A draft law proposing amendments to Armenia’s Law on Cinematography, published for public discussion on March 6 by the Ministry of Education, Science, Culture and Sports, has already triggered strong reactions from the professional community.
Comments submitted through the official public platform show that filmmakers, producers, and industry experts have raised serious concerns about the proposed changes.
At the center of the criticism is a provision that would allow the national body — effectively the Cinema Foundation of Armenia — to act as a collective manager of authors’ property rights in the film sector. Industry representatives argue that such an approach contradicts both Armenian copyright legislation and established international practice, where rights are typically held by producers or co-producers.
Another controversial provision would expand the definition of a “national film” to include not only projects meeting specific criteria, but also films whose property rights have been transferred to the Republic of Armenia or the national body. Critics say this raises fundamental legal and policy questions about the role of the state in relation to creative ownership.
Concerns have also been raised over proposed changes to the system of state support. Several provisions regulating funding quotas, limits, and distribution mechanisms are set to be removed or rewritten. According to some experts, this could weaken key strategic safeguards and increase the risk of discretionary decision-making.
Industry voices have emphasized that state support mechanisms should not be removed from the core law without detailed justification and impact analysis. Some argue that these principles must remain enshrined in the primary legislation, rather than being delegated to secondary regulations.
The redefinition of what constitutes a “national film” has also become a major point of debate. Professionals note that removing requirements related to the citizenship of directors or screenwriters, as well as introducing new language criteria, could significantly alter both the legal and cultural meaning of national cinema.
Additional concerns relate to proposed changes affecting the film register and film heritage preservation. Critics have pointed to the removal or modification of key terms such as “national film”, “public use”, and provisions governing the transfer of property rights to producers, warning that this could create legal uncertainty and complicate both production and archival processes.
Governance issues have also been raised. In particular, some commentators questioned proposals that would allow representatives to replace high-ranking officials on the board of the Cinema Foundation of Armenia. According to critics, this could dilute accountability and weaken institutional responsibility in decision-making.
Among the most detailed responses are those submitted by director and producer Armine Anda, director and producer Inna Sahakyan, and architect and cultural figure Nare Leone Ter-Gabrielyan. Despite differences in emphasis, their comments converge on several key concerns: protection of producers’ rights, alignment with international co-production frameworks, limits on the authority of the national body, and the lack of sufficient justification for the proposed changes.
Inna Sahakyan, in particular, argued that parts of the draft contradict not only Armenian legislation but also the Council of Europe’s European Convention on Cinematographic Co-Production. She warned that weakening producers’ control over property rights could damage international co-productions and hinder the global distribution of Armenian films.
Armine Anda went further, calling for the draft to be withdrawn in its current form. In her assessment, the majority of the proposed changes would need to be removed, as they amount not to technical adjustments but to a fundamental restructuring of the sector’s legal framework.
Shorter comments echo similar concerns. Grigor Poghosyan stated that transferring property rights to a funding body or foundation in any form is unacceptable. Nare Leone Ter-Gabrielyan also criticized the idea that property rights could belong to the state or a national body, describing it as incompatible with democratic principles of creative ownership.
Notably, nearly all of these comments have so far received the same official response: “noted” or “will be further considered,” with no detailed feedback provided at this stage.
This is not the first wave of criticism surrounding the draft. An earlier version, presented for public discussion during the Golden Apricot International Film Festival in the summer of 2025, faced significantly stronger and more widespread backlash from the professional community. At the time, concerns focused on the same core issues — state support mechanisms, copyright regulation, and the scope of authority of the national body — suggesting that key tensions remain unresolved in the current version.
At this stage, it is clear that the proposed amendments have become a major point of contention within Armenia’s film industry. For many professionals, the draft is not seen as a set of technical corrections, but as an attempt to redefine the fundamental principles governing film production, financing, and ownership in the country.
