Direct Request (CEACR) - adopted 2025, published 114th ILC session (2026)

Minimum Age Convention, 1973 (No. 138) - Armenia (Ratification: 2006)

Article 1 of the Convention. National policy and application of the Convention in practice. The Committee notes the statistical information provided by the Government from the report Labour Market in the Republic of Armenia, 2023, issued by the State Statistical Agency of Armenia (ARMSTAT), which includes data on the employment of children aged 15 to 17 years from 2019–2022. According to the report, 6,200 children in this age group were employed in 2022, comprising 3,800 boys and 2,400 girls. Of these, 1,200 were in urban areas and 5,000 in rural areas. The Committee notes that 72 per cent of these children were engaged in the agricultural sector, while the remaining 28 per cent were employed in other industries and services. However, the Committee notes the absence of information on the nature, extent and trends in the employment of children under 15 years of age that may be involved in child labour activities.

The Committee further notes that the United Nations Committee on the Rights of the Child (CRC), in its concluding observations of October 14 2024, expressed its concern at the large number of children, including some below the age of 14, that are engaged in work in the agriculture or construction sectors and the limited data on the economic exploitation of children, including child labour.

The Committee further notes the CRC concluding observations reference of the adoption and implementation of a new Programme for the Protection of the Rights of the Child for the period 2024–29 (CRC/C/ARM/CO/5-6 paras 42 and 7). The Committee requests the Government to provide statistical information on the nature, extent and trends of the employment of children under 15 years of age, disaggregated by sex and by age. The Committee also requests the Government to provide information on the measures taken within the framework of the Strategy Plan for the Protection of the Rights of the Child 2024–2029 to eliminate child labour, particularly in the agricultural and construction sectors, and the results achieved in this regard.

Article 3(2). Determination of hazardous work. The Committee notes with interest the adoption of a detailed list of hazardous types of work prohibited for persons under the age of 18, as set out in section 257 of the Labour Code of the Republic of Armenia (Labour Code), as amended by Law HO-160-N on May 2023. The list includes, for example, activities involving the production, advertising, or sale of tobacco products, as well as work related to erotica, pornography, horror content in printed publications, films, videos, and television programmes. It also prohibits the involvement of persons under 18 in the organization or promotion of gambling and in heavy, harmful work.

Article 8. Artistic performances. The Committee notes the Government’s indication that amendments to the Labour Code, as reflected in sub-section 2 of section 17.1, allow the participation of children under the age of 14 in artistic activities such as filmmaking, sports, drama, concerts, circus, television, and radio. However, the Committee recalls that, under Article 8(1) of the Convention, exceptions to the minimum age for admission to employment or work may be granted, on an individual basis and after consultation with the employers’ and workers’ organizations concerned, for participation in artistic performances.

The Committee also notes that sub-section 3 of section 17.1 permits the temporary employment of persons under 16 years of age, with previous written consent of a parent, foster parent, adoptive parent or a guardian, or, in the absence, with the written consent of the Nursing Body, provided that such employment does not interfere with compulsory education. However, the Committee observes that the information provided does not clarify whether the amended Labour Code contains a provision requiring that individual permits for participation in artistic performances by children under the minimum age are granted by a competent authority, as required by Article 8(1) of the Convention. The Committee further recalls that, under the terms of Article 8(2) of the Convention, the individual permits so granted shall limit the number of hours during which and prescribe the conditions in which such employment or work is allowed. The Committee requests the Government to clarify whether the recent amendments to the Labour Code provide for the issuance of individual permits by a competent authority for the participation of children under 16 years of age in artistic performances, in accordance with the requirements of Article 8(1) of the Convention. The Committee also requests the Government to ensure that such permits limit the number of hours during which and prescribe the conditions in which such employment or work is allowed.

Article 9(1). Penalties. The Committee notes with interest the Government’s indication that, within the framework of recent amendments to the Labour Code, several provisions have been introduced to ensure the prohibition of involving persons under 18 years of age in prohibited work. In particular, the Committee notes that: (1) section 41.6 of the Code on Administrative Offenses, along with sub-section 18 of section 158 and sub-section 3 of section 173, are aimed at enforcing the prohibition of employment of persons under the age of 18 in prohibited work; (2) under sub-section 18 of section 158, the involvement of persons under 18 in the sale of alcoholic beverages, narcotics, and psychotropic substances, or the distribution of materials containing horror or pornography, results in an administrative fine equivalent to 100 times the minimum wage; and (3) under sub-section 3 of section 173, the involvement of persons under 18 in the sale of tobacco products, related accessories, or substitutes results in an administrative fine ranging from 150 to 200 times the minimum wage. Repeating the same violations within six months after the application of administrative penalties results in a fine for the official position-holding individual, amounting to double the initial administrative penalty. The Committee requests the Government to provide information on the application in practice of section 41.6 of the Labour Code on Administrative Offences.

Labour Inspection. The Committee notes the information provided by the Government regarding labour inspection activities. It notes that between 2022 and 2024: (1) 881 inspections were carried out; (2) nine cases of violations involving the employment of persons under the age of 18 in prohibited work were recorded; and (3) administrative liability was enforced, with a total of 950,000 AMD. The Committee also notes that, pursuant to the Prime Minister’s Resolution No. 706-A of June 11, 2018 (as amended by Resolution No. 808-A of 16 July 2022), the maximum number of official staff positions within the Health and Labour Inspection Body was increased from 280 to 340.

The Committee further notes that, new risk-based inspections checklists have been implemented covering the construction sector and the extraction of raw materials such as clay and porcelain clay (kaolin), under Government Decisions No. 718-N (30 April 2020, No. 239-N (as amended on 3 March 2022), and No. 299-N (as amended on 10 March 2022). The Committee requests the Government to continue to provide information on the activities of the Health and Labour Inspection Body, includingthe number of child labour inspections carried out and the number and nature of violations detected. The Committee requests the Government to continue to provide information on any measures taken to strengthen the capacity of labour inspectorate to detect violations, including in the informal economy.