Establishing an Electronic Payment Service Provider (EPSP) in Iraq is regulated by the Central Bank of Iraq (CBI) under the Electronic Payment Services Regulation and related CBI instructions. Any entity wishing to provide electronic wallets, POS services, payment processing, or digital payment solutions must obtain prior licensing and approval from the Central Bank of Iraq.

Electronic payment activities are considered regulated financial services, and strict compliance with licensing, capital, governance, and AML/CFT requirements is mandatory.

Types of Electronic Payment Activities: CBI licenses may cover one or more of the following activities, subject to approval:

• Electronic wallet services
• POS and merchant acquiring services
• Payment processing and switching
• Prepaid card issuance
• Mobile and digital payment platforms

Each activity may be subject to specific operational and technical requirements.

Key Regulatory Requirements: Applicants must demonstrate:

• Minimum capital as determined by the CBI
• Clear ownership and shareholder structure
• Fit and proper shareholders and management
• Robust governance and internal control frameworks
• AML/CFT and KYC compliance systems
• Secure technical infrastructure and data protection measures
• Viable business plan aligned with Iraqi market needs

Foreign investors are subject to enhanced regulatory scrutiny and must appoint a local Iraqi legal representative.

Step-by-Step Licensing Process

Initial Application to the Central Bank of Iraq: Submit a formal request outlining the proposed electronic payment services, ownership structure, and business objectives.

Submission of Business Plan & Documentation: Provide detailed documents including:

• Business and operational model
• Financial projections
• Governance and management structure
• AML/CFT, KYC, and risk management policies
• IT systems and cybersecurity framework

Regulatory Review & Due Diligence: The CBI conducts a comprehensive assessment of:

• Shareholders and source of funds
• Management suitability
• Compliance readiness and system security

Capital Deposit: Upon preliminary approval, the required capital must be deposited with a bank approved by the CBI.

Company Incorporation: Register the company under the Iraqi Companies Law with the Companies Registration Department (Ministry of Trade).

Final Licensing Approval: Once all regulatory conditions are satisfied, the CBI issues the electronic payment service license.

Operational Readiness: Before launching operations, the company must:

• Finalize internal policies and SOPs
• Complete system testing and security validation
• Train staff and appoint compliance officers
• Obtain any additional approvals required

Ongoing Compliance Obligations: Licensed electronic payment companies must comply with:

• CBI supervision and reporting requirements
• AML/CFT and sanctions regulations
• Transaction limits and wallet controls
• Consumer protection and data security rules
• Periodic audits and inspections

Non-compliance may result in penalties, suspension, or license revocation.

Investment Timeline (Indicative): The licensing process typically takes several months, depending on the scope of services, regulatory review, and readiness of the applicant.