Her Excellency Ms Ursula von der Leyen
President of the European Commission
Rue de la Loi 200 / Wetstraat 200
1049 Brussels, Belgium
Copies, for the record, via email to:
Ms Kaja Kallas, High Representative for Foreign Affairs and Security Policy / Vice-President of the European Commission
Ms Marta Kos, Commissioner for Enlargement and the Eastern Neighbourhood
Mr Michael McGrath, Commissioner for Democracy, Justice, the Rule of Law and Consumer Protection
Ref.: Elections to the National Assembly of the Republic of Armenia on 7 June 2026 – responsibility of the European Union for its political decisions and notice of the legal consequences arising therefrom.
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Dear Madam President,
I am writing to you as the head of the institution whose political decisions are largely to blame for the situation described below. Enlargement policy, financial assistance instruments and visa liberalisation fall within the remit of the Commission that you preside over and have been deployed as a reward to a government whose institutional safeguards have been weakening. I do not write to seek your sympathy or to request your good offices: I write to place on record, formally and unambiguously, that the European Commission bears direct political and legal responsibility for what has occurred, and to put you on notice of the consequences that will follow.
I write as legal counsel, in representation of Mr Samvel Karapetyan. The contents of this letter have been prepared in coordination with the legal team of the ‘Strong Armenia’ (Ուժեղ Հայաստան) party alliance, the primary opposition force that stood in the regular elections to the National Assembly of the Republic of Armenia held on 7 June 2026. Mr Karapetyan, the leader of that opposition force, has throughout the electoral cycle been the target of the criminal prosecution, public intimidation and legislative manoeuvres described below, and it is both on his behalf and on behalf of the alliance that I address you.
This letter has a clear purpose, to convey to you, with all due respect but in no uncertain terms, that the serious democratic deterioration currently affecting Armenia is neither a purely internal matter nor an incident unrelated to Europe, but, to a substantial extent, the direct consequence of political decisions taken by the European Commission and the institutions of the Union. This is, moreover, not the first time we have addressed the Commission on these facts. In our letter of 8 April 2026, and previously on 23 March 2026 to the High Representative, we set out in detail the deployment of a Hybrid Rapid Response Team operating exclusively with the government, the channelling of €27 million through the NDICI-Global Europe instrument without a single guarantee of neutrality, and the eleventh-hour reform of the Electoral Code designed to exclude our alliance’s own name from the ballot. Each of those warnings was met with silence. The election that we predicted would be neither free nor fair has now taken place, exactly as foreseen. The Commission cannot now plead that it was not warned.
To be precise about responsibility: the serious democratic deterioration affecting Armenia is, to a substantial extent, the consequence of political decisions taken by the European Union through its institutions, including the Council, the European Council, the High Representative and the EEAS, and the Commission, each acting within their respective competences. The Commission, however, bears specific and direct responsibility for the instruments within its own remit: the implementation of NDICI-Global Europe funding, neighbourhood and enlargement policy, visa liberalisation and the related support that enabled and legitimised that policy. It is in that capacity that we address you, and it is by reference to those competences that the responsibility set out in this letter is to be understood.
The results of those elections have been formally contested. ‘Strong Armenia’ has lodged an application for annulment with the Central Electoral Commission (CEC) and, in response to its Decision No. 259-A of 14 June 2026, has lodged an appeal with the Constitutional Court of the Republic of Armenia. Both appeals document with detailed evidence, not isolated incidents but a systemic pattern of violations that affected all stages of the electoral process. The Constitutional Court opened its hearing of that appeal on 26 June 2026 and, the session having been adjourned, resumed it on 27 June 2026. Counsel before the Constitutional Court have argued that the violations are of such gravity that there are clear and serious grounds to declare the entire vote invalid and to order a repeat vote across the whole Republic.
