Dear reader,
Today, we publish part II of our RO Long Read series on the Iraqi fintech sector.
Before diving in, we strongly recommend you read part I, which you can find here.
This series is written by RO Correspondent Rabel Kaka.
Based in Iraq, Rabel is a senior research associate at MAGNiTT and has become a fine connoisseur of the Iraqi fintech scene. He has spent the past few months interviewing Iraqi fintech startups, Iraqi VCs, and other relevant parties to paint a picture of where Iraqi fintech stands today.
Some of the topics Rabel uncovered include:
- The dichotomy between digital commerce and digital transactions (the former doesn't automatically lead to the latter).
- The benefits of digitizing and formalizing the Iraqi economy, and why it has become a governmental priority.
- The Iraqi government's efforts to push digital payments in the public sector.
- The hesitations Iraqi consumers and businesses have vis-a-vis digital payments, and how founders are building with those hesitations in mind.
- The current Iraqi "payment stack".
- Why fintech Iraq is bank-dependent, not bank-disruptive.
- The notable, encouraging evolutions in the Iraqi regulator's posture.
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The core friction: trust, not technology
The success of platforms such as Simma and Wayl shows that Iraqi consumers and merchants are willing to use digital payments when reliable rails exist. What we haven’t covered yet, however, is the long trust-building process needed for adoption to scale.
If you look at Iraq from the outside, it is easy to blame technology. People talk about low card usage, fragmented acquiring (ie: merchant card acceptance infrastructure), and weak settlement systems. Those issues exist, but they do not explain why cash remains dominant even when digital tools are available.
As we alluded to earlier, the deeper issue is trust, and trust in Iraq has a history. Decades of conflict, sanctions, and institutional disruption trained households and merchants to treat cash as tangible protection, not just convenience. When you hold cash, you do not depend on a system that can approve, clear, reverse, or freeze the money you own.
One visible example is the aforementioned pattern of salary withdrawals. Public employees increasingly receive wages through digital salary cards, yet 97% of Iraqis still “withdraw or keep their entire salary, pension, or social benefits in cash”. This pattern reflects decades of institutional conditioning. For many Iraqis, banks have not historically been a source of stability. Cash, by contrast, is immediate, visible, and fully controlled by the holder. In that context, digital storage of value feels riskier than physical custody.
Samer Tarazi (co-founder of Simma) explained that Simma ran cash-on-delivery for its first year to earn credibility before introducing its digital wallet. When the wallet launched, adoption improved only after customers witnessed repeated proof that deliveries were reliable and that digital payments created benefits (such as smoother ordering), or provided incentives (such as free shipping). Three months after introducing its wallet, Simma started receiving roughly 30% of its total transactions through it.
According to Tarazi, payment behavior changes after trust is earned through execution and use cases are aligned with customers needs. Simply releasing the feature is insufficient.
Attempts to accelerate digitization through government mandates have been attempted. They can backfire if they arrive before trust. In part I, Mustafa Sirri (a financial sector advisor with deep experience in Iraq’s banking and payments ecosystem) described an example in which the government mandated that payments at fuel stations be made through digital cards. The public simply did not comply. That is a predictable outcome when a population is asked to switch payment behavior without first seeing consistency in the system around it.
Mohammed Jamal from KAPITA Research (a Baghdad-based market intelligence firm that maps Iraq’s digital economy) emphasizes that adoption depends on proposing compelling use cases. Building the infrastructure does not change behavior on its own. People change when they have a reason to do so, like convenience, safety, access, or a financial advantage. When digital payments do not clearly beat cash, cash wins by default. If the mandate for digital payments at petrol stations had been paired with clear consumer incentives, such as cashback or price discounts, public perception and adoption might've been higher.
There is another element reinforcing this behavior. Cash allows large segments of Iraq’s commercial activity to operate outside formal banking visibility. For some merchants and individuals, remaining off record reduces perceived tax exposure and regulatory scrutiny. For many small merchants, registering a business means lengthy and complicated paperwork, fees, and potential tax exposure, with little immediate return.
To change that outcome, government policy would need to lower the upfront burden and increase the value of formalization. This can be achieved through digitizing company formation, shortening processing timelines, lowering early-stage compliance requirements, and aligning registration costs with business size rather than applying uniform thresholds. Allowing small merchants to operate under limited transaction caps and simplified compliance requirements before moving into full regulatory obligations would allow micro-merchants to enter digital channels under defined transaction caps before facing full regulatory obligations.
