Iraq prepares for advance customs collection and introduces new operating rules
The first week of September brought preparations for a change in customs payment procedures, intervention at an Iraqi bank and new rules relevant to shipping and industrial imports. For foreign businesses, the immediate task is to check payment arrangements and sector approvals before committing to delivery dates or project costs.
Advance customs collection targeted for October
On 2 September, the Ministry of Finance called for preparations to collect customs duties in advance at the point of financial transfer from 1 October 2026. It also discussed the technical and administrative work needed to introduce ASYCUDA at customs points in the Kurdistan Region. This was an implementation announcement; it did not establish that every regional border point was already connected.
Importers should ask their bank and customs adviser which documents and electronic references will be needed for payments made around the proposed start date. Contract teams should check who funds the duties and who bears the cost of a delayed transfer. The later implementation announcement is addressed in the third weekly edition.
Source: Ministry of Finance announcement, 2 September 2026. [2]
Central Bank places Al Taif Islamic Bank under guardianship
On 3 September, the Central Bank of Iraq announced that it had placed Al Taif Islamic Bank for Investment and Finance under guardianship. Companies with deposits, payroll arrangements or trade finance exposure should obtain written confirmation of the operating arrangements that apply to their accounts.
A practical review should distinguish account balances, amounts immediately available for withdrawal and obligations owed to the bank. Companies should preserve statements and correspondence and assess an alternative route for essential payments. The announcement alone does not establish a repayment timetable for each customer.
Source: Central Bank of Iraq announcement, 3 September 2026. [3]
Food regulation proposal and seasonal agricultural restrictions
At its 1 September session, the Cabinet approved a draft Food and Drug Authority Law for referral to Parliament. This is a legislative proposal. The same session approved a recommendation restricting agricultural crop imports until the local production season ends. The public statement did not identify a complete crop list or a single reopening date.
Food and pharmaceutical businesses should monitor the bill. Agricultural importers should confirm the position for their particular product and entry point before shipment.
Source: Prime Minister Media Office statement published on 2 September 2026. [1]
New rules for substances controlled under the Montreal Protocol
Regulation No. 2 of 2026 took effect on 7 September when published in Official Gazette No. 4880. It amends Regulation No. 5 of 2012, changes its title to refer to substances controlled under the Montreal Protocol and defines controlled substances by reference to that Protocol and its amendments. It also provides that a licence remains valid until the end of its year of issue and may be renewed annually.
This warrants a review by businesses importing or using refrigerants and other potentially controlled substances. Relevant operations include cooling systems, food storage, pharmaceutical distribution and industrial facilities. A chemical or equipment specification should be checked against the applicable controls; an ordinary import approval should not be treated as confirmation of environmental compliance.
Source: Official Gazette No. 4880, 7 September 2026, pages 5 to 7; Regulation No. 2 of 2026, Articles 1, 2, 4 and 5. [4]
Maritime collision prevention regulation enters into force
Regulation No. 1 of 2026 also took effect on 7 September. It assigns implementation of the international collision prevention framework to the Iraqi Supreme Maritime Authority. Subject to specified exclusions, its scope covers Iraqi vessels wherever located and foreign vessels in Iraqi waters or licensed to operate in Iraq. It also provides for inspections and collision investigations.
Shipowners, charterers and marine contractors should check whether their vessels fall within its scope and maintain inspection, certification and incident records. Contracts should allocate responsibility for compliance and the consequences of detention or operational delay. The regulation contains specific exclusions and an exemption mechanism, which require separate assessment for the relevant vessel.
Source: Official Gazette No. 4880, pages 1 to 4; Regulation No. 1 of 2026, particularly Articles 2, 5, 6 and 11. [4]
Housing initiative advances to land and infrastructure arrangements
A 2 September statement on the Watan housing initiative reported Cabinet approval of arrangements for transferring state land to the relevant municipalities and models for investor participation in infrastructure. These announcements are relevant to developers and infrastructure contractors assessing future opportunities.
