Procedure for submitting NGO Reports: Clarification

A number of amendments to the RA Law on Non-Governmental Organizations, which came into force on 24 April, 2020, provide for new rules and conditions for the submission of annual reports by non-governmental organizations.

In particular, Article 24 (7) of the law in the new edition stipulates that in case of receipt of the property of the non-governmental organization from the public funds (funds of the state or local self-government bodies and other public funds or the legal entity), the  public organization is obliged to before 30 May of the reporting year, publish a report provided by the law on the website of the reports published by the organizations. The Authorized Body, the State Revenue Committee, shall approve the sample form of submission of reports, the procedure of publication and submission.

As a result of the research conducted by the ALA and the clarifications received from the State Revenue Committee, it becomes clear that the relevant platform for submitting reports is still in the process of formation. Due to the uncertainty of the deadlines for its completion, it was clarified that the non-observance of the deadlines for the publication of the reports until 30 May will not cause any liability envisaged by the RA Code on Administrative Offenses.

However, the ALA continues to receive concerns from NGOs as to which year’s report should be submitted in accordance with the new amendments.

Based on the above, the ALA, studying the clarifications of the State Revenue Committee and the discussions it had, informs that the reports should be submitted in the following order: According to the new format and order, the reports for 2019 are presented on a voluntary basis: and the presentation of the reports for 2020, which will be presented in 2021 according to the new order, will be mandatory>

All the non-governmental organizations that are interested and want to get additional information on the issue can apply to the State Revenue Committee, as well as to the Armenian Lawyers’ Association.