If you have challenged a public-law monetary claim of up to AMD 300,000 in court, such as a fine, and the ruling was issued in your favor, the administrative body can no longer file an appeal against that decision. The right to appeal remains available to individuals and legal entities, as well as the Corruption Prevention Commission.
This restriction is provided for by Law HO-92-N of March 4, 2026, which introduced amendments to the Code of Administrative Procedure. It applies to public-law monetary claims not exceeding 300 times the minimum wage; with AMD 1,000 used as the calculation base, the threshold is AMD 300,000.
If a person wins such a case in the first instance, the administrative body's appeal is rejected, while if the person loses, they continue to have the right to appeal. In certain cases, the new regulation also applies to proceedings initiated based on statements of claim filed before the law entered into force.
The law generally entered into force on April 10. For judicial acts issued against the Patrol Service and Yerevan Municipality, the restriction has applied since that date, while for other administrative bodies, it takes effect three months after official publication. Relevant appeals submitted before that date but not yet admitted are rejected, while proceedings in cases already admitted and still pending are terminated, subject to the exception provided by law.
New rules concerning appellate review deadlines also take effect on October 1. The Court of Appeal examines appeals against judicial acts resolving a case on the merits within six months after admitting them for review, and that period may be extended once for another six months by a reasoned decision.
As a general rule, appeals against Administrative Court acts are examined under a written procedure, without a hearing. A hearing may be held upon a reasoned motion by a participant or at the court's initiative if the court considers it necessary for effective examination of the appeal.
In practice, the new regulation distinguishes between the appeal rights of an administrative body and those of the person who brought the case to court, particularly in cases where the amount of the claim does not exceed AMD 300,000. As a result, within this threshold, a state body's ability to take a first-instance decision to appeal is no longer the same as that of an individual, creating an important distinction for citizens challenging administrative fines or other public-law monetary claims.
Particular attention should be paid to the transitional provisions, as the amendment is not limited only to cases initiated after the law entered into force. For appeals that have already been filed, the law provides different consequences depending on whether they have been admitted for review, whether the examination has been completed, or whether the process is still ongoing. Meanwhile, the new deadlines taking effect on October 1 and the general rule of written examination will also change how cases are handled at the appellate stage.
