At the beginning of 2025, the Freedom of Information Center published its 24th annual Black List, which includes state agencies and officials violating people’s or organizations’ access to information constitutional rights by providing unreasonable or incomplete responses, illegal denials, or leaving requests unanswered.

The FOICA has summarized the Black Lists published in previous years and highlighted notable data regarding the structures and officials appearing on the lists.

Here are the key findings:

• Over the past 24 years, a total of 345 officials have been included in the Black Lists.

• The most extensive Black List was published in 2007, including 46 officials. The shortest was the 2023 Black List, with 3 officials.

• Among the officials listed, 39 appeared twice, four were included three times, and three officials made it onto the list four times.
• The most frequently cited institution in FOICA’s 24 Black Lists since 2001 is the Yerevan Municipality, which has been included 12 times—specifically in 2001-2005, 2009-2013, and consecutively from 2021 to 2024.
• Among Armenia’s ministries, the Ministry of Defense has been listed the most—nine times. The Ministry of Health comes second, with five appearances, the same as the now-defunct Ministry of Energy Infrastructure and Natural Resources.
• The National Assembly has been included in the Black List 4 times: 2013-NA Speaker Hovik Abrahamyan, 2020-NA Speaker Ararat Mirzoyan, 2021-NA Speaker Alen Simonyan, 2021-Former NA MP Gor Gevorgyan.
• The most frequently listed regional administration is Shirak, appearing 6 times. In 2002, regional governor Felix Pilumyan appeared on the black list, in 2004, regional governor Romik Manukyan, in 2004, head of the regional education department Sahak Minasyan, in 2009 and 2010, regional governor Lida Nanyan, and in 2022, regional governor Nazeli Baghdasryan (of the Shirak regional governors, only Lida Nanyan appeared twice). The next place is Gegharkunik regional administration, 3 times. In 2001, regional governor Vahagn Hakobyan was included in the list (in that year, Hakobyan violated the FOIA right twice), in 2004, regional governor Sipan Barseghyan, and in 2009, regional governor Nver Poghosyan.