“INTERFERENCE BY DESIGN” Electoral Integrity, EU Engagement, and the 2026 Parliamentary Elections in Armenia
A White Paper by Amsterdam & Partners LLP
Armenia’s parliamentary elections on 7
June 2026 are set to occur in conditions
that do not meet the standards set by the
EU-Armenia Comprehensive and Enhanced
Partnership Agreement, the Strategic Agenda
for the EU-Armenia Partnership, the Interna-
tional Covenant on Civil and Political Rights,
or the European Convention on Human
Rights. This paper, prepared by Amsterdam
& Partners LLP, is the second part of the firm’s
Armenia series. The first part, published in
October 2025, reported serious violations of
Armenian law and international human rights
standards by the government of Prime Min-
ister Nikol Pashinyan. These included the
arrest and prosecution of the main opposition
leader, the detention of senior clerics from the
Armenian Apostolic Holy Church, and the use
of economic pressure against dissenters. An
addendum from February 2026 found that
these patterns had become more severe.
This paper examines whether the Euro-
pean Union’s actions before the election,
including over €300 million in financial sup-
port, sending a Hybrid Rapid Response Team,
running counter-disinformation efforts, and
holding a summit of 44 European leaders in
Yerevan a month before the vote, amount to
interference in Armenia’s electoral process.
THE GOVERNING LEGAL
FRAMEWORK: WHAT THE EUROPEAN
UNION IS REQUIRED TO DO
Before summarizing the paper’s findings, it is
important to clearly outline the legal frame-
work used to assess the European Union’s
AMSTERDAM & PARTNERS LLP 6
actions. This paper only asks the EU to follow
its own legal requirements.
Article 2 of the Treaty on European
Union provides that the Union is founded
on the values of democracy, the rule of law,
and respect for human rights. Article 21 of
the Treaty on European Union requires that
these same values guide the Union’s external
action. Article 8 of the Treaty on European
Union requires that neighbourhood relations
be “founded on the values of the Union.” Arti-
cle 21(3) of the Treaty on European Union
imposes a consistency obligation, requiring
that the Union ensure coherence between its
internal and external policies.
The bilateral relationship between the
European Union and Armenia is governed
by the Comprehensive and Enhanced Part-
nership Agreement, known by its acronym
CEPA, which entered into force on 1 March
2021. Article 2 of CEPA designates respect
for democratic principles, the rule of law,
human rights, and fundamental freedoms
as “essential elements” of the agreement,
binding on both parties. The clause incorpo-
rates, by express reference, the Organisation
for Security and Co-operation in Europe
Helsinki Final Act, the Charter of Paris for
a New Europe, the Universal Declaration of
Human Rights, and the European Convention
on Human Rights. A breach of these essen-
tial elements may trigger consultations and
“appropriate measures” under Articles 378
and 379 of the agreement.
The Strategic Agenda for the EU-Arme-
nia Partnership, adopted by the EU-Armenia
Partnership Council on 2 December 2025,
April 2026translates these general commitments into
operational obligations. It requires “politi-
cal pluralism, inclusion in decision-making
and cooperation and positive engagement
with the opposition”; “transparent, inclusive,
free and fair elections”; compliance with the
recommendations of the Organisation for
Security and Co-operation in Europe’s Office
for Democratic Institutions and Human
Rights; and the express condition that Euro-
pean Union support “will be conditional on the
implementation of agreed reforms.”
This paper evaluates the European
Union’s actions based on these agreements.
The criticism is not about engagement itself,
but about engagement that is one-sided when
inclusivity is required, lacks transparency
where openness is needed, is unconditional
when conditions are expected, and remains
silent on democratic abuses when the EU
should speak out for democracy, the rule of
law, and human rights.
the opposition. Instead, the EU should take
neutral steps, such as publicly condemning
violations, applying conditions to its support,
engaging with all political groups, and send-
ing independent election observers. The EU
should do less to help the current govern-
ment and more to hold it accountable. These
are not conflicting demands, but both reflect
the same legal requirement: the EU must act
within its own laws.
