“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.