EBRD TMT Sector Assessment · Multi-Stream Synthesis

Iraq: Technology, Media & Telecommunications
Market Landscape Study

Integrating findings from Streams 4 (Telecom Operators), 5 (Digital Infrastructure), 6 (Regulatory), and 9 (FDP Labor Supply) into the core TMT assessment
v2 · April 2026 · Cross-stream integration complete

01 · Market Context & Macro Fundamentals

Iraq presents one of the most compelling—and complex—frontier technology investment cases in the MENA region. Population exceeds 43 million, 60% under 25. Mobile penetration sits around 102% (multi-SIM), internet penetration ~75%, smartphone penetration ~82%. GDP per capita ~$4,775—higher than every North African country except Libya. The World Bank forecasts 4.4% GDP growth for 2026, the highest projected rate in MENA.

The financial system is strikingly underdeveloped: formal bank-account ownership hovers around 11–20% of adults (among MENA's lowest), with over 10 million pre-paid cards in circulation and 20+ trillion IQD in electronic transactions in 2024. Digital transaction volumes surged from 2.6 trillion to 7.6 trillion IQD in a single year—a threefold increase suggesting inflection rather than linear growth. The CBI has mandated all government payments be electronic by July 2026.

The government's National Development Plan 2024–28 ($184 billion budget) prioritises ICT, agriculture, manufacturing, and tourism. The Iraq Development Road project ($17 billion—highway and electrified railway from Basra's Grand Faw Port through Iraq to Turkey/Europe) will generate massive construction-tech and logistics demand. The EBRD began Iraq operations in September 2025 ($100M trade finance facility to National Bank of Iraq), with Star Venture programme launched for startups.

Structural tension for EBRD: Iraq combines high mobile penetration, ultra-low banking penetration, and a massive youth bulge—the classic profile for mobile-first fintech leapfrogging. Whether regulatory, trust, and infrastructure barriers continue to suppress that potential or whether the 2024 EPSR and adjacent reforms catalyse breakout growth is the central question.

02 · Telecom Landscape: The Effective Duopoly

From Stream 4 (Telecom Operators): Zain Iraq FY2025 revenue $1.29B (+20% YoY). Asiacell FY2024 ~$1.42B. Combined ~80% market share = effective duopoly. Korek distressed (>$3B ICC arbitration, $800M unpaid CMC fees, subscribers collapsed 11.6M→8.2M). NMTC (state-backed, Vodafone partner) authorized March 2025, judicially suspended October 2025.

Zain Iraq

Zain Iraq · Kuwait's Zain Group subsidiary

FY2025 revenue $1.29B +20% YoY. Q1 2025 revenue $286M (+13%), EBITDA $105M (+13%), net income up 73%. Approximately 15.7–18M active subscribers (~37–42% share). Nokia three-year accord (2024) inserted 3,000 high-capacity E-band microwave hops, raising cell throughput 35%. Operates Zain Cash via subsidiary Iraq Wallet. Co-designs managed private-LTE with Schlumberger for oilfield automation. Carrier billing for Shahid VIP, STARZPLAY, Anghami Plus. Combined tower JV with Ooredoo to reduce opex. PM met Nokia delegation (May 2025) to discuss 5G and AI infrastructure expansion.

Asiacell

Asiacell · Ooredoo Group majority-owned

FY2024 revenue ~$1.42B. Subscriber base 19.1M by end-2024 (+8% YoY)—now rivalling or exceeding Zain. Operates 8,201 LTE sites; piloting 5G NSA for enterprise clients in Erbil's oil-service corridor. Won all nine Opensignal awards (January 2025 Iraq report): best download speed (27.9 Mbps), reliability, video experience. Operates AsiaHawala mobile money (launched December 2015, powered by Comviva's mobiquity platform). Signed MoU with China Mobile International (June 2025) for B2B/enterprise digital solutions. Deploying multi-edge computing in Baghdad for low-latency cloud workloads. Launched Shofha video portal. Also operates Oodi as Ooredoo's fintech vehicle.

Korek Telecom — Distressed

Korek Telecom · Kurdistan-based, distressed

Market share collapsed from 34.8% (2015) to under 19%. Subscribers fell from 11.6M → ~8.2M. >$3B ICC arbitration exposure (Orange/Agility lawsuit awarded $1.65B for alleged corrupt practices; DIFC Courts hearing appeal). $800M unpaid CMC fees. CMC temporarily blocked Korek's interconnection in late 2023, pushing customers to obtain second SIMs with competitors. CMC ordered internet service suspension (February 2025) over outstanding debts and violations. Launched 4G only in 2021—well behind competitors. Differentiates via Kurdish-language content bundles. Any technology or fintech layered on Korek infrastructure carries significant counterparty risk.

