Beyond the historic union. CIS: one diverse region – multiple polarities.
For much of the post-Soviet period, the Commonwealth of Independent States (CIS) was often treated as a relatively unified bloc of 12 countries (Russia, Belarus, Ukraine, Moldova, Georgia, Armenia, Azerbaijan, Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, Uzbekistan), underpinned by a shared linguistic environment and a common regulatory and institutional legacy. Over time, however, this cohesion has diminished, with Georgia, Moldova and Ukraine no longer considering themselves part of it. At the same time, alternative regional frameworks - such as the Eurasian Economic Union (EAEU) and the GUAM Organization for Democracy and Economic Development - have emerged to reflect evolving political and economic alignments.
Rising geopolitical tensions - most notably conflicts between Armenia and Azerbaijan, and between Russia and Ukraine - have accelerated policy divergence across the region, particularly in the telecommunications sector. Broadly, three orientations can now be observed: a pro-European trajectory (Georgia, Moldova, Ukraine, and to a lesser extent Armenia); a pro-Russian trajectory (primarily Belarus as well as Russia itself with some degree of influence extending to other states); and a group pursuing more regionally integrated or Asia-facing trajectory, including Azerbaijan, Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan and Uzbekistan.
These geopolitical shifts are increasingly reflected in national regulatory approaches. While, historically, digital and telecommunications frameworks across the CIS were strongly influenced by Russian regulation and technical standards, countries are now developing more independent policy agendas. The practical cohesion of regional structures such as the EAEU has weakened in practical terms, with limited expansion and uncertain future direction. At the same time, governments are placing greater emphasis on digital development - not only as to enhance connectivity and economic integration, but also to strengthen national security and technological sovereignty.
As a result, several key regulatory trends are emerging. Russia’s growing regulatory isolation has, indirectly, encouraged neighbouring states to strengthen their own frameworks over the past five years. Across the region, digitalisation strategies have been positioned as drivers of economic diversification and administrative efficiency. At the same time, geopolitical disruption, sanctions exposure, rising cyber risks and supply chain constraints have significantly accelerated the urgency of these programmes.
In this first part of our 5‑minute read, we focus on countries following a pro‑European trajectory - namely Georgia, Moldova, Ukraine, and, to a certain extent, Armenia - and examine their regulatory trends and future compliance implications.
EU-Aligning Trajectory
Georgia, Moldova, Ukraine, and Armenia (to an extent) are reshaping their telecommunications and digital‑regulatory systems to align with the European Electronic Communications Code (EECC) and broader EU law, focusing on market liberalisation, regulatory transparency, and interoperability with EU systems. This results in more predictable, investor-friendly frameworks, though implementation depth varies from country to country. The overall impact is a structural decoupling from legacy CIS regulatory models and a move toward predictable, investor‑friendly environments that support cross‑border interoperability with the EU’s Digital Single Market.
Ukraine represents one of the most advanced examples of this trajectory. Russia’s full‑scale invasion has significantly accelerated regulatory reform in the telecommunications sector, as resilient and secure digital infrastructure has become a critical national priority. Not only has Ukraine introduced multiple national strategies to reflect this (such as the Strategy for Electronic Communications Development to 2030; the 2022 Law on Electronic Communications and related cybersecurity policies) but it is also steadily implementing corresponding national standards and compliance frameworks. These include local equivalents of EU RoHS, WEEE, and Ecodesign requirements, as well as improved spectrum management to support emerging technologies such as Wi‑Fi 6E, all aimed at closer alignment with the EU. It is clear that the country is looking beyond the end of the war, actively preparing for infrastructure reconstruction while building a more attractive and transparent regulatory environment for investors.
Moldova is similarly advancing its EU alignment agenda. Its new Law on Electronic Communications, which came into effect in January 2026, directly transposes the EECC and broader EU telecom rules into national legislation. It practically removes requirement for national level compliance approvals as the country fully aligns its regulation with EU. This creates a modern, competition‑driven market framework and establishes a clear legal basis for deeper integration with the EU. In addition, the EU–Moldova Association Agreement provides a legally binding roadmap for the gradual harmonisation of Moldova’s telecommunications regulations with EU law.
Georgia has also made significant progress through its existing Law on Electronic Communications, which serves as the foundation of its regulatory framework. This legislation establishes market structure, defines the role of the national regulatory authority (GNCC), and implements competition rules and authorisation regimes broadly consistent with the EU model. As a reminder, the country fully accepts CE marking and there’s no national level approval scheme. Building on this foundation, Georgia is undertaking an EECC Approximation Programme, which involves continuous legislative updates to align its national framework with EU Directives to synchronise areas of market regulation, spectrum policy, and broadband development, further strengthening regulatory compatibility with the EU.
Armenia presents a more hybrid case. While not fully aligned with EU telecom frameworks, it is making gradual progress in selected areas. Its ongoing Digitalisation Strategy Programme focuses on strengthening state digital infrastructure and improving administrative predictability, although telecom‑specific harmonisation remains limited. At the same time, Armenia is deepening cooperation with the EU through initiatives such as the EU‑Armenia Connectivity Partnership, which supports broadband expansion, cross‑border connectivity, and alignment with EU connectivity standards, while also encouraging investment. The Comprehensive and Enhanced Partnership Agreement (CEPA) between the EU and Armenia further provides a structured roadmap for gradual approximation to EU rules across telecoms, competition, and digital policy. However, Armenia continues to maintain independent national regulations in areas such as telecom, spectrum management, and equipment certification, and still operates within certain Eurasian Economic Commission (EAC) frameworks.
Horizon Scan – Summary, Trends, & Future Compliance Implications
• Deepening EU Regulatory Convergence – alignment with the EU and its legislation is becoming the central organising principle for telecom and digital regulation in EU trajectory countries, driving harmonisation in areas such as market access, spectrum management, and consumer protection, and anchoring long‑term integration with the EU Digital Single Market.
• Security‑Led Regulatory Acceleration – particularly in Ukraine, wartime conditions have accelerated reforms, embedding cybersecurity, network resilience, and infrastructure protection into core regulatory frameworks; this security‑first approach is increasingly influencing neighbouring EU‑aligned states, like Moldova.
• Structural Decoupling from CIS Legacy Systems – EU‑trajectory countries are progressively moving away from Russian‑influenced standards and regulatory models, replacing them with EU‑compatible frameworks, though the pace and depth of transition varies, with some residual legacy requirements still present.
• Evolving but Uneven Compliance Landscape – while convergence improves predictability and investor confidence, differences in implementation capacity, enforcement, and hybrid alignment (e.g. Armenia) mean companies must still navigate transitional complexity, including overlapping frameworks, evolving cybersecurity obligations, and ongoing legislative updates.
In Part 2, we will explore the remaining CIS countries (Azerbaijan, Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, Uzbekistan) and examine the key developments shaping their national telecommunications policies.