At the same time, formal registration must unlock practical advantages. If registration enables faster settlement cycles, reduced cash-handling risk, improved logistics integration, and access to credit, migration becomes economically rational. When formalization introduces scrutiny without any offsetting benefit, informal operations remain the rational choice.
Digital payment adoption in Iraq is therefore a behavioral migration. It spreads gradually, anchored to trust-building and practical use cases rather than mandates or technology alone.
The current Iraqi payments stack
Understanding trust mechanisms explains behavior. Understanding Iraq’s current payments stack clarifies what “plumbing” needs to be fixed to channel hard-earned trust into digital payments.
Fintech in Iraq operates within a bank-led architecture, meaning that most fintech products cannot function independently of licensed banks. For a digital wallet to operate at full functionality (transfer funds, pay merchants, and withdraw physical cash), it must integrate with a bank that holds settlement accounts and clears transactions on its behalf. Payment rails do not exist as parallel infrastructure layers but extend directly from the traditional banking system. Transfers are regulated, often subject to transaction caps, and ultimately settle in Iraqi dinars.
As Hady El Samra, head of investments & programs at Iraq Venture Partners, explains, fintech companies in Iraq complement the world of traditional banks by opening new channels for financial inclusion. However, that inclusion story remains a work in progress. Cultural awareness and the need for regulatory enhancements are key factors that continue to hold back the growth of fintech companies, particularly in more complex segments.
Lending fintechs, for instance, require accurate credit scoring, revenue tracking, and other data points. Yet, large segments of SMEs in Iraq remain unregistered and operate with limited financial data. The absence of reliable credit histories, revenue tracking, and formal records makes risk assessment difficult and slows product expansion. Progress therefore depends not only on fintech innovation, but also on broader improvements in business formalization and the data infrastructure that underpins it.
Licensing requirements further reinforce these structural constraints. According to Mustafa Sirri and recent CBI mandates, establishing a digital bank in Iraq now requires a minimum capital of 100 billion IQD (approx. $76M USD). Furthermore, obtaining a license for Electronic Payment Service Providers (such as digital wallets and payment processors) requires a minimum capital commitment of 10 billion IQD (approx. $7.6M USD).
Samer Tarazi (Simma) confirms this, noting that securing a digital payment and e-wallet license effectively demands capital equivalent to roughly $7 million. In addition to regulatory capital, companies must absorb Visa compliance, PCI certification, cybersecurity standards, and infrastructure costs, which Ali Ismail (founder of Wayl) estimates can reach tens of thousands of dollars before meaningful scale is achieved.
Within this environment, aggregation becomes a structural outcome. Without an aggregator, a merchant may need separate contracts with multiple banks, wallets, and card networks, each requiring its own integration and reconciliation process. Aggregators such as Wayl compress that complexity into one contractual relationship and one technical integration point, enabling merchants to access multiple payment channels simultaneously. In a system where many small merchants are informal and not fully registered, aggregation becomes a bridge between real commerce and regulated rails.
Market concentration further shapes incentives. A small number of established players, including Qi Card, dominate large segments of payroll-linked and card-based distribution channels. In Iraq, fintech competition tends to focus on onboarding speed, merchant acquisition, and regulatory alignment rather than reinvention of the core payment rails themselves.
Qi Card naturally dominated digital payments in Iraq because it was embedded in the government’s payroll infrastructure. International Smart Card, the company behind Qi Card, was established in 2007 as a public–private partnership anchored by Al-Rafidain Bank (one of Iraq’s largest banks), with an initial focus on digitizing salaries for state employees, retirees, and social protection beneficiaries.
The benefit of processing the government’s payroll is a mass-access channel. If a company’s product is the channel through which salaries and pensions are distributed to millions of citizens, it does not need to acquire customers individually. Users are automatically onboarded. For Iraqi fintechs, access to institutional relationships and distribution pipelines often carries more weight than technological differentiation.
By contrast, newer fintech startups typically enter the market through retail services and lack direct access to these government payroll pipelines. This places them at a structural disadvantage compared with incumbents such as Qi Card.
Settlement dependency introduces another structural constraint. In Iraq’s current architecture, fintech companies do not directly control final settlement accounts (ie: the accounts where transaction funds are stored and reconciled). Merchant funds typically pass through acquiring banks or licensed processors before being released to the fintech operator and, ultimately, to the merchant.
If a bank flags transactions, delays clearance, or initiates a compliance review, the fintech company cannot independently override that decision. Ali Ismail (Wayl) described a period when a transaction spike triggered a compliance review by an acquiring partner, temporarily withholding a seven-figure settlement balance. When this happens, merchant payouts slow, liquidity buffers tighten, and the fintech bears reputational damage even though the root decision sits upstream.