NMTC — The Suspended Fourth Player

NMTC · State-backed, judicially suspended

The Iraqi Cabinet approved the National Mobile Telecommunications Company in March 2025 to operate a nationwide 5G network under a three-year exclusive licence. Ownership is entirely public: State Employees' Pension Fund + Trade Bank of Iraq + Al-Salam General Company (Ministry of Communications). Under a "Partner Market" framework, Vodafone was selected as technical/commercial collaborator (brand use, systems, training—no equity).

PM Al-Sudani formally inaugurated NMTC on August 31, 2025. However, a specialist security judge suspended the licence signing on October 8, 2025, following a lawmaker's letter and concerns about transparency. The West Point Combating Terrorism Center published an analysis (November 2025) alleging the NMTC deal was structured around companies linked to designated militia-connected entities, with Vodafone's role limited to a "respectable wrapper." Minister Al-Yasiri stated no contract had been concluded with Vodafone—"only a memorandum of understanding exists"—and the first test call (planned November 2025) was postponed indefinitely.

Impact on TMT landscape: The NMTC suspension creates fundamental uncertainty for any technology or fintech service layered on MNO infrastructure. If NMTC launches, it introduces a sovereign-backed competitor with exclusive 5G rights for three years. If it doesn't, existing operators may eventually receive 5G spectrum—but on an uncertain timeline. This uncertainty suppresses private-sector investment in 5G-dependent services (IoT, edge computing, high-bandwidth enterprise) and complicates EBRD due diligence on telecom-adjacent investments.

Infrastructure Economics

Average mobile download speed reached 36.39 Mbps in 2025 (+25.1% YoY). Data/internet services captured 51.55% of MNO market share in 2025 (overtaking voice for the first time). Outstanding government receivables tighten operator cash flows: Asiacell at IQD 121 trillion, Zain Iraq above $4M. Corporate tax is 15%, but import duties on telecom gear fluctuate, complicating capex planning. Currency volatility (dinar vs. vendor billing currencies) further clouds budgeting.

03 · Digital Infrastructure: IXP, Submarine Cables & the Data Center Gap

From Stream 5 (Digital Infrastructure): IRAQ-IXP (DE-CIX operated, Baghdad) reached 28 networks and 180 Gbps peak traffic in 12 months — 3rd largest IX in Middle East. Meta, Akamai, Tencent connected. Iraq jumps from 2 to 5–6 submarine cables by 2027. Zero functional carrier-neutral data centers exist. EarthLink built 800 fiber distribution terminals (600K-home capacity) but MoC activation is slow.

IRAQ-IXP: A Breakout Story

IRAQ-IXP (operated by DE-CIX under its DaaS model, hosted at the Iraq Connectivity Gateway data center in Baghdad) went live in February 2024 with 12 connected networks. Within one year it climbed to 28 networks (including Meta, Akamai, Tencent) and 180 Gbps peak traffic—a 150% increase since January 2025—making it the 3rd largest IX in the Middle East by connected networks. CEO Ahmed Rakwi's stated vision: "to position Iraq as a digital hub for the region."

Why this matters for the TMT study: An IXP with major CDN presence (Meta, Akamai, Tencent) fundamentally changes the economics of local content delivery, cloud services, and streaming. Before IRAQ-IXP, Iraqi internet traffic tromboned through international transit—adding latency, cost, and fragility. With local peering, content loads faster, streaming buffers less, and cloud services become viable for enterprise. This directly enables: the OTT/streaming market (Section 07), fintech apps that require low-latency transaction processing, and enterprise cloud adoption.

Submarine Cable Pipeline: From 2 to 5–6 Systems

Iraq currently has only two in-service international submarine cables landing at Al-Faw (Basra): FALCON (Global Cloud Xchange) and GBI (Gulf Bridge International, Iraq's first subsea cable, landed 2012). The incoming pipeline represents a step-change:

Incoming Submarine Capacity

2Africa PEARLS (Meta-led consortium, ~180 Tbps design capacity, contract with STC to land at Al-Faw, signed early 2024). Core 2Africa infrastructure completed November 2025; PEARLS Gulf extension was scheduled for 2026 but has been paused—Alcatel Submarine Networks declared force majeure due to Iran-related Gulf hostilities (March 2026). Timeline now uncertain.

Fibre in Gulf (FIG) (Ooredoo Group, 720 Tbps, built by Alcatel Submarine Networks, connecting Qatar-Oman-UAE-Bahrain-Saudi-Kuwait-Iraq). Ooredoo/ITPC landing party agreement signed March 2025. Service expected Q4 2027. Ooredoo separately committed $500M to overland routes from Iraq through Turkey to Europe.

Khaleej North (SEA-ME-WE 6 extension): Confirmed to land in Iraq. Also subject to Gulf conflict-related delays.

