Etihad Law

Spectrum Allocation in Iraq

Fifth-generation mobile technology 5G represents the most significant technological transition in mobile communications since the introduction of mobile broadband. For Iraqi MNOs, 5G is both a regulatory obligation and a commercial opportunity: an obligation because the CMC is developing a framework for 5G spectrum licensing that will create coverage requirements for the transition; and an opportunity because 5G will enable new services, ultra-fast broadband, Internet of Things connectivity, and enterprise private networks that can drive revenue growth and strengthen operators’ market positions. Preparing for 5G licensing in Iraq requires action now on spectrum strategy, network architecture, regulatory engagement, and investment planning. This article examines the 5G landscape in Iraq and what operators must do to be ready.

5G Licence Requirements

Based on international precedents and the CMC’s developing 5G policy, operators should expect 5G licences or spectrum assignments to include: coverage obligations requirements to deploy 5G in specified geographic areas within defined timelines, likely starting with major cities; minimum investment commitments, financial obligations for network rollout; technology requirements, technical standards for 5G network deployment; spectrum efficiency obligations, requirements to utilise assigned spectrum efficiently; neutral host obligations requirements to provide 5G connectivity to enterprise customers on open terms; and annual reporting detailed reporting to the CMC on 5G coverage progress, network performance, and service adoption. The CMC may conduct a competitive spectrum assignment process auction or beauty contest for the primary 5G bands.

5G Infrastructure Requirements

5G deployment requires fundamental changes to network infrastructure that Iraqi MNOs must plan for in advance. Key infrastructure requirements include: densification 5G’s higher frequency bands have shorter range, requiring a denser network of base stations potentially five to ten times more sites than 4G; small cell in addition to macro base stations, 5G requires deployment of small cells on street furniture, buildings, and indoor locations; fibre backhaul 5G’s ultra-high data speeds require fibre backhaul connectivity to base stations, a major infrastructure challenge in Iraq where fibre penetration is limited; core network evolution operators must upgrade their core networks to a cloud-native 5G core architecture; and power solutions each additional base station requires power, exacerbating Iraq’s electricity supply challenges and creating demand for solar and battery solutions.

Spectrum Refarming for 5G

Before receiving new 5G spectrum assignments, Iraqi MNOs can accelerate 5G readiness by refarming their existing spectrum holdings. Spectrum refarming involves deploying 5G technology in frequency bands currently used for 2G or 3G services, as users migrate to 4G and 5G capable devices. Key bands suitable for refarming in the Iraqi market include: 900 MHz currently used for 2G GSM, refarming for 5G low-band provides excellent coverage; 1800 MHz currently used for 4G LTE in some markets, refarming for 5G mid-band provides urban capacity; and 2100 MHz, currently used for 3G WCDMA and 4G LTE, refarming for 5G improves efficiency. Spectrum refarming in Iraq requires CMC approval, operators must notify the CMC and obtain permission before changing the technology deployed on assigned spectrum.

Enterprise 5G: Private Networks and New Revenue

One of the most significant commercial opportunities presented by 5G in Iraq is the enterprise private network market. Industries including oil and gas, manufacturing, logistics, and construction can deploy dedicated 5G networks on their premises enabling applications including industrial automation, remote monitoring, and connected machinery. In Iraq, the oil and gas sector presents a particularly significant opportunity given the extensive operations of international energy companies requiring reliable, high-bandwidth connectivity. MNOs should engage with enterprise customers early on 5G private network opportunities and ensure their 5G spectrum licences permit the provision of private network services.

How Etihad Law Firm Assists

Etihad advises MNOs on 5G spectrum strategy and licensing, assists in engaging with the CMC on 5G policy development, advises on 5G licence conditions and infrastructure obligations, and provides regulatory advice on spectrum refarming requirements. We also advise on the legal structuring of 5G infrastructure sharing and enterprise private network arrangements.