Among the facts substantiated before the Armenian authorities themselves, the following stand out:
Systematic abuse of administrative resources. The Prime Minister, the leading candidate on the ruling party’s list, failed to effectively separate his institutional role from the campaign; pensions were increased by government decree after the elections had already been called, targeting a particularly vulnerable electorate; and the involvement of public officials, educational institutions and even minors in events organised by the ruling party was documented. More concretely: employees of Yerevan Municipality’s Greening and Environmental Protection Service were photographed and filmed placing Civil Contract campaign posters featuring Prime Minister Nikol Pashinyan; the Mayor of Yerevan held public office while simultaneously appearing on the ruling party’s electoral list; municipal employees took part in campaign activities during working hours; and teachers and schoolchildren were drawn into ruling-party campaign events. These are not isolated lapses but a deliberate channelling of the State’s personnel, premises and resources, none of it accessible to the opposition, into the ruling party’s campaign. Colleagues from the ‘Armenia’ alliance have further demonstrated before the Armenian authorities that several hundred million drams from the State budget were spent on the ‘Civil Contract’ campaign, a direct diversion of public funds into the ruling party’s electoral effort.
Pressure, coercion and undue influence on public employees. Individuals in subordinate employment relationships to the State, including teachers, municipal staff and other public-sector workers, were pressured to attend ruling-party events and could not freely refuse, as observer reports cited in our application confirm. Coercion of those whose livelihoods depend on the State is incompatible with free political participation and electoral equality.
Misuse of criminal prosecution bodies. Numerous criminal cases were brought against hundreds of people linked to the headquarters of ‘Strong Armenia’, involving measures such as pre-trial detention and house arrest, whilst the same procedures were not applied to the ruling party. The Anti-Corruption Committee disseminated edited recordings, publicly linking them to the alliance, thereby violating the presumption of innocence, a breach by public authorities that the European Court of Human Rights itself has repeatedly condemned, despite the fact that the courts subsequently rejected the interim measures on the grounds of a lack of reasonable suspicion. Investigative actions against opposition figures were timed and publicised to influence voters, amplified through state-supported media, and used to portray our representatives as criminal suspects before any judicial finding. This selective deployment of law enforcement was not the pursuit of justice; it was an electoral weapon.
Hate speech and an unequal media environment. The Administrative Court of Armenia (case no. VD/8592/05/26) found that certain public statements made by the ruling party’s lead candidate exceeded the limits of permissible political criticism and were incompatible with a free, peaceful and healthy electoral environment, and that the CEC had assessed such statements inadequately. That environment was poisoned by a sustained campaign of defamation and fear: the labelling of Mr Samvel Karapetyan as the “Kaluga oligarch”, the branding of the opposition as a “three-headed war party”, unfounded vote-buying allegations against ‘Strong Armenia’, and the repeated portrayal of opposition parties as threats to Armenia’s independence. At the same time, Public Television gave disproportionate coverage to the ruling party and excluded opposition participants from meaningful exposure, while the regulators failed to enforce any neutrality requirement, manufacturing a structural informational advantage for the government.
Dissemination of false and misleading information. Voters were knowingly misled, for example through the false claim that Robert Kocharyan would become the opposition’s joint candidate for Prime Minister, through television advertisements and repeated public statements designed to create confusion about the opposition’s alliances and objectives, materially degrading the quality of voters’ decisions.
Voting, counting and recount irregularities. Election-day violations affecting the freedom and secrecy of the vote were documented, including group voting, irregular military-voting procedures, voters being guided inside polling stations and the unauthorised presence of individuals near the voting process. The results of polling stations 35/65, 10/51 and 12/13 were annulled outright; recounts revealed discrepancies between initial counts and recount results; and counting procedures deviated from the Electoral Code in numerous further stations that were never annulled, casting doubt on the reliability of the official result as a whole. In a number of polling stations, the voting envelopes were transparent, defeating the secrecy of the ballot and exposing voters’ choices to observation and control.
Further concerns arise from the existence of approximately 17,000 voters registered on confidential electoral lists associated with military and other state institutions. The identities of these voters, as well as the polling locations at which they cast their ballots, were not subject to meaningful public scrutiny or independent verification. This lack of transparency undermines confidence in the integrity of the electoral process and creates a risk that such voters could have voted more than once without detection. Given the narrow margins by which parliamentary representation may be determined, the existence of a large category of unverifiable voters is capable of materially affecting electoral outcomes. A further and specific concern attaches to the votes of the Prosperous Armenia Party (PAP), which from the very first day of counting hovered precisely at the 4 per cent threshold required for parliamentary representation. Where a party sits exactly on the statutory threshold, even minor manipulation of the count is capable of determining whether it enters Parliament at all, and thus of reshaping the entire distribution of seats.