WorldLink Transit: Terrestrial corridor announced February 2025 by consortium of Iraq's Tech 964, UAE-based Breeze Investments, and Iraq-Kurdish DIL Technologies.

Silk Route Transit: Existing terrestrial fibre-optic cable across Iraq (3,500 km, six cable landing stations), operated by iQ Group.

Critical risk update (March 2026): The Iran-related Gulf conflict has caused force majeure on the 2Africa PEARLS extension. This potentially delays the most significant capacity upgrade. However, the FIG cable (Q4 2027 target), Ooredoo's overland Turkey route, and multiple terrestrial corridors provide redundancy. Iraq's positioning as a Gulf-to-Europe transit corridor is actually strengthened by Red Sea/Hormuz disruptions, as traffic seeks overland alternatives.

The Data Center Gap

Zero functional carrier-neutral data centers exist in Iraq. The Iraq Connectivity Gateway (ICG) in Baghdad hosts IRAQ-IXP but is not a full-scale colocation facility. This gap is critical: without carrier-neutral DCs, enterprises cannot colocate with cloud providers, CDNs cannot establish local PoPs at scale, and the IXP ecosystem cannot fully develop. This is a high-priority EBRD infrastructure investment opportunity (see Section 11).

Last-Mile Fiber: The MoC Bottleneck

EarthLink Iraq (100% Iraqi-owned, largest ISP, 5,200+ free public Wi-Fi access points) has built 800 fiber distribution terminals with capacity to serve 600,000 homes. However, Ministry of Communications activation is slow—a policy bottleneck, not an infrastructure one. iQ Networks partnered with Gulf Bridge International to launch Iraq's first dark fibre IRU framework in Baghdad (January 2025). ITPC (government-owned) operates the public telephone network, fibre backbone, and microwave infrastructure.

04 · MNO Fintech Strategies

The Primary Fintech Vehicles

Iraq's mobile money landscape is anchored by three MNO-affiliated wallets, each CBI-licensed, plus a set of independent fintech providers that increasingly compete for the same underbanked population.

Zain Cash · Zain Iraq's fintech vehicle (via Iraq Wallet)

Launched 2016. 1M+ active users 35M transactions (2024). Over 1.2M app downloads, 10,000 agent outlets nationwide. Users link wallets to SIM cards for P2P transfers, bill payments, merchant payments, digital shopping. BNPL (buy-now-pay-later) roadmap in development—this would be Iraq's first consumer credit product delivered through mobile money rails. Zain Cash is the primary rail for UNHCR humanitarian disbursements to refugees in Iraq (iris-scan verification, dual-document KYC).

AsiaHawala · Asiacell's mobile money play

Launched December 2015—Iraq's first mobile money service. Powered by Comviva's mobiquity platform. Creates stored-value accounts linked to mobile numbers. P2P transfers, salary/pension/aid receipt, bill payments, mobile top-up, e-vouchers. Mobile number = unique identifier.

Oodi · Ooredoo's fintech vehicle

Ooredoo Group's fintech play, operating alongside AsiaHawala within the Asiacell ecosystem. Positioning within the broader Ooredoo digital services stack that includes FIG submarine infrastructure and enterprise connectivity.

Independent Fintech Providers

Qi Card / ISC (founded 2007/2009 by Bahaa Abdul Hadi): Largest by reach—11M+ users, 23,000 POS terminals across every governorate including remote villages. Biometric authentication, geofencing, real-time monitoring. Three-year partnership with K2 Integrity for AML oversight. Exploring UAE/Jordan expansion. Acquired Miswag (November 2024) and owns Digital Zone (5M+ users, 41M+ orders). MFTA Iraq Chapter chair. Projects cash below 50% of urban retail spending by 2030.

NassWallet: Processed $1B+ in transactions (2022). Partnered with IrisGuard for UNHCR disbursement to 280,000+ refugees via biometric verification.

FastPay (est. 2017, Kawa Junad—founder of Newroz Telecom): App-based wallet for deposits, withdrawals, mobile recharge, online shopping, P2P.

Neo Pay: Leading payment service provider focused on merchant acceptance infrastructure.

Wayl ($150K pre-seed from EQIQ): Payments platform for online sellers; enables social-media merchants to accept payments without company registration. QR payments via First Iraqi Bank partnership. E-payments grew 11x in 2024 (100M+ IQD processed).

Airtime Lending & Micro-Credit

Nascent relative to East African markets. Zain Cash's BNPL roadmap represents the first serious attempt at consumer credit through mobile money rails. The 2024 EPSR formally authorises EPSPs to issue credit instruments, which could unlock airtime-based lending if credit-scoring models are developed. The challenge is data: Iraq lacks credit bureaux, and alternative data scoring (mobile usage patterns, top-up frequency, social graph) has not been commercialised at scale. Zain Cash's 35M transactions in 2024 provide a meaningful dataset for building scoring models—this is a concrete near-term opportunity.

