FACTS
From December 10 to 24, 2025, the Staff of the RA National Assembly conducted the accreditation process of journalists covering the activities of the 11th session of the 8th convocation of the National Assembly. On December 12, Irina Danielyan, the editor of Gortsntats biweekly newspaper submitted a written application to the NA Chief of Staff, requesting accreditation for herself and Inara Danielyan from the same media outlet. The application was also accompanied by the documents required under the Regulation on Journalist Accreditation in the National Assembly (hereinafter also referred to as the Regulation), including a copy of Gortsntats biweekly and a statement from the state register of legal entities.
On December 24, 2025, Davit Arakelyan, the NA Chief of Staff, informed in writing that the data submitted by the media outlet failed to comply with the requirements of paragraph 8 of the aforementioned Regulation. He further indicated that pursuant to point 2 of paragraph 16 of the same Regulation, the accreditation application of the journalists of Gortsntats biweekly newspaper was subject to rejection. The written notice did not indicate which specific requirement of paragraph 8 of the Regulation the data provided by the editorial office failed to comply with.
The next day, on December 25, the Gortsntats editor sent another letter to Davit Arakelyan, requesting clarification on the grounds for the rejection of the application. In the same letter, Irina Danielyan drew the official’s attention to the fact that Gortsntats continued to be published on a biweekly basis, met all the criteria set out in the Regulation, and highlighted that the NA Staff had failed to observe the established deadlines for rendering a decision on accreditation. In particular, paragraph 15 of the Regulation stipulates that a decision on the application should be made within 5 days, recorded in the e-journal of journalists’ accreditation, and that the media entity should be officially notified within 3 days. Meanwhile, the established procedure was not followed: the rejection was sent 12 days after the submission, on December 24, the last day of the accreditation period.
On January 5, 2026, the NA Chief of Staff replied, stating, in particular, that the application submitted by the media outlet was not well-founded, and that the term “biweekly” was not identical to the term “weekly.”
On January 7, 2026, the head of the media outlet wrote to NA Speaker Alen Simonyan, raising a number of objections to the actions and justifications provided by the NA Chief of Staff. According to the editor, aside from the violation of the deadline for responding to the editorial office’s application, the NA failed to adopt a legal act—namely, a decision—on the denial of accreditation. Instead, the media outlet received an abstract notification indicating that “a rejection decision was issued,” from which it was unclear who had issued the decision and under what regulation.
In her letter to the NA Speaker, the editor also pointed out that the terms related to the media periodicity had been interpreted arbitrarily. According to her, the absence of a reference to biweekly periodicity in any act was regarded as a sufficient ground for rejecting the application. Meanwhile, as she emphasized, the legal meaning of the concept of “periodical” used in paragraph 10 of the Regulation is defined in the Law “On Mass Communication,” which establishes that a periodical must have a permanent name, an issue number, a publication date, and regular issuance, all of which were met by Gortsntats biweekly. Another argument raised by the editor was that the media outlet had faced discriminatory treatment. In particular, having acted in the same manner and submitted the same data, the newspaper had obtained accreditation for the sittings of the previous session of the National Assembly, which, in her opinion, indicated difference in treatment in a similar situation.
In a written response dated January 8, 2026, the NA Chief of Staff informed the media outlet that the accreditation of journalists in the parliament had been carried out on the basis of the Regulation, and that “no administrative action is carried out by the National Assembly” in this process. The letter further highlighted that an additional examination had confirmed compliance with the deadlines set for the accreditation rejection procedure.
CONCLUSION
Under Article 6 of the RA Law “On Mass Communication,” accreditation is defined as a right that public bodies are obliged to recognize. This implies that provided an application for accreditation has been submitted, and the applicant meets the requirements prescribed by law, public bodies must merely record (register) that right, rather than grant permission for it or reject it.
The substance of this article of the Law is also reflected in the Regulation on Journalist Accreditation in the National Assembly, which similarly establishes the institution of notification rather than that of permission. Paragraphs 8 and 10 of the Regulation set out a number of requirements, which, if met, oblige the competent authority to accredit journalists unconditionally.