Equally troubling is the unprecedented number of invalid ballots recorded during the election. Official figures indicate that 16,210 ballots were declared invalid, resulting in a significant number of votes being effectively wasted and excluded from the final count. This represents a substantial increase from the approximately 11,000 invalid ballots recorded in the comparable 2021 parliamentary elections. No satisfactory explanation has been provided for this dramatic rise. In my view, the increase is closely linked to amendments to the voting procedures adopted only two months before polling day. Such last-minute changes are inconsistent with well-established international electoral standards, including the recommendations of the Venice Commission, which caution against fundamental modifications to electoral procedures within one year of an election. The combination of procedural uncertainty and a markedly elevated rate of invalid ballots raises serious concerns as to whether the will of the electorate was accurately reflected in the final results.
A further serious defect was the exclusion of a substantial number of displaced Artsakh Armenians from the electorate. Following the forced displacement of the Armenian population of Nagorno-Karabakh/Artsakh, many displaced persons held Armenian passports issued with the “070” code. Those documents had long functioned as Armenian identity and travel documents, yet the authorities treated them as insufficient to confer citizenship or voting rights for purposes of the parliamentary election. Displaced Artsakh Armenians were therefore required to complete a separate naturalisation or passport-conversion process before being included on the voter lists. OSCE/ODIHR reported that 20,101 recently naturalised displaced Armenian refugees were added to the voter rolls before election day, but that approximately 6,000 further applications remained pending, leaving those applicants without the possibility of voting. The broader scale of the exclusion may have been significantly larger: regional reporting and civil-society allegations suggest that tens of thousands of Artsakh Armenians remained outside the electorate, with estimates of the affected adult population reaching as high as 70,000. The exclusion of such a large displaced population, particularly through contested citizenship classifications and administrative delay, raises serious concerns about the inclusiveness and equality of the election and about whether the final result reflected the will of all persons with a legitimate claim to political participation in Armenia.
Independent and statistically robust observations confirm these violations:
These conclusions are not ours alone. The Akanates Observation Mission, conducted by the Transparency International Anticorruption Center and the Protection of Rights Without Borders, deployed 712 observers on 7 June 2026 and carried out full-day observation in a random sample of 260 polling stations (13% of the total), a methodology that permits a statistically valid assessment of the electoral process at the national level. Its findings corroborate, in detail and on the basis of representative sampling, the pattern described above: voter guidance or controlled voting in 8% of sampled stations (24 recorded cases); deliberate breaches of the secrecy of the vote in 2.69%, some expressly aimed at controlling the ballot; the presence of unauthorised persons in 5.43% of stations and of individuals apparently exercising “control” near the entrance in a further 5.04%; and, strikingly, in 18.22% of stations another person’s signature already appeared next to the names of registered voters, a direct indicator of the proxy- and multiple-voting risks set out above. Crowding inside polling stations was recorded in 22.48% of stations, and the provision of “hospitality” to commission members, mainly by political parties in 11.63%.
The Mission further documented the direct involvement of community and administrative heads in guiding and pressuring voters (naming, among others, the heads of the Baghramyan, Gyulagarak and Khashtarak communities); the organised transportation of voters to polling stations; and the obstruction and intimidation of observers, including false journal entries deliberately made to drive observers from polling stations and create “an atmosphere of fear and pressure”. It recorded serious irregularities in the count itself, including ballots cast for ‘Strong Armenia’ that had been deliberately folded in an identical manner as guidance markings (polling station 7/6), and a chairperson declaring ballots invalid in plain breach of procedure (polling station 33/36), and, during the overnight transfer of materials to the 38 Territorial Electoral Commissions, sacks delivered open or unsealed, ballots brought in by hand without a sack (which itself triggered recounts), and numerous arithmetical discrepancies in the precinct protocols. At polling station 35/65, one of those whose results were ultimately annulled, several hundred servicemembers were admitted to vote after the statutory 20:00 close, a gross violation that speaks directly to the unverifiable military vote described above.