Domestic settlement dependency is compounded by cross-border payment constraints. In recent years, the Central Bank of Iraq (CBI) imposed transaction caps on certain international card usage in response to foreign exchange pressures and concerns about dollar outflows. These caps limit how much individuals and companies can transact abroad using Iraqi-issued cards.
For businesses that import goods, purchase foreign software subscriptions, or pay international suppliers, such limits complicate routine operations and planning. Samer Tarazi (Simma) described how this affects scaling cross-border commerce, especially when local cards cannot process larger international transactions efficiently. Transfers become multi-step compliance processes rather than simple payments.
Taken together, the payments stack explains why adoption moves slowly even when demand exists. The system is bank-anchored, capital-intensive, aggregator-heavy, and operationally dependent on counterparties whose timelines and controls fintech founders cannot fully manage.
Regulation: the bottleneck everyone talks about (and misunderstands)
To understand fintech in Iraq today, an investor or founder must understand one central fact: the regulatory system was designed to protect a fragile banking system in a volatile macro environment. Not to support innovation.
A decade ago, “fintech” as a concept was not a defined regulatory category. Most payment activity came through salary cards, telecom recharge, and basic card issuance. Regulation focused on banks rather than intermediaries. Mohammed Jamal (KAPITA) described early fintech regulatory actions as reactive. Products and workarounds appeared, and regulation followed.
Regulation during the mid-2010s remained heavily bank-centric. Payment services operated through licensed banks. Non-bank innovation was structurally limited. The CBI supervised banks, and payment providers were treated as extensions of that system rather than independent financial technology operators.
Over time, the CBI consolidated its approach. A major step was the Electronic Payment Services System Regulation No. 2 of 2024, which replaced scattered circulars with a clearer umbrella framework for electronic payment companies, wallets, and related service providers.
This led to practical, tangible evolutions for Iraq’s fintech founders and investors.
First, the regulation formalized license categories and operational obligations. Companies must operate under defined license types with capital deposits, compliance requirements, reporting obligations, and integration with licensed banks. The CBI published the recognized electronic payment license categories under Regulation No. 2 of 2024, including payment service providers, electronic wallet issuers, switch operators (entities that provide the infrastructure that allow different financial institutions, i.e. banks, e-wallets, to facilitate transactions), and related financial technology activities.
This reduces ambiguity for institutional operators, but it raises the entry bar for startups that want to test new models before deploying heavy capital.
Ali Ismail’s experience at Wayl shows why this matters. Wayl aggregates payment channels for informal merchants who cannot integrate with multiple banks and wallets on their own. However, there is still no clean, widely understood "payment facilitator” category tailored to Wayl’s model. The result is a gray zone where innovative distribution models can exist, but they must constantly interpret how legacy categories apply to new workflows.
Second, the regulation reinforces bank dependency. All licensed wallets must integrate with settlement banks. Funds ultimately clear through the banking system and are denominated in Iraqi dinars. This institutional design explains why Hady El Samra (Iraq Venture Partners) describes Iraqi fintech as bank-led rather than bank-disruptive. Founders are legally required to build on top of banks, so bank modernization and regulatory coordination become part of product risk.
RO Insights: bank-fintech collaboration in Tunisia
Tunisia’s fintech environment shares similarities with Iraq’s. Bank-centricity is one of them.
For Tunisian fintechs, “disrupting” banks is a pipe dream. On the contrary, Tunisian fintech founders need bank partnerships for their companies to exist. Embedding within a bank also gives the fintech direct access to a pool of existing customers. That can come with its own problems, as we’ll see below.
Nebras Jemel is the co-founder of Flouci, a leading Tunisian fintech startup. As of May 2025, Flouci claimed to have opened over 250,000 accounts.
Here’s how Nebras explains the trials and tribulations of working with banks:
“Our inceptive vision was instant payments. We wanted to enable easy, quick, cheap payments between individuals in Tunisia.
Our MVP aimed for what Zelle does in the US. An intra-bank network, where we’d connect different banking APIs to allow instant payments between account holders. That ended up being a heavy lift regulatorily-speaking, so we decided to become a bank ourselves.
But we didn’t have a banking license. Instead, we “rented” a banking license from an existing local bank. However, we started generating such transaction volume that our “landlord” bank became worried that we’d expand into other services and cannibalize their own clients. Strategic alignment was no more, so we went back to the drawing board. We partnered with another, much smaller Tunisian bank that had more to gain than to lose from the transaction volume we’d bring in.
