Stream 4 — Section 4 Support

Illustrative Investment Opportunities

Preliminary inventory of investment-grade opportunities in Iraq's TMT sector, evident from desk research. These demonstrate the analytical depth the full study would deliver across EBRD's investment assessment framework.

Opportunities

Opportunity I
Zain Iraq — 5G Network Modernisation & Capacity Expansion

Zain Iraq is the country's largest mobile operator by revenue ($1.1B, 11% year-on-year growth) and has an active network modernisation programme with Nokia. A dedicated financing facility could support the transition from 4G to 5G across urban and semi-urban coverage areas, enabling enterprise connectivity and reducing Iraq's dependence on satellite and imported bandwidth. Zain's balance sheet and revenue trajectory make it the most conventionally bankable MNO in the Iraqi market.

Strong transition impact through infrastructure modernisation and competitive market development. Clear financial viability given Zain's revenue base and growth trajectory. Policy engagement potential around spectrum allocation and 5G licensing conditions.

Senior Loan Syndicated Loan TC Grant (spectrum reform)

Detailed financial profile of Zain Iraq (revenue, EBITDA, capex trajectory, debt capacity), market sizing of the 5G enterprise and consumer segments, regulatory risk assessment of spectrum allocation timelines, and benchmarking against comparable EBRD MNO transactions in the SEMED region.

Opportunity II
Asiacell — Enterprise Digital Services & Edge Computing

Asiacell (Ooredoo subsidiary) has the strongest network quality metrics in Iraq and has already deployed a 5G pilot in Erbil alongside multi-access edge computing (MEC) nodes in Baghdad. The operator is positioning itself for the enterprise and institutional connectivity segment — oil and gas, banking, government — which remains largely unserved by dedicated digital infrastructure. A structured financing could accelerate this enterprise pivot and MEC rollout.

High transition impact through private-sector enterprise digitalisation and competitive differentiation in the operator market. Ooredoo's institutional backing provides a credible repayment pathway and co-investment capacity.

Senior Loan Equity Investment Trade Finance Facility

Enterprise connectivity demand analysis (segmented by oil/gas, financial services, government), competitive positioning assessment versus Zain and prospective state-owned entrants, MEC infrastructure cost modelling, and evaluation of Ooredoo Group's cross-border synergies with regional EBRD portfolio companies.

Opportunity III
FIG Submarine Cable — International Connectivity & Transit Hub Positioning

The Fibre-in-the-Gulf (FIG) cable system, landing at Al-Faw and jointly developed by Ooredoo and ITPC, will deliver over 700 terabits of capacity connecting the GCC to Europe through Iraqi territory. This positions Iraq as a potential international data transit corridor — a structural shift from its current status as a connectivity importer. The project requires substantial last-mile and interconnection infrastructure to realise its domestic economic benefits.

Significant transition impact: transforms Iraq's role in regional digital infrastructure from consumer to intermediary. Strong policy engagement around open-access frameworks, transit pricing regulation, and cross-border data governance. The public-private structure (ITPC + Ooredoo) creates scope for institutional capacity building.

Syndicated Loan Guarantee TC Grant (regulatory framework) Blended Finance

Transit revenue modelling and pricing benchmarks from comparable corridors (Turkey, Egypt), assessment of interconnection infrastructure gaps between Al-Faw landing and domestic backbone, analysis of open-access and wholesale regulatory frameworks, and risk mapping of the ITPC governance structure.

Opportunity IV
Fibre-to-the-Home Infrastructure Buildout

Iraq has deployed approximately 4.5 million FTTH lines, of which only 1.5 million are active, against a government target of 6 million. The gap between deployed and activated lines suggests both demand-side constraints (pricing, digital literacy) and supply-side challenges (last-mile completion, CPE provisioning). A dedicated FTTH infrastructure financing — potentially through an independent fibre company (FibreCo) or infrastructure-sharing vehicle — could accelerate deployment while improving capital efficiency across operators.

Core transition impact through broadband access expansion, with downstream effects on digital inclusion, e-government, and private sector productivity. Policy engagement around infrastructure sharing, open-access regulation, and universal service obligations.

Senior Loan Equity Investment (FibreCo structure) Blended Finance (EU co-financing) TC Grant (infrastructure sharing framework)

Geo-spatial analysis of deployed versus activated fibre by governorate, cost modelling for last-mile completion in urban and peri-urban areas, assessment of FibreCo / infrastructure-sharing structures from comparable EBRD markets (Jordan, Morocco), and demand-side analysis of the activation gap (pricing, digital literacy, CPE barriers).