Cross-Border Payments & Remittances

Iraq is both a remittance-receiving country (diaspora from Europe, North America, Gulf) and a humanitarian-transfer corridor. The 2024 regulation formally defines Foreign Transfers Service Providers. Qi Card has pursued cross-border capability aggressively, though US scrutiny over potential sanctions-evasion vectors led to blocking thousands of suspicious cards and capping cross-border volumes. The hawala (informal value transfer) system remains deeply embedded, particularly in areas with limited formal infrastructure.

Competition Dynamics & Blockers

What's Been Attempted, What's Failed, and Why

Iraq has had mobile money since 2015. Growth has been real but incremental. The blockers are interlinked and mutually reinforcing:

Interoperability gaps (the binding constraint): Wallets remain siloed. No unified national payment switch comparable to India's UPI or Jordan's CliQ. Cross-wallet transfers are limited. This is the single most impactful intervention point for a DFI.

Trust deficit: Decades of banking-sector mismanagement and corruption. Qi Card's chairman: "teaching the Iraqi society why a tap or QR code scan is safer than a bundle of banknotes requires patient, empathetic education."

Digital literacy: Consistently identified as the largest adoption barrier, even by operators.

Infrastructure: Electricity cuts, connectivity gaps outside urban centres, absent national postal service.

Regulatory (now easing): The 2024 EPSR replaced a decade-old law. CBI launched the National Financial Inclusion Strategy (May 2025, with World Bank/Arab Monetary Fund/GIZ). Digital-bank licensing guidelines issued March 2024. e-KYC regulations in place. But see Section 08 for CMC and tax-burden constraints that undercut these reforms.

05 · Broader Technology Sector Assessment

Iraq's startup ecosystem ranks 118th globally, 11th in Middle East (StartupBlink 2025). Baghdad: 64.3% annual growth in ecosystem ranking. Estimated $30–40M VC investment in 2024. ~1,217 tracked startups. E-commerce, delivery/logistics, and fintech are the most active verticals.

E-Commerce & Marketplaces

Digital commerce transaction value projected at $10.23B (2024). Cash-on-delivery remains dominant but shifting—Orderii saw e-payment share surge 50%→95% in 2024. Key players: Miswag (acquired by Qi Card Nov 2024), Orisdi (Al Sharqiya partnership), Tamata (Earthlink Group), Simma ($12.3M transactions facilitated), Digital Zone (Qi Group, 5M+ users), Pure Platform (ISC-backed). The Qi Card–Miswag acquisition signals consolidation toward integrated financial-commerce ecosystems. DFI potential: moderate-to-high.

E-Logistics, Delivery & Transport

Highest immediate venture activity. Lezzoo (YC S19, super-app, 50K+ monthly orders, covering 50%+ of Iraq, launched JIRAN social-commerce + Lezzoo Pay wallet). Baly ($10.5M seed, Kingsway Capital/MSA Novo/Rocket Internet-backed, ride-hailing+delivery). Alsaree3 / Al Zajel (Series A with Snoonu, Qatar). Boxy ($1.5M EQIQ, AI logistics aggregator unifying 1,500+ couriers). Sandoog (fulfilment). Hi-Express (IAIN-funded). DFI potential: high. Logistics is critical infrastructure for all other digital-economy verticals.

B2B Supply Chain Tech

Toolmart (seed round, Plus VC/Oasis500). Underdeveloped relative to potential—Iraq's SMEs = 88% of all businesses, supply chains largely informal and cash-based. DFI potential: high but pre-seed.

BPO & IT Services

From Stream 9 (FDP Labor Supply): Only 3% of refugees are English-fluent. Digital/IT labor supply = 5,495 workers. 55% of employed refugees work below qualification level — skills mismatch, not skills absence. This severely limits English-language BPO but Arabic-language digital services and impact sourcing may be viable, especially with incoming bandwidth capacity.

Iraq has not developed a meaningful BPO sector. The FDP labor data from Stream 9 clarifies why English-language outsourcing is not viable at scale (3% English fluency among refugees, 5,495 total digital/IT workers). However, the 55% skills-mismatch finding combined with incoming submarine bandwidth (FIG 720 Tbps by Q4 2027) creates a potential pathway for Arabic-language digital services: content moderation, Arabic NLP training data, customer support for MENA markets. Kurdistan Region's relative stability and higher English penetration remains the most promising BPO geography. Newroz Telecom provides enterprise connectivity that could anchor BPO infrastructure. DFI potential: low-to-moderate near-term, rising with bandwidth.