Flouci is a special case in a startup context. We never had a traction problem. Young people in Tunisia are starved for digital banking solutions, and we’re one of the only ones to offer that. The tough part is carving out a regulatory space to operate within.
[...]
We do a revenue share with the bank whose license we use. All customers have an IBAN from the bank, but the bank can’t contact Flouci customers through its own channels. We maintain sole ownership of our client base.”
Excerpt from Flouci: Tunisia’s neobank, originally published in The Realistic Optimist in May 2025
Third, compliance became heavier as foreign exchange pressures increased. Since 2022, Iraq has faced increased scrutiny on dollar transfers and cross-border payments, particularly in relation to anti–money laundering and counter-terror financing enforcement. In response, the CBI strengthened transaction monitoring, imposed stricter documentation requirements for international transfers, and tightened reporting obligations for banks and payment providers.
These measures aim to control unauthorized dollar outflows and protect Iraq’s foreign currency reserves, which are essential for maintaining exchange rate stability.
In short, Iraqi fintech regulation has historically been structured for risk control and institutional stability, which makes innovation possible, but expensive and slow.
Over the past year however, the regulatory paradigm has favorably shifted in the innovators’ direction.
Recent, consequential evolutions
Over the past 12 to 18 months, the CBI has undergone a measurable institutional shift, driven by a generational and capacity transition within its IT and Payments Departments. Younger, internationally exposed teams are taking the lead, bringing with them a deep familiarity with global fintech supervision tools such as tiered licensing, regulatory sandboxes, and digital banking governance models.
Mustafa Sirri, who has worked directly with the CBI on financial sector modernization, explained that discussions with regulators are becoming more technically grounded. Rather than focusing exclusively on compliance enforcement, conversations increasingly revolve around how fintech business models function in practice, where the risks sit, and what specific controls are realistic for the Iraqi market's unique conditions.
This matters because it changes the regulator’s default behavior. Instead of only enforcing existing categories, the CBI is increasingly trying to understand models that do not fit cleanly inside them.
As Saif Aljaibeji from Urth (an Iraqi growth stage fund) notes, the CBI has begun signaling its direction through policy roadmaps that outline how regulators are thinking about fintech development. While these signals do not immediately resolve operational constraints, they give founders and investors an indication that regulators are increasingly thinking about how digital financial services should evolve within Iraq’s financial system.
One concrete example of this shift is the development of a regulatory sandbox framework the CBI is working on. Instead of requiring a company to immediately meet multi-million-dollar capital thresholds, the sandbox allows limited, monitored experimentation while the regulator observes risks, transaction patterns, and operational controls. We’ll dive deeper into this sandbox later.
Importantly, according to Mohammed Jamal (KAPITA Research) and Ali Ismail (Wayl) this sandbox initiative was not externally imposed by donors or consultants. It was initiated by the CBI itself as a mechanism to better understand emerging fintech models that don’t fit into its existing licensing categories. For founders operating in gray areas, such as payment aggregation or facilitation, this represents a structural shift from a purely top-down mandate approach toward a more consultative regulatory posture.
This change is also embedded in formal policy targets. The CBI’s National Financial Inclusion Strategy (NFIS) targets lifting the share of Iraqis who send or receive a digital payment to 85%. Digital payments are positioned as a national development priority, tied to the country’s economic formalization and overall modernization.
Another material change introduced under the Electronic Payment Services System Regulation No. 2 of 2024 is the extension of license validity from five years to ten years. For investors, this represents more than a minor administrative adjustment. Infrastructure-heavy fintech businesses require longer planning horizons. A ten-year license duration reduces regulatory renewal risk and allows capital deployment to be modeled with greater predictability.
Revand Bamarni from Meso Capital (an Iraqi investment firm) emphasizes that clearer regulation is one of the key enablers of ecosystem growth, particularly in a market where licensing ambiguity has historically constrained startups' scale. In his view, stronger regulatory direction gives founders and local investors clearer ground on which to build, reducing uncertainty around licensing and compliance requirements.
Saif Aljaibeji (Urth Fund), frames the same issue from the investor side. When startups operate in gray areas without a clear licensing pathway, fundraising becomes materially harder because investors are forced to underwrite regulatory uncertainty alongside business risk. Clearer legal rails help startups operate with confidence while also making it easier for venture capital to price risk, structure rounds, and support companies through longer growth cycles.