One fact compels the Commission’s particular attention. This observation mission was carried out with the financial support of the European Union itself. The Union funded the very body whose statistically grounded findings now document the systematic violations that marred this election, and then, only days later, congratulated the result and urged all parties to respect it. The Commission cannot at one and the same time finance the documentation of electoral abuse and disregard that documentation the moment it proves inconvenient. That is not neutrality; it is the deliberate disregard of evidence the Union itself paid to produce, and it aggravates rather than mitigates the responsibility set out in this letter.
Dereliction of duty by the Central Electoral Commission. As the sole body constitutionally responsible for organising and supervising elections, the CEC failed to exercise its supervisory powers: in response to each complaint, it either took no action or merely referred it to the Prosecutor General’s Office, thereby shirking its positive obligation to respond immediately. Worse still, the CEC acknowledged serious violations in certain polling stations yet simultaneously concluded that none had affected the outcome, a conclusion that directly contradicts its own findings on complaints, recounts, court proceedings and annulled stations. Its final decision is legally unsustainable precisely because it refused to assess the cumulative impact of the violations on the result.
Last-minute changes to the Electoral Code. On 7 April 2026, without the opposition’s involvement or consent, the Electoral Code was amended to prohibit the use of the alliance’s name, and the format and grounds for invalidating ballot papers were altered, without an adequate information campaign. The result was an unprecedented number of invalid ballots which had a direct impact on the effectiveness of the vote. Changing the rules in the middle of the contest to legislate a named opponent out of the ballot is not electoral administration; it is the calculated dismantling of free and fair elections.
A wider and independently documented pattern of human rights violations:
The electoral abuses described above are not an isolated episode. They are the latest manifestation of a broader and well-documented deterioration in respect for fundamental rights and the rule of law under the current government, a deterioration recorded not by the opposition, but by a range of independent international organisations whose findings the Commission cannot responsibly ignore before it speaks again of Armenia’s “firm commitment to democracy”.
Christian Solidarity International and the European Forum for Freedom of Religion or Belief have each documented unprecedented State interference in the affairs of the Armenian Apostolic Church, including the arrest of clergy, restrictions on Church leaders and pressure on religious institutions, expressly likened to Soviet-era attempts to subordinate the Church to the State.[1][2] Human Rights Watch records restrictions on media freedom, expanded State surveillance, law-enforcement abuses and shortcomings in the protection of fundamental rights.[3] Amnesty International has highlighted the use of SLAPP-type lawsuits against journalists and civil-society actors, and the chilling effect of such litigation on independent media and human-rights defenders.[4] The Armenian Bar Association has publicly condemned the arrests of clergy and political opposition figures and the disregard for due process and basic legal rights.[5] CIVICUS has raised concerns over freedom of religion and the detention of senior clergy.[6] Freedom House has flagged concerns over judicial independence.[7] The European Centre for Law and Justice has highlighted the arrest of clergy and the restrictions imposed on bishops.[8] Furthermore, Reporters Without Borders has downgraded Armenia from 34th to 50th place in its 2026 World Press Freedom Index, citing deterioration across every measured indicator.[9]
Taken together, these findings describe a government that arrests archbishops, prosecutes and intimidates its critics, weaponises litigation against the press, and erodes the independence of its courts. That is the government whose election the European Union rushed to congratulate, and whose cooperation the Commission continues to fund. The Commission cannot credibly profess ignorance of a record this thoroughly and publicly documented; having been placed on notice of it, any continued endorsement is a deliberate choice for which it bears responsibility.
The fundamental question, however, is not merely what happened on polling day, but who should adjudicate these violations and under what conditions of independence. And herein lies the crux of this letter.
The Armenian Constitution was designed precisely to prevent the usurpation of power by a single political force. It requires a three-fifths qualified majority (60 per cent of the seats) to establish independent institutions and adopt crucial decisions: the election of members of the Constitutional Court (Art. 166.3), judges of the Court of Cassation, the Prosecutor General and members of the Central Electoral Commission itself, as well as the adoption of the Referendum Act, and the adoption or substantial amendment of the constitutional laws, including the Electoral Code and the Judicial Code, (Art. 103.2).