Cleantech & Agtech

Iraq faces acute water scarcity. Government launched six-year climate-resilience initiative (2025) targeting three governorates. CBI Sustainable Finance Roadmap and ESG Code (September 2024). Nakhla (agritech, Euphrates Ventures). Iraq Response Innovation Lab supports agribusiness incubation. Strongly aligned with EBRD green mandate (56% of 2025 investment = green). DFI potential: moderate, impact-high.

Other Verticals

Autotech: iQ Cars (seven-figure seed, Euphrates Ventures). Edtech: Corrsy ($500K, EQIQ), IoT-Kids (Earthlink/IAIN), Abwaab (Jordan-based, Iraq operations). Asset-heavy tech / construction: KESK (angel-funded). Handset manufacturing: None domestic; net importer; minimal DFI relevance.

06 · Telecom-Technology Crossover

Carrier Billing as Platform Layer

In a market with negligible credit-card penetration, carrier billing—subscription fees deducted from prepaid airtime—is the critical distribution mechanism for digital services. Zain Iraq enables direct-from-balance subscriptions to Shahid VIP, STARZPLAY, Anghami Plus. Asiacell operates Shofha video portal. 1001's telco-bundled distribution (Korek zero-rated data, Zain/Asiacell billing integration) operates on this model. This mirrors the Anghami scaling pattern across MENA.

Data-as-a-Service

Absence of credit bureaux creates a potential role for MNOs as data providers. Zain Cash's 35M transactions (2024) provide a meaningful dataset. Operators hold behavioural data (location, usage patterns, top-up frequency) that could underpin alternative credit scoring. Undeveloped in Iraq but significant medium-term opportunity—especially given BNPL roadmap.

IoT & Enterprise Digitisation

Embryonic. Zain Iraq + Schlumberger managed private-LTE for oilfield automation. Asiacell multi-edge computing in Baghdad. Asiacell + China Mobile International MoU (June 2025) for B2B/enterprise digital solutions. National Development Plan identifies IoT in agriculture, transport, urban development. NMTC suspension creates uncertainty for 5G-dependent IoT use cases.

Tower Infrastructure

Zain-Ooredoo tower JV reduces opex. NMTC was instructed it could piggyback on existing towers—a policy that extracts value from private operators' infrastructure to benefit a state competitor. Independent towercos represent a mature EBRD investment class.

IRAQ-IXP as crossover enabler (Stream 5 integration): The IXP's growth to 28 networks with Meta, Akamai, and Tencent connected transforms the viability of data-intensive crossover services. Edge computing, CDN-based content delivery, and cloud-adjacent enterprise services all require local peering that didn't exist before February 2024. The data center gap (zero carrier-neutral DCs) is now the binding constraint, not the IXP itself.

07 · TV, Pay-TV & IPTV Market Dynamics

Market Structure

Free-to-air satellite broadcasting dominates. Iraq's topography and sporadic power supply reinforce satellite's advantage over cable/IPTV. Traditional pay-TV penetration is low, concentrated in urban hotels/commercial served by dealers like Ritaj (authorised OSN/beIN dealer). The dominant broadcaster is Al Sharqiya Group—two FTA satellite channels, daily audience up to 15M viewers, 25M+ social-media followers.

The OTT Pivot: 1001

1001 (co-founded by Mohsen Khairaldin Garcia, backed by Al Sharqiya) is Iraq's first legal streaming platform. Launched March 2023 as AVOD, attracted 1M+ users in three weeks (80% Iraq, 20% diaspora). Exceeded 2M users by 2024. SVOD tier launched February 2024 (Accedo + Brightcove + Jump technology stack).

Content strategy: (1) 3,000+ hours of exclusive Iraqi-dialect content from Al Sharqiya + 1001 Originals (Raid, New Baghdad, Silencer); (2) 25,000+ hours licensed from OSN+, Rotana, STARZPLAY; (3) co-exclusive LALIGA rights through 2027/28 season with localised studio programming. Distribution is telco-integrated: Korek (zero-rated data), Zain/Asiacell (carrier billing). SVOD at $4.99/month—cheaper than regional competitors. Social-media following of 3.5M with viral user-generated content.

Primary competitor: piracy. Iraq has minimal IP enforcement. 1001's CEO: they will "push more aggressively through regulatory and governmental means" as they scale. Piracy suppression is prerequisite for SVOD viability.

IRAQ-IXP impact on OTT (Stream 5): With Meta, Akamai, and Tencent now connected at IRAQ-IXP, CDN-served streaming can deliver lower latency and higher quality to Iraqi users. This directly improves 1001's viewing experience and reduces bandwidth costs for telco partners. The IXP ecosystem is a critical but under-discussed enabler of the entire OTT/streaming value chain in Iraq.

