Iraq's telecommunications, media, and technology sector represents one of the largest underpenetrated digital markets in the Middle East. With a population of approximately 45 million — young, urbanising, and increasingly data-hungry — the country's TMT market reached an estimated $2.88 billion in 2025 and is projected to grow at a compound annual rate of roughly 3.4 percent, reaching $3.53 billion by 2031. The opportunity is not speculative: it is grounded in demonstrable demand, accelerating infrastructure deployment, and a regulatory environment that, while complex, is actively evolving. This study arrives at a pivotal moment — EBRD has become operational in Iraq and is building its first TMT investment pipeline in the country. Our team approaches the assignment not merely as a diagnostic exercise, but as the analytical foundation for that pipeline.
The Iraqi mobile market is structured around three operators: Zain Iraq, the market leader with an estimated 53 percent revenue share and $1.1 billion in 2024 revenues (11 percent year-on-year growth); Asiacell, the Ooredoo-backed challenger at roughly 31 percent, which currently operates 8,201 LTE sites and has launched a 5G non-standalone pilot in Erbil; and Korek Telecom, a Kurdish-owned operator holding approximately 16 percent but carrying $1.3 billion in outstanding government debt and facing active regulatory and parliamentary scrutiny — including suspension of its internet services by the Communications and Media Commission in February 2025. Mobile penetration remains at 75–78 percent, below the regional average, even as SIM penetration exceeds 100 percent — a gap that signals both multi-SIM behaviour driven by patchy coverage and genuine room for subscriber growth. Internet penetration has reached 81.7 percent, data and internet services now account for 51.5 percent of total market revenue, and average mobile download speeds have improved 25 percent year-on-year to 36.4 Mbps. The market is transitioning: voice revenues are declining, data monetisation is nascent, and enterprise digital services are emerging as a growth segment at an estimated 4.01 percent CAGR.
Infrastructure investment is accelerating across the value chain. Fixed broadband — historically Iraq's weakest layer — has seen fibre-to-the-home deployments scale from roughly one million lines to 4.5 million, with approximately 1.5 million now active and a stated target of 6 million lines for non-KRG Iraq against a total addressable base of 8.5 million households. On the backbone side, the Iraq Telecommunications and Post Company (ITPC) operates the national terrestrial network, and a strategically significant submarine cable project is advancing: an agreement between Ooredoo and ITPC for the FIG cable at the Al-Faw landing station — a 24-pair, 700-plus terabit system connecting the Gulf Cooperation Council states to Europe through Iraqi territory. Alongside connectivity, early-stage cloud and edge infrastructure is taking shape, with Asiacell deploying multi-edge computing nodes in Baghdad to serve a growing enterprise customer base. These are not future possibilities — they are capital programmes already underway, each carrying distinct risk profiles, financing needs, and entry points for institutional investors.
The regulatory landscape requires careful navigation. The CMC functions as an independent regulator, separate from the Ministry of Communications — a jurisdictional distinction that is not merely administrative but politically live. The three MNO licences, originally issued in 2007 for fifteen-year terms, entered contested renewal territory after a court annulled an extension in 2020; the terms under which operators currently hold spectrum remain a central question for any investor assessing long-term concession risk. Transparency is being actively pursued: KPMG has been engaged to audit MNO revenues for the 2017–2022 period. Frameworks for cybersecurity and data governance remain underdeveloped, creating both risk and — for the right operator or platform — an advisory and capacity-building opportunity aligned with EBRD's broader institutional development mandate.
The most consequential recent regulatory development is the Cabinet-approved creation of a National Mobile Telecommunications Company (NMTC), envisioned as a fourth operator in partnership with Vodafone under a partner-market model. PM Al-Sudani signed the Articles of Incorporation in August 2025. However, since October 2025, the initiative has been judicially frozen due to disputes between the CMC and the Ministry of Communications over implementation authority and exclusivity provisions. The NMTC's outcome — whether it proceeds, is restructured, or collapses — will materially reshape the competitive landscape, spectrum allocation, and the investability of both incumbent and greenfield assets. This study must account for multiple scenarios without presupposing resolution.
EBRD's entry into Iraq's TMT sector is a natural extension of the Bank's broader regional strategy. Iraq was approved as an economy of operations in 2025, and EBRD's first investment — a $100 million trade finance facility to the National Bank of Iraq — was executed in September of that year. The Bank's conflict-response framework targets €5 billion in deployment across Middle Eastern economies including Iraq in 2026, and the Strategic and Capital Framework 2026–2030 names Iraq expansion as a growth priority. Within TMT specifically, EBRD's Sector Strategy 2025–2029 articulates a vision of "inclusive, resilient, and green digital economies," framing digital infrastructure and tech-enabled products and services as mutually reinforcing components of an integrated digital landscape. The Bank has demonstrated this approach in practice: a €50 million facility to Tunisie Telecom supporting the transition from 4G to 5G alongside fibre expansion and cybersecurity capacity; €68 million to Orange Egypt for 5G rollout; and $100 million to Nigeria's Project BRIDGE for 90,000 kilometres of fibre backbone. Iraq's TMT sector presents an opportunity of comparable scale and strategic significance — but one that requires the granular, market-specific analysis this assignment is designed to produce.
We understand the assignment as carrying a dual mandate: first, a rigorous sectoral diagnosis and mapping that captures the full topology of Iraq's TMT ecosystem — operators, infrastructure players, ISPs, tower companies, data centres, digital platforms, and the regulatory architecture governing them; and second, an investment opportunity identification process calibrated to EBRD's risk appetite, additionality criteria, and transition-impact framework. Our team is structured, and our methodology designed, to deliver both — moving from landscape to pipeline with the analytical precision the Bank requires to make allocation decisions in a market where quality information is scarce and first-mover advantage is real.