The constitution requires an even higher majority of two-thirds (around 67 per cent), which de facto means that consensus between the ruling party and the opposition for the most critical issues: the removal of the President of the Republic (Art. 141), the dissolution of the National Assembly, and the restriction, dissolution or prohibition of political parties. Under the current Armenian system, no single political force possesses such a two-thirds majority, which is an essential safeguard for the checks and balances of the legislative process.
The conclusion is uncomfortable but inescapable: the very bodies now called upon to resolve the challenges, the Constitutional Court, the Court of Cassation, the Public Prosecutor’s Office and the Central Election Commission, are those whose independence is protected by the constitutional framework through reinforced majorities. When these checks and balances are eroded, there is no truly impartial domestic body capable of correcting the outcome. This is the decisive point for the Commission: when you treat this result as “final” you are not deferring to independent national institutions, you are deferring to bodies captured by the very force whose victory is in dispute.
These structural concerns are not abstract; they have crystallised in the very hearing now before the Constitutional Court. The issue raised at the outset of those proceedings is itself one of constitutionality, and the Court’s own composition has given rise to a troubling inconsistency. While certain judges, Mr Vladimir Vardanyan and Mr Artak Zeynalyan, have been treated as unable to participate, the identical conflict applies with equal force to Judge Seda Safaryan, who stood as the number-three candidate on the Shirinyan-Babajanyan alliance’s list at the previous elections, given that the ‘For the Republic’ party is itself one of the parties appealing in the present case. A court that applies the rules on recusal selectively, barring some judges while admitting others affected by the very same conflict, cannot offer the guarantee of impartiality that the Constitution demands. As Mr Aram Vardevanyan, who leads Mr Karapetyan’s legal efforts before the domestic courts, has put it, “[t]he Constitutional Court must be independent, fearless, and maintain political neutrality”, and “the fundamental question is whether the Constitutional Court today meets those criteria”. That these domestic remedies are being pursued in full should not be mistaken for confidence in the independence of the institutions called upon to decide them.
That concern was reinforced outside the Constitutional Court during the hearing. When journalists asked the Minister of Justice, Srbuhi Galyan, about public doubts concerning the Court’s impartiality, and specifically about judges perceived as having close ties to the authorities, including Judge Seda Safaryan, the Minister did not answer as a neutral guardian of judicial independence. She instead treated the issue as a political dispute, asking rhetorically whether this was the first time in Armenia’s history that Constitutional Court judges had been connected to the authorities and insisting that the judges had been appointed not by Civil Contract but by the National Assembly. When the journalist pointed out that this is the sole instance in which nearly all members of the Constitutional Court have been appointed through a National Assembly controlled by Civil Contract, the formal answer did not dispel the appearance problem: the same parliamentary majority whose electoral victory is now under challenge was decisive in shaping the Court called upon to adjudicate that challenge.
Her subsequent answers made the problem clear. Asked about Judge Safaryan’s prior work in the Prime Minister’s staff, the public record of her political activity and the fact that her son had published in Haykakan Zhamanak, the Minister responded by stating that she was present as a representative of Civil Contract and that recusal is essentially a matter for the judge’s own assessment of whether a conflict of interest exists. That formulation reduces impartiality to self-certification by judges whose independence is precisely what is contested. When asked whether, appearing there as a Civil Contract representative, she was also the minister for the citizens whose votes are being contested before the Court, she replied that justice is administered by judges, not by her, and described herself as a policy-formulator in the field of justice. The point is not that the Minister will decide the case, it is that the executive authority responsible for justice publicly defended the contested institutional architecture while appearing in the political capacity of the ruling party.
Nor is the controversy merely rhetorical. The Minister ultimately acknowledged that, if the Constitutional Court declares the election invalid, Civil Contract would have to prepare for new elections. The ruling party therefore understands that the present proceedings concern the continuation of its own mandate. In those circumstances, public statements by the Justice Minister defending the Court’s composition and its approach to recusal, while simultaneously identifying herself as a Civil Contract representative, are material evidence of the appearance of institutional partiality. They underscore why the Union cannot legitimately treat the pending constitutional challenge as a merely internal technical process capable of curing the violations described above.
