Woe from Energy: Armenia’s Search for Autonomy at Regulatory Crossroads

Armenia’s energy sector finds itself at a triple regulatory crossroads. The landlocked nation currently faces a precarious balancing act dictated by three overlapping factors: structural reliance on Russian energy infrastructure, full membership in the Russia-dominated Eurasian Economic Union (EAEU), and an inability to fully leverage cross-border legal and technical partnerships with powers such as China or Iran.

Navigating its tensions with Moscow within the framework of the EAEU, chiefly Russia’s  most recent ban on agricultural imports from Armenia into Russia, has placed Yerevan between Scylla and Charybdis. The Armenian government has to navigate the punitive economic countermeasures, and Moscow’s tendency to dictate, rather than negotiate, when it comes to member states attempting market diversification. Legally, Armenia remains tightly bound to Russia through bilateral EAEU agreements. While Armenia signed the Comprehensive and Enhanced Partnership Agreement with the European Union, the Agreement has not been fully ratified. Yerevan, as a result, has limited legal and institutional leverage when negotiating trade and energy disputes with Moscow from the outset.

This structural tension must be contextualised within Russia’s broader energy strategy across Africa, rather than viewed exclusively through the prism of EU-Russia competition in the energy and trade sectors. British and US think-tanks have largely overlooked the operational role of Russian Energy Minister Sergei Tsivilev in enforcing this policy. Tsivilev is increasingly becoming a key operative in bilateral disputes between Moscow and Yerevan. In 2025, he issued a formal warning to the Armenian Foreign Ministry regarding potential countermeasures, should Armenia advance its integration process with the EU. 

This intervention builds on Tsivilev’s prior experience negotiating bilateral technology, training, and energy infrastructure agreements across Africa, most recently in Burkina Faso, Ethiopia, and Niger in 2025, when either a European nation was pulling out of the country, or by addressing pressing issues, such as electricity connectivity.  Whilst the precise details of his involvement are unclear, it is possible to make a case that Tsivilev’s influence on Russian foreign policy is distinctly operational rather than symbolic, as he could potentially apply frameworks honed in the Global South to maintain structural dependencies when Western influence recedes, or when critical grid infrastructure requires intervention.

Armenia’s position is comparable with the nations in Africa from the perspective of Russia’s energy policy. Whilst Armenia’s 2016 Law on Energy Saving and Renewable Energy introduced the need for technical requirements of how energy is traded and used across different sectors, as well as laying out the mechanism for calculating the independent supplier’s cap on electricity that an individual supplier can provide in one go, the country legally remains tied to Russia. The present bilateral agreement between the two countries is favourable for Russia as it allows Russia to supply gas to Armenia without export duties and on preferential terms for domestic consumption. However, this arrangement increasingly clashes with recent amendments to the Armenian Law on Energy Saving, due to regulatory ambiguity surrounding what technical framework should be used to define the terms  ‘technical knowledge’ and ‘usage of modern equipment’ within the national electricity sector.

The nuclear energy sector offers the most relevant working example of approaching this regulatory ambiguity. Following Independence, Armenia’s nuclear sector operated under joint supervision from the International Atomic Agency and the World Association of Nuclear Operators. Following the 2011 Fukushima disaster, Yerevan steadily turned to the European Nuclear Safety Regulators Group for technical review. Yet as the IAEA 2022 report indicates, Armenia lacks the domestic capacity for nuclear waste processing as this part of the national infrastructure has been historically managed elsewhere in the USSR. Despite this fact, regulatory limbo remains. The landlocked nation is reliant on EU technical oversight for operational safety, yet legally and logistically bound to sanctioned Russian entities for fuel supply and waste management.

Alternative legal frameworks offer little immediate relief. While some analysts point to historical Silk Road connections and potential transit corridors linking China to both the Black Sea and the Persian Gulf, meaningful integration with Chinese legal structures remains distant. On the one hand, some analysts have noted that the partnership between Armenia and China could be beneficial due to a shared trade link to the historical Silk Road, or due to mutually beneficial links opening up access to the Gulf, Black Sea and Europe. 

Moreover, Chinese energy policy is currently facing a similar set of issues in comparison to Armenia; how to price electricity effectively on both local and national levels, how to define modernisation in terms of equipment, and how to develop more robust technical reporting procedures for the sector. As such, the two legal systems are on a partially similar footing in a legal sense. Yet, there is not much incentive for the Chinese legal framework to be implemented. This is due to Beijing having little institutional incentive to extend specialised legal frameworks to Yerevan as Armenia has a lower trade volume in comparison with full members of the Belt and Road Initiative.

Similarly, legal alignment with Iran faces structural legal friction. Despite geographic proximity, substantial trade partnership, and discussions surrounding the 'Persian Gulf–Black Sea' International Transport Corridor protocol in 2022, deep-seated legal discrepancies and conflicting technological standards continue to prevent comprehensive institutional integration.

As a result, Armenia remains trapped in a state of regulatory fragmentation. Without a coherent hybrid framework that reconciles domestic modernisation legislation, EU technical standards, and regional on-the-ground realities, Yerevan’s capacity to achieve genuine energy autonomy will remain constrained by Moscow’s operational leverage.

Image: Unsplash/Lukáš Lehotský

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