Competitive Landscape & Growth Potential

Regional platforms (Shahid, STARZPLAY, Netflix) are available but under-invested in Iraqi-specific content. 1001's advantage: hyper-localisation (Iraqi dialect, Iraqi stories, Iraqi celebrities). OTT/Pay-TV is identified as the fastest-growing telecom subvertical. 43M population, 75% internet penetration, 65% under-35, zero prior legal streaming infrastructure = greenfield. 1001 was seeking $15M seed round. EBRD alignment: creative economy employment, IP development, human-capital mandate.

08 · Regulatory Architecture & Tax Burden

From Stream 6 (Regulatory): CMC independence structurally compromised (5 of 6 board seats = political appointees). Entire telecom regime rests on CPA Order No. 65 (2004); draft Telecom Law unenacted for 20 years. 20% internet fee (March 2026) + existing 17%+20% levies = ~57% cumulative tax burden on ISPs. EPSR No. 2 (2024) and Digital Platforms Framework (2025) are newest instruments. CMC SIM registration blocks FDP mobile money access.

The Regulatory Stack

Iraq's telecom regulatory framework rests on a remarkably fragile foundation: CPA Order No. 65 (2004)—a Coalition Provisional Authority order that is now 22 years old. A draft Telecom Law has been unenacted for two decades. This means the entire legal basis for MNO licensing, spectrum allocation, and regulatory authority exists in a transitional occupation-era instrument, not a sovereign legislative act.

CMC (Communications and Media Commission) is the telecom regulator, nominally independent under the Iraqi Constitution. However, structural independence is compromised: 5 of 6 board seats are held by political appointees. This has concrete consequences—the NMTC affair demonstrates how regulatory decisions can be driven by political-commercial interests rather than market logic.

Key Regulatory Instruments

Electronic Payment Services Regulation No. 2 (2024): Replaced the 2014 regulation. Defines operators, participants, EPSPs, agents, and Foreign Transfers Service Providers. Formally authorises digital wallets, mobile payments, electronic fund transfers, payment aggregation, and credit instrument issuance. Aligns with the National Financial Inclusion Strategy (May 2025, developed with World Bank/AMF/GIZ).

Digital Platforms Framework (2025): Newest regulatory instrument governing digital service delivery.

Digital Bank Licensing Guidelines (March 2024): CBI framework for establishing digital banks. Applications require financial feasibility studies, non-refundable licence fees, and robust IT security infrastructure.

CMC Influencer Registration Fees (March 2025): IQD 250,000–1,000,000 for social-media influencers. Demonstrates unpredictability of ancillary levies that can erode margins for value-added services.

The ~57% ISP Tax Burden

Critical for tech-service economics: A 20% internet fee was introduced in March 2026. Combined with existing levies (17% + 20%), the cumulative tax burden on ISPs reaches approximately 57%. This has profound implications for every data-intensive technology business in Iraq. Streaming services, cloud platforms, SaaS products, e-commerce, and fintech apps all depend on affordable connectivity. A 57% tax burden on the underlying infrastructure gets passed through—partially or fully—to end users and businesses, raising the effective cost of digital participation and potentially suppressing the very adoption the government's National Development Plan is trying to accelerate.

This creates a paradox at the heart of Iraq's digital transformation: the CBI and Ministry of Planning are actively reforming financial regulation and investing in digital infrastructure, while the fiscal authorities (through CMC-administered levies) are taxing the connectivity layer that makes all of it work. For EBRD, this tax burden must be factored into every investment thesis that depends on affordable connectivity—which is essentially all of them.

09 · Ecosystem Participants

Venture Capital & Investment Funds

EQIQ · Abu Dhabi (ADGM) · Iraq-focused VC + venture builder

Co-founders: Mohamed Al-Hakim (ex-Goldman Sachs, ex-Careem Iraq/Jordan), Said Rahmani. First close Jan 2023 at $15M; doubling to $30M. Deployed $8.5M across five: Wayl (payments), InstaBank/Al-Fawr ($3M, digital bank), Fedshi (social commerce), Boxy ($1.5M, logistics), Corrsy ($500K, edtech). 80% of capital → integrated e-commerce/logistics/fintech ecosystem. Currently most active Iraq VC.

Euphrates Ventures

Dedicated Iraqi VC. Investments: iQ Cars (seven-figure seed), Nakhla (agritech), Alsaree3 co-investment.

Iraq Venture Partners (IVP)

Laura Khudairi, Bassam Falah. Manages Orange Corners Innovation Fund ($2.7M Phase 2 from Netherlands). Gateway Fund (2025) for pre-Series A / Series A ($1M+ tickets).

Other investors: Northern Gulf Partners (NY/Baghdad, led Lezzoo seed), MSA Novo (Iraq Islamic Bank tech fund partnership), Kingsway Capital (Baly $10.5M seed), Iraq Tech Ventures, Innovest Middle East, Crossboundary, Vostok Ventures, Plus VC, Oasis500, IAIN, Pay It Forward VC, Nawat VC Studio (Netaj, targets 40 startups/year).