The grounds for restricting the right to accreditation must conform to the three well-known principles for limiting freedom of expression: legality, legitimacy of purpose, and proportionality of the measures applied. Overall, accreditation should not be treated as a “license to work.” Under international law, the permission-based scheme in this process represents a disproportionate and unnecessary interference into freedom of expression and information.[1]
In the present dispute, the NA Chief of Staff informed the applicant outlet about the rejection of its accreditation application through an ordinary written note. This fact in itself constitutes an unlawful interference with the right to freedom of the outlet. The National Assembly must reject an accreditation application through the adoption of an administrative act, thereby carrying out the appropriate administrative procedure. This requirement has already been established by the RA Court of Cassation and the Administrative Court in a similar circumstance. In particular, in the case of journalist Knarik Manukyan, v. National Assembly Staff and its Chief, the Court of Cassation issued a precedent-setting decision on April 16, 2024 (No. VD/1751/05/24), establishing that the legal relations connected to the termination of accreditation are public in nature, rather than private. As a result, disputes related to these matters are subject to review in administrative rather than in civil courts, while the letter of the Chief of Staff of the National Assembly addressed to the journalist is considered an administrative act. In the same case, the RA Administrative Court, by its ruling of June 16, 2025, found that the state body had failed to fulfill its obligation to properly notify the individual about the administrative proceedings, had not conducted the ongoing stage of the administrative proceedings as prescribed by law, and had limited the administrative proceedings to the final stage only. As a result, the journalist’s right to be heard was not ensured. Thus, as a participant in the administrative proceedings, she was deprived of the opportunity to fully exercise the effective protection of her rights and freedoms.
In both the dispute concerning Gortsntats newspaper and the aforementioned case of Knarik Manukyan, the common problem lies in the fact that the NA Chief of Staff informed the parties in writing—rather than through the adoption of an administrative act—regarding the rejection of the media outlet’s accreditation application or, in the case of Knarik Manukyan, the termination of her accreditation. In other words, the decisions were not issued in accordance with the procedure prescribed by law. Specifically, the NA Chief of Staff clearly indicated in the letter sent to the founding director of the newspaper that “no administrative action is carried out by the National Assembly in this process.” Thus, the rejection of the media outlet’s application for accreditation in the NA occurred in violation of the RA Law “On Fundamentals of Administrative Action and Administrative Proceedings.”
From the perspective of legality, the fact that in an essentially identical situation the NA Staff, without any reasonable explanation or justification, treated the applicant outlet differently also raises concerns. As confirmed by Gortsntats, during previous sessions, the NA did not reject the accreditation applications of the newspaper’s journalists, even though the editorial office had provided the same data as in the current case.
With regard to the principle of proportionality, the Information Disputes Council considers it problematic that the NA Staff placed particular emphasis on contrasting the concepts of “biweekly” and “weekly.” Although the NA Staff, as an administrative body, enjoys administrative discretion in evaluating matters in its own manner, this discretion should not result in a restriction of the right of a media outlet to disseminate information and ideas. According to the Law “On Mass Communication,” what matters is that a media entity is issued with a certain periodicity, while the exact frequency of its publications is not essential. Therefore, the reasoning provided by the NA Staff, namely, that the applicant media outlet is a biweekly rather than a weekly, is not a relevant and necessary ground for denying accreditation. To exclude such arbitrary and legally vulnerable interpretations and their future application, it is important to review and amend the relevant provision on this issue and a number of other provisions of the aforementioned Regulation.
Summarizing the above, the IDC concludes that the National Assembly Staff and its Chief, in the process of resolving the issue of accrediting the journalists from Gortsntats newspaper, violated the requirements of the Law “On Fundamentals of Administrative Action and Administrative Proceedings,” interpreted the provisions of Article 6 of the Law “On Mass Communication” to the detriment of the media outlet, exhibited discriminatory attitude toward it, and, by rejecting accreditation, unreasonably restricted the editorial office’s right to disseminate information, opinions and ideas.
Information Disputes Council
Shushan Doydoyan (IDC Secretary), President of Freedom of Information Center
Boris Navasardian, Honorary President of Yerevan Press Club
Ara Ghazaryan, Director of “Ara Ghazaryan” Law Firm
Aram Abrahamyan, Chief Editor of “Aravot” Daily
Ashot Melikyan, Chairman of Committee to Protect Freedom of Expression
Olga Safaryan, Lawyer
[1] Organization for Security and Cooperation in Europe. Representative on Freedom of the Media Dunja Mijatović. Accreditation of Foreign Journalists in the OSCE Region, p. 13