Iraq's new fintech regulation: a deep dive into the 2024 Electronic Payment Services Law
In a detailed analysis breaking down the new legal landscape, the Baghdad-based ALSAIF Law Firm, a firm with over 46 years of experience in the country, outlines the opportunities and requirements under this new regulation. The law aligns with the National Financial Inclusion Strategy, which was launched in May 2025 by the CBI in partnership with global institutions like the World Bank Group, the Arab Monetary Fund, and GIZ, signaling a coordinated push towards a modern financial ecosystem.
The 2024 regulation provides much-needed clarity by defining the key players in Iraq's online payment system. According to the analysis by ALSAIF Law Firm, these roles now include:
Operators: Entities that manage the core technical infrastructure of the payment system.
Participants: Licensed financial institutions that use the payment systems.
Electronic Payment Service Providers (EPSPs): The central players, like e-pay platforms and fintech apps, licensed to provide direct services.
Agents: Those acting on behalf of licensed providers.
The regulation formally authorizes a wide range of activities for licensed EPSPs, including issuing credit and debit cards, managing digital wallets and mobile payments, executing electronic fund transfers, and acting as payment aggregators. This creates a clear legal basis for modern fintech innovation in Iraq.
For local and international finance companies looking to enter or expand in Iraq's emerging market, the new regulation outlines a structured licensing process. Navigating regulatory compliance with CBI Iraq is now more important than ever.
ALSAIF Law Firm's breakdown highlights the key requirements for obtaining a license, which include providing official company incorporation documents, details of founders, and proof of financial solvency. A significant requirement is a minimum company capital of 10 billion IQD and the submission of a comprehensive three-year feasibility study. This study must detail everything from economic projections and technical infrastructure to information security protocols, anti-money laundering (AML) systems, and customer dispute resolution mechanisms.
Once an application is submitted, the Central Bank of Iraq will review and issue a decision within 90 business days, often granting a preliminary license to allow the company time to complete the remaining operational and technical requirements.
The push for this new regulatory framework is a direct response to Iraq's immense potential. As the ALSAIF Law Firm analysis concludes, with a population of over 45 million and the highest projected GDP growth in the Middle East and North Africa for 2026 (4.4% as forecasted by the World Bank), 'the emerging Iraqi financial sector is only getting started.' This new regulation is a foundational step, providing the clarity and stability needed to attract serious investment and build a modern, inclusive, and transparent digital economy.
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