Accelerators & Hubs

KAPITA (Orange Corners Baghdad, Bridge Baghdad programme), Five One Labs / Five One Invest (Ignite pre-incubation, "State of Investments in Iraq" report), Netaj / Nawat (VC studio, Baghdad), The Station (Baghdad, coding bootcamps), Takween Accelerator, Orange Corners Baghdad (Dutch-funded), Zain Iraq Incubator, Founder Institute Baghdad, Iraq Response Innovation Lab (agribusiness).

DFIs & Government

EBRD: Iraq operations September 2025. $100M NBI trade finance. Star Venture. SME finance programmes launched February 2026. SCF 2026–30 priority. IFC: PROSPECTS Partnership; Scale-up initiative with IVP/Innovest. World Bank: $930M Railways project; Financial Inclusion Strategy partner. UNDP: Supported EPSR with USAID funding. ILO: Financial inclusion initiative with CBI under PROSPECTS. UNHCR: Cash assistance via Zain Cash; "Displaced and Disconnected" research. GIZ / Netherlands: PROSPECTS, Orange Corners co-funders.

Government bodies: CBI (primary financial regulator), CMC (telecom regulator, compromised independence), Ministry of Communications (NMTC sponsor), ITPC (public telecom/fibre operator), Ministry of Planning, MoLSA, KRG (MyAccount: 600K+ civil servants banked), MSMEDA, MFTA Iraq Chapter (Bahaa Abdul Hadi, chair).

10 · FDP Financial Inclusion Nexus

From Stream 6 (Regulatory): CMC SIM registration requirements block FDP mobile money access. CBI KYC rules exclude refugees from formal banking. From Stream 9 (FDP Labor): Only 3% English-fluent. Digital/IT labor supply = 5,495. 55% work below qualification level.

Scale of Displacement

~1 million IDPs; 5 million returned IDPs with persistent socioeconomic challenges; 330,000+ refugees/asylum-seekers (90%+ Syrian, predominantly in Kurdistan Region—34% in camps, 66% urban in Erbil/Dohuk/Sulaymaniyah).

The Regulatory Double-Lock on FDP Financial Access

Stream 6 findings reveal a structural double-lock on displaced-population financial inclusion:

Lock 1 — CMC SIM registration: Mobile money requires a SIM. SIM registration requires documentation that many FDPs lack. The same regulator (CMC) that governs telecom also controls the identity-verification gateway to mobile financial services. This is not merely a banking-sector issue—it is a telecom-regulatory issue that belongs in the TMT assessment.

Lock 2 — CBI KYC rules: Formal banking KYC requirements exclude refugees without standard Iraqi documentation. Even if FDPs access a SIM and a mobile wallet, the absence of tiered/simplified KYC (as exists in Jordan and Egypt) prevents them from graduating to more complex financial services (savings, credit, insurance).

UNHCR's "Displaced and Disconnected" research (2022) mapped these barriers across Iraq, Egypt, Jordan, and Lebanon. The finding: without valid civil documentation, FDPs cannot complete KYC for formal financial services; without financial services, they cannot build stability to regularise status—a self-reinforcing exclusion cycle.

Mobile Money as FDP Inclusion Rail (Current State)

UNHCR uses Zain Cash for cash assistance: iris-scan + dual documentation (Iraqi govt ID + UNHCR certificate). NassWallet + IrisGuard delivered UNHCR aid to 280,000+ refugees via biometric verification. In February 2023, MoLSA decided to assess 180,000 IDPs for enrolment in the Social Safety Net (~$85/month/person), prioritising IDP assessment regardless of online registration status.

FDP Labor Supply and Tech-Sector Implications

Stream 9 data fundamentally shapes the BPO and tech-services assessment. With only 5,495 digital/IT workers among the FDP population and 3% English fluency, the narrative of "refugee labor for BPO" is not viable in English-language markets. However, the 55% skills-mismatch finding (employed below qualification level) suggests that targeted upskilling could unlock Arabic-language digital services, data annotation/labeling for AI training, and impact-sourcing models. Incoming bandwidth (FIG 720 Tbps) improves the infrastructure viability of such services.

EBRD TMT ↔ IFC FDP convergence point: The interoperability gap (Section 04) and the CMC SIM-registration barrier (this section) are two sides of the same problem. A national payment switch that incorporates tiered KYC for FDPs—enabling simplified onboarding at low-value thresholds—would simultaneously advance the commercial fintech ecosystem and unlock FDP financial inclusion. This is the single intervention point where EBRD TMT investment and IFC FDP inclusion work converge most concretely. EBRD could condition investment in payment infrastructure on interoperability standards that include FDP-accessible identity tiers, directly linking its TMT mandate to the Bank's broader inclusion agenda.

