Since 2001 the Freedom of Information Center publishes a Black List of officials who head agencies in possession of information, which have not responded to FOICA inquires to gain access to such information.

In the past, the percentage of unanswered inquires was in the range of 30-36%. Currently, as the Republic of Armenia Law on Freedom of Information is in effect already for about a decade, this figure has improved significantly as a result of numerous trainings conducted, litigations launched and public awareness campaigns organized by FOICA: in 2012 the number of unanswered FOICA inquires decreased twice, dropping to 15.6%, compared to 35% recorded in previous years.

The number of officials blacklisted over the years also demonstrates the trend of decreasing count of unanswered inquiries: 40 officials were blacklistedin 2001, and 47 in 2007, whereas in 2011-2012 the Black List contained relatively small numbers – 12 and 15, respectively. In 2013 Q1 and Q2 the Black Lists were comprised of just a single official.

Among other things, this means there is a need to revise the main criteria of the FOICA Black List, because generally, the inquiries now get responded in one way or another.

The number of silent refusals has diminished, instead being replaced by largely incomplete or groundless replies or unjustified refusals. Thus, previously the officials tended to avoid providing information that could have shown their institution at a disadvantage, and left the information inquiriesunanswered. Currently, in response to “problematic” information inquiries the officials prefer to provide incomplete, evasive and unessential answers, rather than leaving them unanswered.

With all of this in mind, effective July 1, 2013 the FOICA introduces more rigorous criteria for blacklisting. The 2013 Q3 (July-September) Black List will already include not only officials who do not respond to FOI inquiries, but also those who groundlessly refuse providing information or breach the 5-day deadline stipulated by the FOI Law.