Before treating an opportunity as available for investment, a company should establish the competent contracting authority, land title and permitted use, procurement route, funding structure and payment rights. The announcement itself is not an invitation to tender or a grant of land rights to a particular investor.
Source: Prime Minister Office statement on the Watan initiative, 2 September 2026. [5]
Practical outlook
The customs timetable and new environmental licensing provisions deserve early operational attention. Businesses pursuing public projects should obtain the project documents and confirm approvals before pricing work or mobilising resources.
For the relevant instruments or advice on a planned import, banking exposure or project, Contact Muayad & Associates
Iraq increases scheduled stamp duties and develops sector specific measures
The clearest binding development of the second week is a 50% increase in the stamp duties covered by the two schedules to the Stamp Duty Law. The week also brought a narrow labour classification change, sanctions decisions, medical import relief and further announcements concerning banking and investment.
Scheduled stamp duties increase by 50 percent from 14 September
Ministerial Council for the Economy Decision No. 26272 Q of 2026 increases the stamp duties specified in the first and second schedules to Stamp Duty Law No. 71 of 2012 by 50%. Although adopted on 31 August, the decision states that it takes effect on publication. It was published in Official Gazette No. 4881 on 14 September 2026.
The increase applies to the relevant scheduled duty, rather than adding 50 percentage points to a transaction value. For example, where a qualifying scheduled duty was IQD 10,000, a 50% increase produces IQD 15,000. This calculation does not decide whether a particular document is chargeable or exempt.
Finance and legal teams should update transaction cost estimates and check documents issued, signed or presented around commencement against the applicable charging rules. Companies should also review contracts allocating taxes, duties and official charges. An old quotation may no longer reflect the amount payable.
Source: Official Gazette No. 4881, 14 September 2026, page 2; Decision No. 26272 Q of 2026. [6]
A narrow change to trade union occupational classification
Decision No. 2 of 2026, effective on publication on 14 September, repeals the 2022 amendment concerning occupational classification for the union of complementary medicine and medicinal herb workers. Its wording is specific to that classification.
Employers in the affected activities should check the appropriate representative body before formal consultation. The decision should not be described as a general repeal of workers’ union rights or of consultation obligations across all industries.
Source: Official Gazette No. 4881, page 17; Ministry of Labour and Social Affairs Decision No. 2 of 2026. [6]
Further asset freezing decisions published
Gazette No. 4881 also publishes Terrorist Assets Freezing Committee Decisions Nos. 51 and 52 of 2026. Compliance teams should check the operative entries and identifiers against their screening records, including changes to existing entries. Publication in the Gazette should not be assumed to be the starting date of every freezing obligation.
Source: Official Gazette No. 4881, pages 3 to 16. [6]
Central Bank explains the approach to Al Taif deposits
In its 8 September statement, the Central Bank described guardianship as a protective supervisory measure. It said it was working with the appointed guardian to improve liquidity and organise withdrawals and the gradual meeting of obligations, with priority for employee salaries domiciled at the bank.
Corporate depositors should reconcile balances and pending instructions and obtain written confirmation of withdrawal arrangements. The statement does not promise immediate payment of every balance.
Source: Central Bank of Iraq statement, 8 September 2026. [7]
Specified medical import approvals receive an extension
On 8 September, the Cabinet approved an extension of the import approvals identified in the Ministry of Health correspondence, with the extension not to run beyond the end of 2026. The wording identifies a defined group of approvals; it does not establish that every healthcare import licence has been renewed.
A supplier should match its approval to the Ministry correspondence and confirm the remaining product, shipping and clearance requirements before relying on the extension.
Source: Cabinet eighteenth session statement, 8 September 2026. [8]
Energy arrangements require contract specific review
The same session announced amendments concerning the oil sales mechanism, Chevron agreements and financing for the water framework with Türkiye. Their commercial effect depends on the relevant approvals and contracts.
