Regulatory AlertsIraq: lending & credit regulation
RegulatedLending strictly regulated via CBI banking licenses; no specific fintech credit regime
- Lead regulator
- Central Bank of Iraq (CBI)
- Also involved
- Ministry of Trade (company registration) · Ministry of Planning (investment)
- Core law
- Law No. 94 of 2004 (Central Bank of Iraq and Organization of Banking)
- Entry capital
- —
- Approval timeline
- —
- Customer assets
- —
- Data protection
- No specific data protection law identified
- Sandbox
- No
Iraq does not have a distinct regulatory framework for non-bank digital lending, BNPL, or P2P platforms. All lending activities are effectively reserved for licensed banks under the CBI's monopoly. The regulatory environment is conservative, with recent guidance focusing on internal bank governance rather than expanding access to alternative credit providers. Foreign or non-bank entities cannot legally originate consumer or SME loans without a banking license.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Consumer lending | LicenceBanking License Only licensed banks may originate consumer loans | — | — | Central Bank of Iraq |
| SME / commercial lending | LicenceBanking License SME lending is a core banking function, restricted to banks | — | — | Central Bank of Iraq |
| Microfinance | LicenceBanking License Microfinance is conducted by banks or NGOs with CBI approval | — | — | Central Bank of Iraq |
| Buy-now-pay-later | Prohibited No legal framework exists; effectively prohibited for non-banks | — | — | — |
| P2P lending platform | Prohibited P2P lending is not recognized; banking monopoly applies | — | — | — |
| Credit bureau / scoring | Uncertainverify with regulator No formal credit bureau or scoring regulator identified | — | — | — |
| Debt collection | Uncertainverify with regulator Regulation of third-party collectors is unclear | — | — | — |
New — what changed recently
- 2020-03-10CBI Corporate Governance Manual FAQs — Clarified governance rules for bank boards, reinforcing strict internal controls over credit exposure.[1]
Market-entry checklist
- 1Secure banking licenseApply for a full banking license from the CBI; no alternative credit licenses exist.
- 2Register with Ministry of TradeIncorporate a local legal entity with the Ministry of Trade to operate.
- 3Meet capital requirementsVerify current statutory minimum capital for banking licenses with the CBI.
- 4Implement AML/CFT complianceAdopt strict anti-money laundering protocols as required by CBI regulations.