The other cash-register regime: how the Central Bank, not the tax authority, supervises FX exchange points

The cash register at a currency-exchange counter is supervised by a different regulator than the cash register at a bakery next door. The bakery's ՀԴՄ is registered with SRC under the tax authority's fiscal regime. The exchange counter's ՀԴՄ — or the computer with FX-trading software that often stands in for one — is supervised by the Central Bank of Armenia, under a separate normative framework that has existed in parallel since 2005.

This is one of those institutional facts that surprises everyone who finds it. The rest of the site tracks one regulator chain — Tax Inspectorate (1991) through today's SRC (2008→). The Central Bank is on a different rail entirely, and yet the rail touches the same physical object: a cash-handling device used to record commercial transactions.

This page is a short tour of that parallel rail.

Why CBA, not SRC

Currency exchange in Armenia is a licensed financial activity. Anyone wanting to operate an exchange counter — whether a standalone "փոխանակման կետ" or part of a broader brokerage business — needs a licence from the Central Bank, not from SRC. That licensing authority brings the supervisory authority with it: CBA gets to set what equipment licensees must have, how it must be approved, and how it must be operated.

The result is two regulators, two normative frameworks, one physical device. SRC's regime governs cash registers as fiscal instruments — receipts, tax compliance, fiscalization. CBA's regime governs the same hardware (or its computer-equivalent) as a financial-supervision instrument — exchange rates, transaction-volume reporting, money laundering controls.

The two regimes don't conflict directly because they answer different questions about the same box.

The founding act: N 90-Ն of 3 March 2005

CBA Board decision N 90-Ն of 3 March 2005, formally titled "Requirements for cash registers and computer equipment used by persons conducting foreign currency purchase-sale and foreign currency dealer purchase-sale activities, registration procedure and operation rules", is the founding act. It establishes:

• What technical specifications the equipment must meet
• The procedure for getting CBA approval before that equipment can be used commercially
• The rules for operating the equipment once approved

We have the decision's title, date, and authority confirmed via multiple sources, but the verbatim current text isn't in our hands — the arlis.am PDF rendering on this one is poor, and we couldn't extract clean clause-level text. What we can say is that the decision is still operationally referenced by the currently-in-force Regulation 10, which means CBA hadn't repealed it as of the last R10 amendment (October 2016).

The current operating regulation: Regulation 10 (N 138-Ν of 15 May 2007)

The day-to-day rulebook for FX exchange points is CBA Board decision N 138-Ν of 15 May 2007, which approved "Regulation 10 on Licensing and Regulation of Foreign Currency Exchange Operations". This is the third iteration of the FX licensing regulation — its predecessors (N 444-Ն of 30 August 2005; N 238-Ն of 6 June 2006) are both formally ուժը կորցրած (superseded). The most recent amendment to Regulation 10 we could verify is N 181-Ն of 25 October 2016.

Two articles inside Regulation 10 do the load-bearing work for the hardware regime:

Article 79 — what hardware must be at the counter.

Every licensed exchange point must have:

1. A fireproof safe (չհրկիզվող պահարան)
2. A device that verifies banknote authenticity (դրամանիշերի իսկությունը ստուգող սարք)
3. A bill counter (դրամանիշերը հաշվելու սարք)
4. A landline city telephone (քաղաքային հեռախոս)
5. A calculator on the cashier's desk
6. A board displaying current exchange rates (արտարժույթի առուվաճառքի փոխարժեքները արտացոլող վահանակ)
7. Computer equipment and/or a cash register machine (համակարգչային սարքավորում և/կամ հսկիչ-դրամարկղային մեքենա) — with a mandatory printer and uninterruptible power supply

The seventh item is the connection to N 90-Ν. Note the "and/or" — an exchange point doesn't strictly have to operate a ՀԴՄ; it can operate a computer with CBA-approved FX-trading software instead, or both together.

Article 15 — how that hardware gets approved.

Before commercial operation, the licensed exchange point must submit to CBA an application requesting "approval to put into operation the computer equipment containing a program" — citing the procedure established by N 90-Ν. This is the CBA-side analogue of the SRC's conformity-assessment process for fiscal cash-register models, except that for FX equipment it's the regulator itself (CBA) doing the approval rather than a downstream operator.

What's NOT clear, and where we'd like help

Three load-bearing questions about how the parallel regime intersects with the regular fiscal regime are not resolved from the public sources we have access to.

1. Does a ՀԴՄ at an exchange point also need SRC fiscalization?

The Armenian Tax Code (Articles 380-381) requires nearly every business transaction to be issued through a fiscalized cash register registered with SRC. FX exchange itself is exempt from VAT and FX trading operators are exempt from turnover tax — both treated as financial operations, not goods sales — so the surface logic could go either way:

• Dual-registered hypothesis: the same physical ՀԴՄ is both CBA-approved (for FX-operation supervision) and SRC-fiscalized (for receipt issuance). Exchange points use one box that wears two hats.
• CBA-only hypothesis: FX equipment lives entirely outside SRC's fiscal regime, on the strength of the financial-operations exemption. Receipts at exchange points are CBA-supervised documents, not SRC fiscal receipts.

The accountant.am Q&A mentions exchange points submit weekly volume reports to CBA by Wednesday of the following week, plus an electronic registration journal (form 13) — but it's ambiguous whether that form-13 system is the SRC fiscal stream or a CBA-only parallel.

2. Does CBA maintain a public list of approved FX equipment models?

SRC's ՀԴՄ approved-models list is published; CBA's equivalent (if one exists) is not visible from the public arlis.am or cba.am pages we could fetch. It's plausible that approval under N 90-Ν is granted device-by-device on application rather than by maintaining a catalogue — but we cannot establish this either way from the public record.

3. The verbatim current text of N 90-Ν.

Multiple later acts reference it, but the arlis.am PDF rendering for this specific decision is fontless and we couldn't extract clauses cleanly. Acquiring the actual clause-level text — directly from arlis or a republished version — would let us say much more about the specific technical requirements.

These three are now open questions on the site. If you've licensed an exchange point and remember the equipment approval paperwork, or you operate one and know how the fiscal reporting actually flows, we'd love to hear.

Why it's worth knowing about

Most of fiscal.am tracks fiscalization in the strict, SRC-administered sense: tax-authority cash registers, fiscal receipts, model approval through SRC chair's orders, the chain of ՀԴՄ technical-requirements decrees from N 946-Ν (2005) to N 1976-Ν (2020).

The CBA parallel regime is a reminder that Armenia's cash-register regulatory landscape isn't a single tree. There is a second, much smaller branch — narrower in subject (only FX counters), narrower in actor (only CBA-licensed entities), but running in parallel for two decades. The same physical device at an exchange point answers to two regulators with two different concerns. That kind of regulatory layering is invisible from any single page on the site — except this one.

For the main fiscalization rail, see the regulator chain and the fiscalization timeline. For the broader history of how cash-register certification took shape, the certification history page.