Suppliers should verify the contracting entity, payment route, procurement requirements and signatory authority before committing resources.
Source: Cabinet eighteenth session statement. [8]
France and Iraq announce further economic cooperation
The joint declaration of 14 September records discussions with TotalEnergies on additional energy projects, a letter of intent concerning French Development Agency financing and cooperation on civil aviation. These announcements may justify early project preparation by French businesses and their advisers.
A declaration or letter of intent should be reviewed for its own legal effect. Companies should establish whether definitive agreements, financing, procurement and Iraqi approvals remain outstanding. The announcement does not establish that every proposed project has been awarded or funded.
Source: French Presidency, joint declaration, 14 September 2026. [9]
KRG budget discussions remain at the drafting stage
Meetings on 9 September addressed the Kurdistan Region’s proposed financial and investment allocations and oil arrangements in the 2027 federal budget bill. These are proposals under discussion. Contractors should continue to assess payment rights by reference to their contracts and confirmed funding arrangements.
Source: KRG Department of Media and Information report, published 10 September 2026. [10]
For assistance with the stamp duty changes, regulatory approvals or project documentation, Contact Muayad & Associates
Iraq advances customs implementation and medical procurement measures
The third week brought a further implementation step for advance customs collection, changes affecting medical procurement and updated sanctions guidance. These developments call for coordination between legal, finance, procurement and compliance teams, particularly where payments or tenders are due shortly.
Finance Ministry completes the advance collection mechanism
On 17 September, the Ministry of Finance announced completion of the implementation mechanism for advance customs collection under Cabinet Decision No. 413 of 2026, using ASYCUDA and approved electronic payment systems. This follows the Ministry’s 2 September announcement identifying 1 October as the intended start for collection at financial transfer.
Importers should prepare a reconciled file linking the invoice, goods description, classification, origin and value to the bank transfer and customs declaration. Before authorising payment, confirm the bank’s required reference, the payment sequence and the treatment of a later change in quantity or value. Arrangements for goods already in transit and existing payment commitments also need confirmation.
The announcement of a completed mechanism does not resolve every operational question. Businesses using Kurdistan Region entry points should confirm the position at their specific border point. Contracts should address additional working capital and responsibility for delays caused by incomplete declarations or payment documentation.
Sources: Ministry of Finance announcements of 2 and 17 September 2026. [2] [11]
Financial capability relief for specified medical suppliers
At the 16 September Cabinet session, reported the following day, the Ministry of Planning was authorised to exempt qualifying pharmaceutical and medical supply manufacturers from the financial capability requirement in the government tender controls. The announcement also addresses companies and factories contracting with KIMADIA and establishes a Health and Planning committee to develop specific supply controls.
Manufacturers should seek written confirmation that the exception covers the bidder and the relevant tender. A distributor should not assume it receives an exemption expressed for a manufacturer. The announcement does not by itself remove product registration, technical evaluation, security or other tender requirements.
Source: Prime Minister Media Office, nineteenth Cabinet session, published 17 September 2026. [12]
Oil subcontract exceptions need the underlying wording
The Cabinet also approved a recommendation concerning exceptions for oil company subcontracts and a specific exception for the Oil Projects Company. The short statement does not explain the complete scope of the subcontract relief.
A contractor should obtain the decision and the relevant implementing direction before changing its procurement, payment or approval process. The announcement should not be presented as a general tax exemption for oil contractors.
Source: Prime Minister Media Office, nineteenth Cabinet session. [12]
Targeted financial sanctions guidance requires prompt action
On 20 September, the Central Bank published guidance on implementing targeted financial sanctions without delay. The accompanying guide addresses financial institutions, designated nonfinancial businesses and professions, other implementing bodies and persons within Iraq. It defines action without delay by reference to freezing within 24 hours of the relevant listing decision.
