legal framework, deposits into special gaming accounts, bets, and payment of winnings must generally be carried out through non-cash transactions in Armenian drams.
Foreign currency may be used where:
- the player is not an Armenian citizen;
- the residence address provided by the player is outside Armenia;
- the transaction is conducted from a non-Armenian IP address;
- the payment is not made through a bank or payment and settlement organization licensed by the Central Bank of Armenia.
In addition, gaming accounts must be funded through a bank account or card belonging to the player.
Where Armenian bank accounts or cards are used, the operator must verify ownership according to the established procedure.
Certain exceptions apply to accounts and cards issued by foreign banks; however, these exceptions do not eliminate the need to manage AML/KYC compliance risks.
6. The New Law introduces additional capital, certification, and operational requirements
The New Law introduces additional capital, certification, and operational requirements that foreign investors should carefully consider before entering the Armenian iGaming market.
The principal provisions of the New Law will become fully applicable on the day following the completion of the sixth month after the selection of the gaming sector regulatory Operator. Licences issued before that date must be brought into compliance with the requirements of the New Law within six months thereafter. Failure to comply with these requirements may result in the relevant licences being deemed terminated.
The New Law also requires an internet gambling organizer, throughout the validity period of the licence, to maintain a deposit in a bank operating in Armenia equal to twice the amount of the annual state duty. This requirement creates an additional financial obligation for licensed operators and should be included in the investment planning and compliance strategy.
In addition, gaming products must have certificates of conformity. For gaming products where winnings are determined through random number generators, the minimum programmed total payout must be 90 percent.
The new regulatory framework also establishes important staffing and operational requirements. Gaming operations must be carried out by individuals holding valid operational certificates. The Operator will have a central role in issuing certificates of conformity or verifying the authenticity of certificates issued by international laboratories.
For foreign investors, these requirements mean that regulatory compliance should be considered not only during the licensing process but also throughout the entire operational period of the business. Proper preparation of internal compliance procedures, technical systems, employee certification processes, and operational controls is essential for maintaining an Armenian iGaming licence.
7. Advertising should be treated as a separate compliance risk
Advertising of gambling, internet gambling, casinos, and their organizers is strictly restricted under Armenian legislation. Therefore, advertising compliance should be considered as a separate legal risk when developing an iGaming business strategy in Armenia.
The current law prohibits advertising through methods not expressly permitted by law, the display of money or images of minors, messages directed at minors, and any content that creates the impression of regular or guaranteed income from gambling activities. Advertising materials must also include a warning regarding the risk of financial loss.
For foreign investors planning international marketing campaigns, it is important to consider two regulatory layers: the rules of the target country and Armenian advertising regulations.
Even where advertising is directed primarily at foreign markets, accessibility from Armenia may create additional compliance considerations. Therefore, operators should evaluate advertising channels, digital marketing strategies, affiliate programs, and promotional campaigns from both Armenian and foreign regulatory perspectives.
A properly structured advertising compliance policy can help reduce regulatory risks and ensure that marketing activities remain aligned with Armenian gambling legislation and the requirements of foreign jurisdictions.
Conclusion
Armenian iGaming licensing may present opportunities for foreign investors seeking to establish operations in a technologically developing regional market. However, entering the Armenian internet gambling sector requires detailed legal analysis, regulatory planning, and comprehensive due diligence.
Before beginning the licensing process, investors should have a clear product classification strategy, a financial model covering state duties and betting-related thresholds, a properly structured “.AM” domain and brand strategy, a KYC/AML compliance framework, a payment architecture, a legal assessment of target jurisdictions, and a plan for meeting the capital, technical, and operational requirements introduced by the New Law.
Successful market entry depends not only on obtaining an iGaming licence in Armenia but also on ensuring that the entire business model is properly structured at the intersection of Armenian legislation, international market requirements, and the evolving regulatory framework of the gaming industry.
LSA Law Firm provides legal support in the iGaming sector, assisting foreign investors with licensing, compliance, gaming regulation, and business structuring in Armenia.