11 · EBRD Entry Strategy & Investment Thesis

Tier 1: Infrastructure (High EBRD fit, systematic impact)

Payment interoperability infrastructure: National payment switch connecting wallets, banks, merchants. Commercial opportunity + public good + FDP inclusion benefits. Could be structured as PPP or investment in licensed switch operator. Condition on FDP-accessible identity tiers.

Carrier-neutral data center: Zero exist in Iraq. The IXP ecosystem (28 networks, Meta/Akamai/Tencent) creates demand that cannot be fully served without colocation infrastructure. High alignment with EBRD digital-infrastructure mandate. Incoming submarine bandwidth (FIG Q4 2027) will amplify demand.

Tower infrastructure / fibre backhaul: Zain-Ooredoo towerco JV and fourth-operator demand create entry points. EBRD has deep towerco experience. EarthLink fiber activation bottleneck (MoC policy, not infrastructure) could benefit from EBRD policy-engagement leverage.

Trade finance expansion: Building on $100M NBI facility. Sector-specific trade finance for technology equipment imports.

Tier 2: Platform & Ecosystem (Core TMT focus)

Digital banking: InstaBank/Al-Fawr (EQIQ $3M) and other CBI-licensed digital banks. Natural EBRD investment class. March 2024 licensing framework provides regulatory clarity.

Logistics aggregation: Boxy-type models that unify fragmented last-mile. Growth capital for enabling infrastructure.

Content platforms: 1001 exemplifies creative-economy catalysis. Aligned with EBRD human-capital mandate.

Tier 3: Venture-Stage Ecosystem (Higher risk, highest impact)

Co-investment with local VCs: Matching fund structures with EQIQ, Euphrates, or Nawat. EBRD credibility premium + local VC knowledge.

Star Venture Iraq expansion: TMT-specific cohorts (cleantech, agtech, Arabic-language digital services).

Regulatory TA: Interoperability standards, tiered KYC, data protection, IP enforcement (critical for OTT viability), and addressing the ~57% ISP tax burden through policy engagement.

Risk factors for all tiers: (1) NMTC judicial suspension creates 5G-timeline uncertainty. (2) ~57% ISP tax burden suppresses connectivity economics. (3) CMC independence compromise introduces regulatory risk. (4) 2Africa PEARLS force majeure may delay major bandwidth upgrade. (5) Korek distress could trigger contagion in adjacent fintech/content partnerships. (6) CPA Order 65—the entire telecom regime rests on a 22-year-old transitional instrument with no enacted replacement.

12 · Entity Index for Graph Analysis

All entities tagged throughout this document, consolidated by category. Edge relationships (investment, partnership, subsidiary, competition, regulatory oversight) derivable from narrative context.

MNOs & Telecom

Zain Iraq Asiacell (Ooredoo) Korek Telecom NMTC Vodafone Newroz Telecom Nokia Huawei Ericsson Zajil Telecom

Digital Infrastructure

IRAQ-IXP DE-CIX ICG Baghdad Meta Akamai Tencent FALCON GBI 2Africa PEARLS FIG (Ooredoo) Khaleej North WorldLink Transit Silk Route Transit EarthLink Iraq iQ Networks ITPC Tech 964 DIL Technologies

Fintech & Payments

Zain Cash Iraq Wallet AsiaHawala Oodi Qi Card / ISC NassWallet FastPay Neo Pay Wayl InstaBank / Al-Fawr Ideal Payments Lezzoo Pay

Startups & Tech

Lezzoo Baly Alsaree3 / Al Zajel Miswag Orisdi Tamata Simma Orderii Digital Zone Pure Platform Boxy Sandoog Hi-Express Toolmart KESK Corrsy IoT-Kids Abwaab iQ Cars Nakhla Fedshi 1001 Teami

Media & Content

Al Sharqiya Group 1001 Media Shahid (MBC) STARZPLAY OSN+ Rotana Ritaj Shofha

VC & Investors

EQIQ Euphrates Ventures IVP Northern Gulf Partners MSA Novo Kingsway Capital Iraq Tech Ventures Innovest Crossboundary Vostok Ventures Plus VC Oasis500 IAIN Pay It Forward VC Nawat

Hubs & Accelerators

KAPITA Five One Labs Netaj The Station Takween Orange Corners Baghdad Zain Incubator Founder Institute Baghdad Iraq Response Innovation Lab

DFIs & International

EBRD IFC World Bank UNDP UNHCR ILO UNICEF USAID GIZ MFTA Iraq IBBC K2 Integrity IrisGuard Comviva Accedo Brightcove

Government & Regulatory

CBI CMC Ministry of Communications Ministry of Planning MoLSA KRG ITPC MSMEDA Al-Salam General Company Trade Bank of Iraq State Employees' Pension Fund