Businesses should ensure that screening reaches beneficial ownership and payment beneficiaries, and that an identified match can be escalated immediately. The guide distinguishes confirmed, potential and false matches. Procedures should therefore support prompt identity checks and the correct freezing and reporting response, without treating every similarity in a name as a confirmed match.
Management should test who receives an alert outside working hours and who can stop a transaction. The publication is guidance under the existing legal framework, rather than a new standalone sanctions law.
Source: Central Bank publication of 20 September 2026 and accompanying targeted financial sanctions guide, scope and definitions. [13]
KRG announces an electronic payroll milestone
On 15 September, the KRG Prime Minister stated that one million citizens on the government payroll would receive salaries electronically that week through participating banks licensed by the Central Bank of Iraq.
The MyAccount announcement concerns the government payroll programme. It should not be described as a new requirement for every private employer. Payment providers and businesses serving the region should assess service arrangements, customer verification and the allocation of responsibility for failed payments.
Source: KRG Prime Minister statement, 15 September 2026. [14]
Parliament recommends a review of fuel pricing
On 21 September, Parliament voted on recommendations that included reviewing Cabinet Decision No. 429 of 2026 concerning petroleum product prices and assessing its effects. A recommendation to review the decision is not evidence that it has already been repealed or that new prices have taken effect.
Transport, construction and industrial businesses should check price adjustment clauses and preserve evidence of additional costs, while continuing to verify the prices and instructions that actually apply.
Source: Council of Representatives session report, 21 September 2026, corroborated by contemporaneous reporting. [15]
Proposed Netherlands tax treaty ratification remains under review
The parliamentary Foreign Relations Committee reported discussion on 21 September of the bill to ratify the Iraq and Netherlands income tax agreement. Committee consideration alone does not establish that treaty relief is available. A transaction should be assessed against the applicable ratification, entry into force and effective date provisions.
Source: Council of Representatives committee report, 21 September 2026. [16]
Muayad & Associates advises foreign companies and international law firms on Iraqi transactions, compliance and disputes. For the underlying instruments and advice on their application, Contact Muayad & Associates
When did the September stamp duty increase take effect?
Decision No. 26272 Q of 2026 took effect on 14 September 2026, the date of publication in Official Gazette No. 4881. It increases the duties specified in the two schedules to Stamp Duty Law No. 71 of 2012 by 50%. [6]
Does the increase mean a duty of 50 percent of the contract value?
No. It increases the applicable scheduled duty by 50%. The document category, charging provisions and any exemption must first be established. It does not impose a general charge equal to half the contract value. [6]
What should importers do before the announced customs change?
Confirm the payment sequence and required electronic references with the bank and customs adviser, reconcile commercial and customs data and clarify treatment of existing commitments. The Ministry identified 1 October as the intended start and announced completion of the mechanism on 17 September. [2] [11]
Does medical tender relief automatically cover a distributor?
The Cabinet announcement addresses specified manufacturers and companies or factories contracting with KIMADIA. A distributor should obtain confirmation of its eligibility and the tender requirements that remain applicable. [12]
Is the proposed Food and Drug Authority Law already in force?
The 1 September Cabinet action was approval of a draft for referral to Parliament. That action alone does not establish enactment or commencement of a new law. Any later legislative development must be checked before publication. [1]
Did Iraq remove trade union rights for all workers?
No such conclusion follows from Decision No. 2 of 2026. The decision repeals a specific occupational classification amendment concerning complementary medicine and medicinal herb workers. It is not a general repeal of union rights. [6]
Does MyAccount create a new rule for every private employer?
The 15 September announcement concerns electronic payment of the KRG government payroll through participating licensed banks. It does not itself announce a universal payroll obligation for private employers. [14]
Where can readers obtain the instruments mentioned in the update?
Readers may contact Muayad & Associates for copies of the relevant instruments and advice on their application to a particular business or transaction.
