The World Bank published a report titled “Armenia’s Economic Pulse: Fair Markets for Inclusive Growth” on 21 November 2025, which contains a number of inaccuracies and statements lacking sufficient evidence that do not reflect the full picture of the competitive environment in product markets in the Republic of Armenia.
1. The comparative analysis was conducted on the basis of non-comparable data. Specifically, the authors of the report examined the level of concentration in several sectors of the economy in the Republic of Armenia and the stability of market shares of economic entities using indicators from 2018–2023, and compared these indicators with those of Georgia, Moldova, and Croatia for the period 2015–2019. As a result, in contrast to Armenia, the comparable countries’ data do not take into account significant global economic shocks, such as the COVID-19 pandemic. Meanwhile, the results of the analysis for both Armenia and the comparator countries could have been entirely different if comparable time periods was considered.
2.The assumption presented in the report that consumers did not benefit from the decline in international prices during 2023–2024 due to the concentration of retail chains does not correspond to reality. The authors illustrate this assumption using the examples of two products: chicken meat and flour.
Chicken meat prices
• One of the reasons for erroneous conclusions may be that the authors used the international price of frozen chicken meat as a benchmark, while local wholesale and retail prices were calculated for fresh chicken meat. According to the authors, international chicken meat prices declined on average by 5 percent during 2023–2024 (production prices by 8.6 percent and retail prices by 4.2 percent), and in December 2024 price declined by 8.22 percent compared to early 2023. To verify the reliability of the data presented in the report, the Commission conducted an analysis which revealed that while international chicken prices fell by about 9 percent, the price of chicken imported into the Republic of Armenia rose by 6 percent over the same period. Furthermore, a comparison of December 2024 with December 2023 shows that the price of frozen chicken imported into Armenia increased by 10.8 percent. In this sense, it should be noted that under conditions of declining international prices presented by the authors, the price of chicken imported into Armenia increased during the same period. As for local meat prices, the Commission found that under conditions of rising prices for imported frozen chicken, wholesale and retail prices for fresh local chicken meat either remained unchanged or decreased.
Flour prices
• With regard to flour prices, the authors’ observations are not confirmed; rather, the situation appears to be the opposite. Under conditions where import prices increased by 18.8 percent, production and retail prices increased on average by only 6–7 percent. Moreover, the authors failed to take into account that wheat imported into the Republic of Armenia is predominantly sourced from the Russian Federation, which, given the unified customs territory of the EAEU, makes it significantly cheaper than the wheat price presented in the report. As a result, the data presented in the report show a different trend and are higher than the price of wheat imported into Armenia.
Within the same context, the authors also present observations regarding butter and sausage prices for 2023–2024.
Butter prices
• According to the authors, while local production prices for butter declined by 7.7 percent, retail prices decreased by only 1.1 percent. The main issue here is that the authors did not consider international prices, despite the fact that the majority of butter consumption in Armenia is covered by imported butter. International exchange data shows that the annual average price of 1 kg of butter was approximately 2,044 AMD in 2023 and increased to 2,850 AMD in 2024 (This represents an increase of about 39 percent). In December 2024, the import price of cream butter increased by 32.8 percent compared to December 2023. Thus, given that the majority of butter consumption in Armenia is ensured through imported butter, the data presented by the authors do not correlate with actual market pricing dynamics.
Sausage prices
• With regard to sausages, according to the authors, while local production prices declined by 2 percent, retail prices decreased by 1.4 percent. Primarily, the absence of clearly specified data on the products classified under the sausage category by the authors is problematic. As a result, it is unclear whether the wholesale and retail prices include only locally produced sausages or also imported products. Considering that the sausage market is competitive and heterogeneous, the reasons for price changes may differ for each individual product. Therefore, under such market conditions, it is not possible to draw conclusions about competitive conditions in the market based on average price changes derived from the grouping of multiple product groups.
3.The report states that the thresholds established by the Commission for the notification of concentrations are low, despite the fact that the report contains no comparative analysis or review of international experience, nor does it specify what baseline data were used for such a comparison. Meanwhile, the thresholds for concentration notification are periodically reviewed by the Commission, taking into account economic factors, enforcement practice, and international best practices. In particular, notification thresholds were increased as a result of legislative amendments in 2021, and as a result of legislative amendments in 2025, the requirement to notify concentrations was completely removed for a number of transactions.
It is also noteworthy that in 2023 the Organization for Economic Co-operation and Development (OECD) approved the Republic of Armenia’s application to join the Guidelines for Merger Assessment, thereby confirming that Armenia’s relevant legislative framework, enforcement, and policy related to concentrations comply with the high international standards set by the OECD.
4.The authors assume that a potential risk for small economic entities in Armenia seeking to increase their sales volumes could be that the Commission might classify them as having a dominant position. This assumption is entirely unfounded, given that similar criteria exist in almost all countries worldwide, and it is illogical to assume that any company would consider the possibility of acquiring a dominant position as an obstacle when expanding its entrepreneurial activities and developing its business—especially considering that having a dominant position is not prohibited; only the abuse of such a position constitutes an infringement.
With respect to the clarity of the regulatory framework for assessing the existence of a dominant position, it is important to emphasize that in 2021–2022, in cooperation with EU partners, the Commission developed, adopted, and published both the procedure for determining dominance (https://www.arlis.am/hy/acts/210849/latest) and the procedures and methodology for defining the product market, which are also publicly available (https://www.arlis.am/hy/acts/210845/latest) (https://competition.am/wp-content/uploads/2023/02/58-%D4%B1-%D5%B8%D6%80%D5%B8%D5%B7%D5%B8%D6%82%D5%B4.pdf). It should also be emphasized that in 2024, based on the Commission’s application, the OECD examined and confirmed the compliance of the Republic of Armenia’s legislation and its enforcement with the high standards for transparency and due process in the enforcement of competition law.
Taking into account the above circumstances, as well as the close cooperation established with the World Bank over the years, the Commission deems it necessary to emphasize that it is ready to support, in any format, efforts to correct the inaccuracies contained in the report on the basis of reliable data that accurately reflect reality.