Against this backdrop, on 8 June 2026, the European Union, through the High Representative and the Commissioner for Enlargement, congratulated the Armenian people and stated that the vote “demonstrates Armenia’s firm commitment to democracy, peace and closer ties with Europe”, urging all parties to “respect the result”. That statement was issued whilst challenges regarding the violations described here were, and remain, pending resolution.
Allow me to be blunt, that congratulatory message coupled with the Commission’s broader policy decisions, the accession and enlargement framework, financial assistance, visa liberalisation and the New Partnership Agenda, has conferred European legitimacy on a process that Armenian institutions themselves are currently scrutinising. The Union has rewarded and endorsed a government whilst the constitutional checks and balances that were supposed to limit it were being rendered meaningless, without making that support genuinely conditional on the integrity of independent institutions or on the effective fairness of the electoral contest. This endorsement is all the more striking because, even with the benefit of the irregularities described above and of the Union’s own backing, the ruling party failed to secure the support of a majority of voters: it did not obtain even half of the vote, the greater part of the electorate having cast its ballot for the opposition. The Union thus conferred its legitimacy not merely on a flawed process, but on a government that the Armenian people themselves declined to endorse with a majority.
Let me state the matter as plainly as it deserves. The Commission applies the strictest rule-of-law conditionality to its own Member States, it has invoked Article 7 TEU against Poland and Hungary, frozen cohesion funds for rule-of-law failings and made NextGenerationEU disbursements conditional on judicial milestones. Yet faced with a government that prosecutes the opposition leader, detains clergy and defence lawyers, and rewrites the electoral rules to bar a named rival, the Commission applied no conditionality whatsoever․It deepened cooperation, increased funding, and then congratulated the result. That selectivity is not neutral. It told the Armenian electorate, in the clearest possible terms, which side Brussels had chosen. The double standard is your responsibility.
That is why we assert, respectfully but firmly, that what is happening is, to a considerable extent, the result of the European Commission’s political decisions. It is untenable to claim, at the same time, that the Union is a guarantor of democracy and the rule of law whilst endorsing an election marred by violations that have been documented before the Armenian courts themselves. European coherence demands a choice be made.
Legal consequences and accountability
We therefore put the Commission on formal notice that the facts set out above and in our previous correspondence give rise to the following legal consequences, which we intend to pursue with the utmost rigour:
- Misuse of powers (Article 263 TFEU). Funds channelled through the NDICI-Global Europe instrument, nominally to counter “hybrid threats”, have had the foreseeable and, in these circumstances, inevitable effect of strengthening the governing party’s electoral position against a criminalised opposition. That is a misuse of powers (détournement de pouvoir) reviewable before the Court of Justice.
- Acting ultra vires (Articles 4(2) and 5 TEU). The Commission lacks competence to manage electoral narratives within its own Member States; a fortiori it lacks any such competence in a third State. The financial implementation acts giving effect to the operation in Armenia exceed the limits of the Commission’s competence and are void.
- Breach of the right to good administration (Article 41 of the Charter). Channelling European public funds to a government internationally condemned for democratic backsliding, without any guarantee of neutrality and without consulting the opposition, breaches the Commission’s duty of care and amounts to structural complicity in the distortion of the electoral process.
- Breach of transparency (Article 15 TFEU). The operational mandate of the Hybrid Rapid Response Team, the criteria for classifying content as “disinformation”, the oversight arrangements and any appeal mechanism have never been published, a substantial defect compromising the legality of the financing decision.
- Violation of fundamental rights (Articles 11 and 39 of the Charter; Article 3 of Protocol No. 1, and Articles 10 and 11, ECHR; Articles 19 and 25 ICCPR). Free elections require a level playing field, not merely the absence of overt censorship. By funding a mechanism that handed the government a privileged tool to shape public debate while the opposition was criminalised, the Commission helped destroy that level playing field.
- Violation of the Armenian people’s right to self-determination (Article 1 ICCPR and ICESCR; Article 1(2) UN Charter). Self-determination requires that a people choose its representatives free from external interference that predetermines the outcome. An intervention of this nature and scale, at this moment, substitutes the geopolitical preferences of Brussels for the will of the Armenian people and makes the Commission jointly responsible for the distortion of a process that belongs to them alone.