Opportunity V
Carrier-Neutral Data Centre Development — Baghdad & Erbil

Iraq's data centre market is nascent: current capacity is extremely limited, most enterprise data is hosted abroad or on-premises, and there is no carrier-neutral colocation facility of regional significance. As FIG submarine cable connectivity comes online and domestic fibre expands, demand for local hosting, content caching, and cloud on-ramps will grow substantially. Baghdad and Erbil represent the most viable initial locations given population density, enterprise concentration, and relative infrastructure readiness.

Transition impact through private-sector infrastructure development and enabling downstream digital services (cloud, SaaS, fintech). Carrier-neutral design promotes competitive market structure. Financial viability is contingent on anchor tenancy commitments, which the study would assess.

Equity Investment Senior Loan Guarantee

Data centre demand assessment (enterprise, government, content delivery network operators), power and connectivity infrastructure audit for candidate sites, competitive landscape analysis including regional players eyeing Iraqi market entry, and financial modelling of a phased build (initial 1–2 MW, expandable) with anchor tenancy scenarios.

Opportunity VI
CMC Institutional Strengthening & Spectrum Management Reform

Iraq's Communications and Media Commission (CMC) faces capacity constraints that affect licensing efficiency, spectrum management, and enforcement. With 5G deployment imminent and a potential fourth mobile operator (NMTC) entering the market, the CMC will need to manage increasingly complex spectrum allocation, interference management, and competitive oversight responsibilities. A technical cooperation programme — potentially paired with EBRD lending conditionality — would build institutional capacity while de-risking the broader investment environment.

Directly serves the policy engagement pillar. Creates enabling conditions for every other TMT investment by improving regulatory predictability and licensing transparency. Strong precedent in EBRD TC grants across SEMED telecoms regulators.

TC Grant Blended Finance (paired with investment conditionality)

CMC organisational capacity assessment, gap analysis against ITU benchmarks for regulatory independence and spectrum management, roadmap for 5G spectrum assignment (band plan, auction design, timing), and identification of TC-eligible workstreams with scoped terms of reference for follow-on advisory mandates.

Opportunity VII
Digital Financial Services & Payments Infrastructure

Iraq remains overwhelmingly cash-based: electronic payments penetration is among the lowest in the MENA region. Mobile money, merchant acquiring, and digital lending infrastructure are at an early stage, though regulatory appetite for modernisation is growing. EBRD's existing Star Venture programme in Iraq (launched February 2026) creates a complementary pipeline for fintech equity investments. A broader DFS infrastructure play — payment switches, interoperability layers, merchant acquiring networks — would address the foundational layer that individual fintechs require to scale.

Strong transition impact through financial inclusion and formal economic activity. Policy engagement around electronic payment regulation, KYC/AML frameworks, and central bank digital infrastructure planning. Synergies with existing EBRD Star Venture deal flow.

Equity Investment Trade Finance Facility TC Grant (regulatory framework)

Digital payments market sizing (current volumes, growth trajectory, addressable segments), regulatory landscape assessment for e-money and mobile financial services licensing, mapping of existing infrastructure (payment switches, interbank clearing, mobile money rails), and identification of investable DFS platforms with analysis of MNO-led versus bank-led versus independent models.

Value Proposition

These seven opportunities span the full depth of Iraq's TMT investment landscape: from bankable private-sector operators (Zain, Asiacell) through strategic infrastructure plays (FIG, FTTH, data centres) to enabling institutional reforms (CMC) and emerging ecosystem investments (DFS). Taken together, they demonstrate that Iraq is not a single-thesis market — it offers a pipeline of structurally distinct opportunities, each suited to different EBRD financial products and risk appetites.

The proposed study would move each of these from desk-research hypothesis to investment-grade assessment, delivering the financial modelling, regulatory risk analysis, and market sizing that EBRD project teams require to advance from concept to mandate.

Editorial Decisions

Excluded Korek Telecom — its $1.3B government debt and suspended services make it a restructuring story rather than an illustrative investment opportunity at this stage. The study would assess it, but including it here would undercut the tone of analytical confidence.
Excluded NMTC — the judicial freeze creates too much uncertainty to present as illustrative. Flagged in the FIG and CMC entries as contextual risk (fourth operator entry), which is the right level of treatment.
Ordered opportunities from most bankable (Zain) to most structurally complex (DFS), creating a narrative arc from near-term lending to ecosystem development.
Referenced EBRD precedent transactions (Tunisie Telecom, Orange Egypt, Star Venture, Project BRIDGE) by implication rather than direct citation — the brief's framing language should match the proposal's voice rather than name-checking deal sheets.
Maintained consistent treatment of risk throughout: acknowledged complexity (activation gap, governance structures, judicial freezes, cash-based economy) without foregrounding it, per the brief's guidance that these should read as "seeds of investment memos."