On October 20, 2026, the Communications and Media Commission of Iraq (هيئة الإعلام والاتصالات) opened a public consultation on the draft Annex 5 regulatory framework for the digital voucher market in the Republic of Iraq, ملحق (5): اللائحة التنظيمية لسوق القسائم الرقمية, an annex to the Framework Regulations for Digital Platforms and Services under Coalition Provisional Authority Order No. 65 of 2004. Iraqi digital voucher and gift card issuers and resellers, Iraqi gaming token and prepaid gaming card sellers, Iraqi digital payment platforms and e-wallet providers (ZainCash, AsiaHawala, FastPay), and the prepaid voucher businesses of Iraqi mobile network operators (Zain Iraq, Asiacell, Korek) must review the draft, send comments to [email protected] by November 20, 2026, and prepare licensing and compliance dossiers for the framework once it is adopted, or they lose the chance to shape the rules and, once the framework is adopted, risk licensing sanctions, operating restrictions, or enforcement action by the CMC.
The CMC announcement states that the consultation runs for one month from publication. The draft Annex 5 is not in force. It would attach digital vouchers to the 2025 framework, in force since February 17, 2025: mobile credit, electronic game vouchers, digital subscriptions such as streaming or computing, and other digital cards with a monetary value.
What does draft Annex 5 change for digital vouchers in Iraq?
Wholesale import, aggregation and distribution inside Iraq would be reserved to an Iraqi-registered Licensed Digital Voucher Distributor (LDVD), the exclusive approved source. A fintech app or e-commerce platform selling to the end consumer in Iraq would have to connect, through a documented API, to at least one licensed LDVD, and that proof would be a condition of operation. A regional issuer licence would not replace the LDVD licence: the draft requires both. The point of consumption is where in Iraq the user buys, activates or uses the voucher, whatever the server location or the place of registration.
Three classes apply: telecom and mobile credit, coordinated with CMC-licensed operators; entertainment, streaming, games and subscriptions; and payment-value vouchers, which stay with the CMC for the chain and the source. Cash-redeemable vouchers and those that credit a bank account would also follow Central Bank of Iraq instructions.
Who must comment by November 20, 2026, and who would need a licence?
The licence, the API link and the records fall on Iraqi issuers and resellers of vouchers, gift cards and gaming tokens, the e-wallet platforms named above, and the prepaid arms of Zain Iraq, Asiacell and Korek, including a foreign platform if the point of consumption is inside Iraq.
An LDVD applicant would need an Iraqi commercial registration and tax card, real-time voucher APIs, capital at limits the CMC sets (no figure is stated), and a transaction-chain diagram. Records would be kept for at least five years, with quarterly reports and a 48-hour notice of a money-laundering, fraud or illicit-financing pattern. Any revenue share would follow a market study of at most six months from publication of the annex, then at least 60 days of grace.
| Proposed step for a licensed platform | What the draft would impose |
|---|---|
| First serious breach | First warning and a fine of IQD 50,000,000 |
| Second serious breach | Second warning, 60-day licence suspension and a fine of IQD 75,000,000 |
| Third serious breach | Final warning, permanent withdrawal, a fine of IQD 150 million, permanent blocking, referral to court |
| Unlicensed foreign operator | Immediate fine of IQD 150 million and a stop within 10 working days |
What should operators file before November 20, 2026?
Comments on the draft's provisions go to [email protected] before the consultation closes on November 20, 2026.
- Map each product to telecom credit, game or streaming vouchers, or payment-value vouchers, including cash-out and bank credit.
- Check that wholesale supply would sit with an LDVD holder and that each retail app has a documented API to at least one.
- Draft the transaction-chain diagram from the original issuer to the Iraqi consumer, with the APIs and IP addresses the draft requires.
- Test the five-year archive, the quarterly report and the 48-hour notice, and flag contracts that treat a foreign regional right as enough for Iraq.
What does the draft say happens if the rules are breached?
Section 11 sets that ladder for a licensed LDVD or retail platform, with at least 30 days between proven serious breaches. An unlicensed foreign distributor would face an immediate fine of IQD 150 million and a stop within 10 working days. A CMC decision may be appealed to the Appeal Board within 30 days under section 8 of Order No. 65 of 2004. After a decision is final, the CMC would notify the General Company for Communications and Informatics and Iraqi internet providers to restrict or block non-compliant systems. None of this applies until the annex is adopted. Continuous per-jurisdiction monitoring surfaces a CMC annex when the consultation opens, before the comment window closes.
Before November 20, 2026, confirm which of the three classes the product sits in, send comments to [email protected], and name an owner for the LDVD or API file if the annex is adopted in this form. Obsidian keeps this CMC annex on one watch so the adopted text, the licence register and the revenue-share study are not missed.