THE APPARENT TENSION
IN THE PAPER’S POSITION
Readers may notice that this paper argues
both that the European Union should not
have given certain types of support to the
current government and that it should not
have stayed silent about the government’s
actions against the opposition. While this
may seem like a contradiction, the tension
is not as significant as it seems.
The key difference is between neutral
and non-neutral engagement. This paper
does not suggest that the European Union
should leave Armenia. Instead, it argues
that the EU’s current involvement is not neu-
tral and actually makes the situation worse
by supporting the government’s actions.
The paper recommends suspending meas-
ures like the Hybrid Rapid Response Team,
unconditional financial support, and coun-
ter-disinformation operations, as these only
benefit the government and do not protect
AMSTERDAM & PARTNERS LLP
THE DOMESTIC CONTEXT:
DEMOCRATIC BACKSLIDING
AND THE SUPPRESSION
OF POLITICAL COMPETITION
Since June 2025, the Armenian authorities
under Prime Minister Nikol Pashinyan have
arrested and prosecuted Samvel Karapetyan,
the leader of the principal opposition party,
Strong Armenia, the day after he made a
public statement in defence of the Armenian
Apostolic Holy Church. They have detained
senior clerics of the Church, including Arch-
bishop Bagrat Galstanyan and Archbishop
Mikayel Ajapahyan, the latter of whom was
convicted and sentenced to two years’ impris-
onment in a trial described by civil society
organisations as unprecedentedly swift. They
have arrested a defence lawyer, Alexander
Kochubaev, for a social media post criticising
prosecutors involved in the clergy cases, a
step condemned by the International Com-
mission of Jurists as a serious interference
with the independence of the legal profes-
sion. They have nationalised the opposition
leader’s principal business asset, Electric
Networks of Armenia, and revoked its oper-
ating licence. They have closed Shoghakat
TV, a church-founded public broadcaster.
They have amended the Electoral Code, two
months before the election and with exclu-
sively governing-party votes, to prohibit the
use of personal names in party-alliance titles,
targeting the “Strong Armenia with Samvel
Karapetyan” bloc. And they have detained
7 April 2026fourteen party affiliates in the final weeks
of the campaign on charges that the party’s
lawyers describe as politically motivated.
These facts are not just claims from one
side of a political argument. They are sup-
ported by three independent organizations.
The Organisation for Security and Co-op-
eration in Europe’s Office for Democratic
Institutions and Human Rights, in its report
from 19 March 2026, noted that opposition
parties were concerned about their ability
to campaign, that the closure of the church
broadcaster was seen by many as politically
motivated, and that changes to the Electoral
Code were made quickly without input from
the opposition. The International Observatory
for Democracy in Armenia, which included
Kenneth Roth, former head of Human Rights
Watch, found evidence of politically moti-
vated arrests, misuse of vague laws, and
government interference in the Church’s
independence. CivilNet, an independent
Armenian media outlet, called 2025 a year
of democratic decline and reported that pre-
trial detention was used to control political
opponents.
fourteen European experts, who, according
to a document seen by Radio Free Europe/
Radio Liberty, advised the Armenian Prime
Minister’s office and Security Council on
“crisis management plans in various elec-
toral scenarios,” helped the Interior Ministry
and tax authorities, assisted in “tracking and
prosecuting illicit election financing,” and
launched “public awareness campaigns
related to elections on FIMI, with support
in targeting key demographics.” The EU also
scheduled its first-ever EU-Armenia Summit,
attended by the Presidents of the European
Council and Commission and 44 European
leaders, 33 days before the election. This
was the strongest show of external political
support in Armenia’s electoral history.
