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

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

Article 2(1) of the Convention. Scope of application. The Committee notes the Government’s indication, in its report, concerning the amendment of the Labour Code of the Republic of Armenia (Labour Code) through the adoption of Law HO-160-N of 3 May 2023. The Committee observes that pursuant to section 14(1) of the Labour Code, employment relationships are established through a written employment contract or an individual employment contract, as provided for by employment legislation. The Committee also observes that section 17.1(1) provides that every person under the age of 18 has the right to engage in employment activities not prohibited by law.

However, the Committee notes that the above provisions of the Labour Code still do not apply to work performed outside the framework of a formal labour relationship, such as self-employment and non-remunerated work. The Committee reminds the Government that the Convention applies to all sectors of economic activity and covers all forms of employment and work. The Committee requests the Government to take the necessary measures, in the very near future, so that all children who engage in economic activities outside a formal employment relationship, particularly children who work in the informal economy, benefit from the protection afforded by the Convention.

Article 7. Light work. Following its previous comments, the Committee notes that section 17.1 of the Labour Code, as amended by Law HO-160-N of 2023, provides that persons under the age of 18 may engage in work not prohibited by national legislation, in accordance with their age, developmental characteristics and abilities. It further notes that section 17.1(3) allows for the temporary employment of persons under 16 years of age, with the prior written consent of a parent, foster parent, guardian, or the Curatorship Body, provided that such employment does not interfere with compulsory education and that permanent employment is prohibited.

The Committee further notes the amendments to section 140 of the Labour Code concerning shorter working hours for children. The Committee observes from the Labour Code that: (1) subsection 1(1) of section 140 allows children under the age of seven to work up to two hours per day and no more than four hours a week; (2) subsection 2(1) permits children between the ages of seven and 12 years to work up to three hours per day and no more than six hours per week; and that (3) subsection 3(1) provides that children aged 12 to 15 years may work up to four hours per day and no more than 12 hours per week, in all cases outside the hours prescribed for compulsory education. Noting that the minimum age for employment in Armenia is 16 years, as per section 15(2) of the Labour Code, the Committee reminds the Government that, pursuant to Article 7(1) of the Convention, national laws or regulations may permit the employment or work of persons of at least 13 years of age in light work, provided that such work is not likely to be harmful to their health or development. Furthermore, the Committee recalls that under Article 7(3) of the Convention, the competent authority shall determine the activities in which light work may be permitted. The Committee therefore requests the Government to bring its legislation into conformity with the Convention by raising the minimum age for admission to light work to at least 13 years under section 140 of the Labour Code. It also requests once again the Government to take the necessary measures to determine the activities in which light work may be undertaken by children of 13 years of age and above, in accordance with Article 7(3) of the Convention.

The Committee is raising other matters in a request addressed directly to the Government.