Armenia is amongst the world’s richest agrobiodiversity hotspots, but rapid genetic erosion is threatening these vital resources of food security. The objective of this study is to investigate how legislation and policies affect the conservation and sustainable use of plant genetic resources for food and agriculture (PGRFA) in Armenia. National gene banks are central actors in this regard. Relevant legislation and policies within the context of international commitments and the institutional structures of Armenia are analysed, as well as their impact on the gene banks’ ability to provide access to PGRFA for farmers. Official documents, legislation and interviews with key stakeholders in Armenia are the primary sources of information. Despite Armenia’s post-Soviet trajectory of institutional collapse, war and lack of political support, national gene banks have managed to store much of Armenia’s plant heritage ex situ, even though under modest conditions. Armenian legislation provides barriers to the marketing and exchange of seeds from most traditional varieties. Nevertheless, informal exchange still continues amongst farmers to some extent. The legislation is a serious obstacle to conservation and sustainable use of PGRFA and thus to the compliance with relevant international agreements that Armenia is party to. As a comprehensive strategy and action plan on PGRFA conservation and sustainable use is still lacking, the gene banks’ promotion of on-farm conservation and sustainable use of PGRFA can be attributed to committed individuals taking responsibility for the country’s international obligations. Political attention and policy coherence are required, as are well-targeted long-term commitments from development agencies.