What the European Union failed to do
is just as important. It did not send its own
Election Observation Mission. It did not pub-
licly respond to the findings of the Office for
Democratic Institutions and Human Rights,
the International Observatory for Democracy
in Armenia, or CivilNet. The EU did not use the
CEPA essential-elements clause, start con-
sultations under Articles 378-379 of CEPA,
or make any financial support conditional
on stopping the documented violations. It
did not engage with the opposition or reply
meaningfully to any of the three letters from
Amsterdam & Partners LLP about the legality,
neutrality, and impact of EU-funded activities.
THE EUROPEAN UNION’S
ENGAGEMENT: UNCONDITIONAL
SUPPORT IN THE FACE OF
DOCUMENTED VIOLATIONS
Instead of making its support conditional
on meeting democratic standards set by
CEPA and the Strategic Agenda, the Euro-
pean Union increased its cooperation. In
the year before the 7 June 2026 election,
the EU announced commitments totalling
over €300 million. It signed a €270 million
Resilience and Growth Plan 80 days before
the election without any democratic condi-
tions. The EU also announced €12 million
for counter-disinformation, €15 million
for resilience, and approved €20 million in
non-lethal military support. It sent a Hybrid
Rapid Response Team of about nine to
AMSTERDAM & PARTNERS LLP
WHY THE EUROPEAN UNION’S
ENGAGEMENT CONSTITUTES
INTERFERENCE
The paper shows that the European Union’s
involvement in Armenia is not neutral support
for democracy. Instead, it is one-sided, work-
ing only through the current government. This
approach is similar to methods the EU has
used in Romania, Moldova, Hungary, Slovakia,
Poland, and the Czech Republic. The analysis
highlights five main features that together
show this interference.
8 April 2026First: the securitisation
of opposition discourse
The European Union’s engagement is framed
not through the vocabulary of democratic
development, pluralism, neutrality or equal
access, but through the vocabulary of secu-
rity governance: “hybrid threats,” “Foreign
Information Manipulation and Interference,”
“cyber resilience,” and “strategic communi-
cation.” This distinction matters because
the securitisation of a pre-election envi-
ronment transforms the standards against
which engagement is assessed. In the secu-
rity paradigm, the question is not whether
the engagement is neutral but whether the
threat is real. Once the threat is accepted,
the response is shielded from democratic
accountability.
The Pashinyan government has exploited
this framework. It has characterised oppo-
sition clergy as “criminal-oligarchic clergy,”
framed the arrests as the prevention of
“acts of terrorism,” and portrayed domestic
political opponents as vectors of Russian
influence, without evidence of foreign
direction. The International Observatory
for Democracy in Armenia identified this
dynamic precisely: “the government seems
to be weaponizing evidence-free claims of
foreign interference to lull European officials
into looking the other way as it exercises
increasingly authoritarian powers.” By pro-
viding the government with a European team
specialising in counter-disinformation, the
European Commission does not combat
external threats. It endows the incumbent’s
repressive narrative with supranational
legitimacy. No mechanism exists to prevent
the Armenian government from using the
European Union team to classify domestic
opposition discourse as “Russian propa-
ganda.” The opposition was not consulted.
No public criteria for classifying content as
“disinformation” have been disclosed. No
appeal procedure exists. No independent
oversight has been established.
AMSTERDAM & PARTNERS LLP
Second: the absence
of structural transparency
The detailed mandate for the Hybrid Rapid
Response Team has not been made public
and is only known through media reports.
The classified Political Framework for a Crisis
Approach for Armenia, a 28-page document
from the European External Action Service
that reportedly describes Armenia’s political
situation as a crisis needing EU intervention,
has also not been released. The criteria for
labelling content as “Foreign Information
Manipulation and Interference” in Armenia
are not known. Amsterdam & Partners LLP
has written to the European Commission
three times with concerns about the legality,
neutrality, and impact of these operations, but
has not received any meaningful response.
The International Observatory for Democracy
in Armenia shared its findings in Yerevan on
12 March 2026, and the Office for Democratic
Institutions and Human Rights issued its
report on 19 March 2026, but the EU has not
publicly addressed either. When the European
Commission uses public funds to influence a
country’s information environment during an
election, a lack of transparency about how it
operates is not a minor issue—it is a serious
legal problem.