In light of the foregoing, we formally demand that the European Commission:
- (a) refrain, with immediate effect, from treating an electoral result still under challenge before the Constitutional Court of Armenia as final or legitimate and withdraw or qualify the statement of 8 June 2026 accordingly.
- (b) suspend any political endorsement of the election result, and the operations of the Hybrid Rapid Response Team, until independent, transparent and verifiable oversight mechanisms, including the participation of opposition representatives, are in place.
- (c) make any continuation of support effectively and verifiably conditional on the real functioning of independent institutions, the release of political detainees, the cessation of the persecution of opposition figures, clergy and defence lawyers, and a level electoral playing field, applying to Armenia the same rule-of-law conditionality the Union applies to its own Member States.
- (d) publicly condemn the amendments to the Armenian Electoral Code adopted on the eve of the elections; and
- (e) meet, within fifteen (15) days and at a senior level, with Mr Samvel Karapetyan, the undersigned counsel and the representatives of ‘Strong Armenia’, to receive first-hand the full documentary record of the appeals lodged before the Central Electoral Commission and the Constitutional Court of Armenia, and confirm in writing, by the same deadline, the date and level of that meeting. A failure to respond will itself be treated as a refusal to engage.
Should the Commission fail to take appropriate and timely measures, we hereby give notice that we shall, without further warning: (i) bring an action for annulment under Article 263 TFEU before the General Court of the European Union against the financial implementation acts at issue; (ii) seek interim measures for the immediate suspension of the deployment and operations of the Hybrid Rapid Response Team, the harm being not speculative but already materialised; and (iii) pursue any further proceedings necessary before international fora, including the European Court of Human Rights, to vindicate the rights of the Armenian opposition and to hold the European Union to account for its role in the dismantling of Armenian democracy. We expressly reserve the right to make this correspondence public and to rely on it as evidence in any such proceedings.
We thank you in advance for your attention and remain at your entire disposal to provide further details or supply the full documentation of the appeals lodged with the Central Electoral Commission and the Constitutional Court of Armenia. We expect a substantive reply, in writing, within fifteen (15) days of the date of this letter.
Yours faithfully,
Robert Amsterdam
Founder and Managing Partner
Amsterdam & Partners LLP
Legal counsel to Mr Samvel Karapetyan
[1]Christian Solidarity International (CSI), “Armenia: Report on Persecution of the Armenian Church”, summary at https://www.csi-int.org/news/armenia-report-on-persecution-of-armenian-church/ ; full report (PDF) at https://www.csi-int.org/app/uploads/sites/13/2026/06/20260512_Armenia-Report_Final-Low-Res.pdf
[2]European Forum for Freedom of Religion or Belief (FOREF Europe), “Armenia: Apostolic Church under Attack” (3 February 2026), https://foref-europe.org/blog/2026/02/03/armenia-apostolic-church-under-attack/
[3]Human Rights Watch, World Report 2026 — Armenia country chapter, https://www.hrw.org/world-report/2026/country-chapters/armenia ; see also https://www.hrw.org/europe/central-asia/armenia
[4]Amnesty International, Armenia country report, https://www.amnesty.org/en/location/europe-and-central-asia/eastern-europe-and-central-asia/armenia/report-armenia/
[5]Armenian Bar Association, statement on arrests of clergy and political opposition (28 June 2025), https://armenianbar.org/2025/06/28/protecting-legal-rights-amid-crisis-armenian-bar-association-issues-statement-on-arrests-of-clergy-and-political-opposition/
[6]CIVICUS Monitor, https://monitor.civicus.org
[7]Freedom House, Freedom in the World — Armenia, https://freedomhouse.org/country/armenia/freedom-world/2025
[8]European Centre for Law and Justice (ECLJ), https://eclj.org/religious-autonomy/pace/le-ministre-armenien-des-affaires-etrangeres-nie-la-persecution-de-leglise-armenienne-devant-lapce?lng=en
[9]Reporters Without Borders (RSF), 2026 World Press Freedom Index — Armenia, https://rsf.org/en/country/armenia