Third: the fallacy of consent
The European Commission’s anticipated
defence is that Armenia requested the assis-
tance and that the deployment responds
to a sovereign invitation. The argument
is untenable. Any engagement by the EU,
regardless of invitation, must comply with
international law, its bilateral obligations,
and democratic norms. Moreover, the con-
sent of a government that simultaneously
prosecutes the opposition leader, detains
defence lawyers, revokes business licences
from critics, and arrests archbishops is
not the consent of Armenia as a sovereign
state. It is the consent of a political faction
that exploits state institutions to perpetuate
9 April 2026itself in power. The non-intervention prin-
ciple, as incorporated into CEPA through
the Organisation for Security and Co-oper-
ation in Europe Helsinki Final Act, protects
the sovereign choice of the people, not the
prerogative of an incumbent whose demo-
cratic credentials are contested. Moreover,
the European Union’s own legal framework
does not treat partner-state consent as
sufficient. The CEPA essential-elements
clause imposes bilateral obligations. The
Strategic Agenda’s conditionality mech-
anism makes support conditional on the
implementation of agreed reforms. Arti-
cle 21(1) of the Treaty on European Union
requires the Union’s external action to
respect international law, including the prin-
ciple of non-intervention. These provisions
exist precisely because unilateral execu-
tive consent cannot discharge the legal
requirements for lawful engagement. If it
could, the essential-elements clause, the
conditionality mechanism, and the non-in-
tervention principle would be superfluous.
Fourth: the third-country problem
and the absence of mandate
The paper identifies a constitutional defi-
ciency at the core of the European Union’s
Armenia engagement. The Digital Services
Act was adopted under Article 114 of the
Treaty on the Functioning of the European
Union as an internal-market instrument. It
regulates online intermediaries and platforms
operating within the EU. Its election-risk pro-
visions formally address elections within the
European Union. No treaty provision confers
upon any European Union institution the
competence to manage, shape, or influence
parliamentary elections in a non-member
state. Armenia has no seat in the European
Parliament, no representative in the Coun-
cil of the European Union, no recourse to
the Court of Justice of the European Union,
and no capacity to participate in the dem-
ocratic accountability structures through
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which European Union policy is contested
and constrained. The functional export of the
Digital Services Act’s conceptual apparatus,
systemic risk assessment, rapid response,
counter-FIMI coordination, into a sovereign
third state through “resilience” programmes
and hybrid-threat response teams raises a
direct question of ultra vires: the exercise of
powers that exceed the legal basis conferred
by the Treaties. If the European Commission
lacks competence to manage electoral nar-
ratives within its own Member States, as
Articles 4(2) and 5 of the Treaty on European
Union confirm, it lacks such competence a
fortiori in a non-member state.
Fifth: double standards
and the consistency obligation
The European Union’s treatment of Armenia
stands in stark contrast to its treatment of
its own Member States. Within the Union, it
triggered the Article 7(1) procedure against
Hungary. The Council suspended billions of
euros in cohesion policy commitments. The
European Commission withheld disburse-
ments from the Recovery and Resilience
Facility to both Hungary and Poland pend-
ing compliance with rule-of-law conditions.
Annual Rule of Law Reports were published.
The European Parliament characterised
Hungary as an “electoral autocracy.” Outside
the Union, in Armenia, where the democratic
deficiencies documented by independent
bodies are at least as serious, the European
Union has frozen no funds, conditioned no
financial commitment, initiated no consulta-
tions under CEPA, published no rule-of-law
assessment, addressed no findings from
the Office for Democratic Institutions and
Human Rights, and condemned no Electoral
Code amendment. Instead, it has deepened
cooperation. Article 21(3) of the Treaty
on European Union requires consistency
between the different areas of the Union’s
external action and between its internal and
external policies. The selective application
10 April 2026of conditionality, rigorous within the Union,
absent toward Armenia despite comparable
or worse violations, constitutes a breach of
that consistency obligation.
LEGAL VIOLATIONS
The paper identifies twelve specific breaches
of European Union law, international law, and
the bilateral framework.
First, ultra vires action in breach of the
principle of conferral under Articles 4(2)
and 5(1)-(2) of the Treaty on European
Union. The European Commission has
functionally exported election-risk gov-
ernance instruments, developed for the
internal market under the Digital Services
Act, into a non-member state that lies out-
side the Union’s treaty-based constitutional
settlement. The channelling of funds for
a mandate that encompasses pre-elec-
tion narrative management in a third state
exceeds the competences conferred upon
the Commission by the Treaties.
Second, breach of the right to good
administration under Article 41 of the Charter
of Fundamental Rights. The European Com-
mission disbursed election-sensitive funds
without assessing the foreseeable conse-
quences, without consulting the opposition,
without establishing independent oversight,
and without responding to documented con-
cerns raised by legal counsel, independent
monitoring bodies, and the Organisation for
Security and Co-operation in Europe’s own
assessment mission.
Third, breach of the principle of transpar-
ency under Article 15 of the Treaty on the
Functioning of the European Union and Arti-
cle 42 of the Charter of Fundamental Rights.
The operational mandate has not been pub-
lished. The criteria for classifying content
as “Foreign Information Manipulation and
Interference” have not been disclosed. The
classified Political Framework for a Crisis
Approach has not been released.
AMSTERDAM & PARTNERS LLP
Fourth, violation of the principle of pro-
portionality under Article 5(4) of the Treaty on
European Union. Even accepting that coun-
tering hybrid threats is a legitimate objective,
the total absence of safeguards, no opposi-
tion consultation, no independent oversight,
no published criteria, no appeal procedure,
and no equal access renders the deployment
manifestly disproportionate. The government
receives everything; the opposition receives
nothing.
Fifth, violation of fundamental rights
under Articles 11 and 39 of the Charter
of Fundamental Rights, Article 10 of the
European Convention on Human Rights,
and the Bradshaw framework. In Bradshaw
and Others v. the United Kingdom (2025),
the European Court of Human Rights held
that counter-interference measures must
be “calibrated carefully to ensure that they
do not interfere disproportionately with an
individual’s right to impart and receive infor-
mation, especially in the period preceding
an election,” and must “take due account
of the risk of abuse by Contracting States
seeking to interfere in the outcome of their
own elections.” The Court cited Kobaliya
and Others v. Russia (2024), which found
that “foreign agent” labelling “contributed
to shrinking democratic space by creating
an environment of suspicion and mistrust
towards civil society actors and independent
voices, thereby undermining the very foun-
dations of a democracy.” In Armenia, the
government’s characterisation of opposition
clergy as “criminal-oligarchic clergy” and of
the opposition leader as an agent of desta-
bilisation reproduces the Kobaliya dynamic.
The European Union’s counter-disinforma-
tion framework provides the institutional
substrate upon which this labelling operates:
it endows the government’s characterisation
with supranational credibility. No balancing
exercise has been performed. No criteria
for distinguishing protected political speech
from actionable foreign manipulation have
11 April 2026been published. The Bradshaw standard has
not been met. It has been inverted.
Sixth, breach of the CEPA essential-ele-
ments clause. The European Union has not
invoked the essential-elements clause in
response to documented democratic dete-
rioration. It has not initiated consultations
under Articles 378-379. It has not conditioned
any financial commitment on the cessation
of the documented violations. The clause has
been rendered decorative.
Seventh, breach of the Strategic Agenda
commitments. The paper documents serious
non-compliance with each of the Strategic
Agenda’s six core commitments: political
pluralism and positive engagement with the
opposition; transparent, inclusive, free and
fair elections; inclusive legislative consul-
tations aligned with European standards;
conditionality-based assistance; support for
independent media and an enabling informa-
tion space; and justice-sector commitments
to judicial independence.
Eighth, breach of international law, includ-
ing the sovereign equality principle and the
election-rights guarantees of Article 25 of the
International Covenant on Civil and Political
Rights and the Bradshaw framework under
Protocol No. 1, Article 3 of the European Con-
vention on Human Rights.
Ninth, double standards and selective
application in breach of Article 21(3) con-
sistency obligation.
Taken together, these breaches lead to
the tenth finding: the European Union is not
acting as a neutral supporter of democracy
in Armenia. Instead, it is helping to shape an
election environment that favours the ruling
government.
Amsterdam & Partners LLP has formally
notified the European Commission of the
legal consequences arising from the conduct
documented in this paper.
THE EUROPEAN UNION’S
SILENCE AS THE ENABLING
CONDITION OF INTERFERENCE
The European Union’s silence about Arme-
nia’s decline in democracy is not separate
from the interference described in this paper;
it makes that interference possible. If the
EU had applied the conditions required by
CEPA and the Strategic Agenda, its financial
support would be proper cooperation, not
unconditional approval. If it had engaged
with the opposition as required, the Hybrid
Rapid Response Team could have been neu-
tral, not just a tool for the government. If the
EU had publicly addressed the findings of
the Office for Democratic Institutions and
Human Rights, the International Observatory
for Democracy in Armenia, and CivilNet, its
actions would show principled engagement,
not selective support. Instead, the EU did
none of these things. It gave the government
everything that strengthens its position and
withheld everything that could limit it. This
pattern, active when it helps the government,
silent when it should protect the opposition,
is the core of the interference.
RECOMMENDATIONS
The paper concludes with sixteen recommen-
dations in three categories.
Immediate measures before 7 June 2026:
suspend the Hybrid Rapid Response Team
pending independent review, including the
publication of its detailed operational man-
date, disclosure of the criteria used to classify
content as “Foreign Information Manipula-
tion and Interference,” and establishment
of an appeal mechanism and independent
oversight with opposition participation; pub-
lish the classified Political Framework for a
Crisis Approach for Armenia; engage with the
opposition, with the International Observatory
for Democracy in Armenia, and with Amster-
dam & Partners LLP; publicly condemn the
AMSTERDAM & PARTNERS LLP
12 April 2026April 2026 Electoral Code amendments;
apply CEPA conditionality by conditioning
disbursement of remaining tranches of the
€270 million Resilience and Growth Plan on
the cessation of politically motivated pros-
ecutions, the release of pre-trial detainees,
compliance with the recommendations of
the Office for Democratic Institutions and
Human Rights, and the reversal of the April
2026 amendments; and deploy an independ-
ent European Union Election Observation
Mission.
Structural reforms to prevent replication:
mandatory cooling-off periods between
major funding announcements and sched-
uled elections in partner states; transparent
publication of all election-period counter-dis-
information activities; independent audits by
the European Court of Auditors; automatic
conditionality triggers for political detention
during pre-election periods; and mandatory
opposition inclusion in all election-period
assistance, including consultation, rep-
resentation in oversight mechanisms, and
equal access to analytical outputs.
Demands on the Armenian government
under the bilateral framework: release
political detainees and cease politically
motivated prosecutions; reverse discrimi-
natory Electoral Code amendments; restore
media pluralism, including reversing the clo-
sure of Shoghakat TV; cease interference in
ecclesiastical autonomy; and cooperate with
international human rights accountability
mechanisms, including the United Nations
Human Rights Committee, the Council of
Europe’s Commissioner for Human Rights,
and the Venice Commission.
These recommendations are not just sug-
gestions; they are requirements based on the
legal framework the European Union has set
for itself. The Treaties, CEPA, and the Strate-
gic Agenda do not give the EU a choice; they
require compliance. If the EU follows its own
standards, these recommendations are legally
binding. If it does not, the EU loses its claim to
be a principled supporter of democracy, not
because of criticism, but because of its own
actions. The Armenian people deserve a real
election. This paper directly asks whether the
EU’s institutions will act in accordance with the
principles they claim to uphold.