None of these developments entirely eliminate existing constraints. But practically, the CBI is building the institutional capability to regulate fintech using clearer categories, longer horizons, and supervised learning tools. For investors and founders assessing Iraq, that trajectory is as important as the current constraints themselves.
Current initiatives
The regulatory conversation in Iraq has shown signs of positive progress. Several initiatives are already underway. Together, they show the CBI’s desire to proactively solve specific bottlenecks.
The clearest example of this is the CBI’s new regulatory sandbox. From what we gather, the sandbox is expected to become operational over the course of 2026. It will follow a phased onboarding approach, where a limited number of companies are admitted first so the regulator can observe and adjust before scaling access.
To understand why this matters, it helps to explain what the sandbox changes. In simple terms, the CBI is moving from a “guess-first” model to a “test-first” model.
Under a guess-first approach, regulators write strict rules in advance based on what they think might happen. Under a test-first approach, regulators allow limited experimentation under supervision, collect real data, and then write rules based on observed behavior. Mustafa described the sandbox as a learning instrument. Instead of drafting policy in isolation, the CBI will watch how products function in the market before finalizing regulatory treatment.
What does this look like in practice?
Take Buy-Now-Pay-Later (BNPL) as an example.
Under the old approach, regulators might worry that BNPL products could increase consumer debt. Without a specific BNPL license category, they might simply delay approvals or restrict activity.
Under the sandbox approach, a startup could be allowed to offer small, capped BNPL loans to a limited group of users for a defined period. The CBI would monitor repayment rates, fraud levels, and default risk. If the data shows manageable risk, a specific BNPL framework could be drafted with evidence behind it.
RO Insights: launching BNPL in an uninitiated market
The promise behind BNPL is elegant: higher basket sizes for merchants, zero-interest & instant loans for consumers.
However, launching a BNPL startup in a market unaccustomed with it isn't for the faint-hearted.
Kukaraj Tharmasegaram and Urmila Chandrasekeram are the co-founders of Mintpay, a Sri Lankan fintech company offering buy-now-pay-later (BNPL), cashback rewards, and vouchers.
Launched in 2020, Mintpay now claims to have onboarded over 500,000 customers and to serve over 2,500 merchants.
Mintpay’s beginnings were treacherous. Here’s how the founders explained how they methodically overcame the barriers they encountered:
“The initial reaction was skepticism. We pitched it to as many people as we could, from bankers to investors. The first question was always the same: “Sure, this works in other markets. But in Sri Lanka, where default rates are high, how on earth will you make this work?” The idea that someone could sign up in two minutes and immediately get credit to buy lifestyle products didn’t sit well with many people.
Central to this skepticism was the question of credit assessment and perceived market risk. By 2019, Sri Lanka’s banking sector already had a high non-performing loan (NPL) rate, and consumer credit without collateral was widely viewed as risky. For industry veterans who had relied on traditional credit tools and methodologies, the idea of using alternative data and machine learning to reliably assess someone’s ability to repay felt unrealistic.
Another major challenge was funding. BNPL is, by nature, a cash-intensive business. We pay the merchant in full at the moment of the transaction, and gradually recuperate customers’ installment payments afterward. We raised a round from friends and family, which helped us bootstrap for the first few years. That early support allowed us to prove the concept before raising more structured capital.
Convincing merchants was the other big hurdle. For BNPL to work, you need a strong base of merchants that accept you as a payment method. Many of them initially saw us as another payment gateway. We approached them with our model (and our commission that covers our cost of capital, risk, and operational costs). They didn’t immediately understand why they should use a payment gateway like ours, which charges a higher commission for payments.
It took time to explain to merchants that this wasn’t just a payment method. We had to convince them that Mintpay is a tool to drive incremental sales, reach new customers, and reduce their dependency on cash-on-delivery. Further, we had to educate them on why the commission was set at that level and how BNPL could benefit them long-term. In other words, offering a BNPL option usually drives more sales and increases average order value.
Our first merchant partners were people from our network (friends, or friends-of-friends who ran businesses). Once we gained some traction, onboarding more merchants became easier.
To sum this up, the initial reception was cautious. People needed to see proof, understand the mechanics, and trust that the model could work in Sri Lanka before they were willing to adopt it.”
Excerpt from Mintpay: pioneering BNPL in Sri Lanka, originally published in The Realistic Optimist (March 2026)
Now, consider wallet limits.
Today, digital wallet caps are often set conservatively due to AML concerns. A startup might argue that merchants need higher limits to pay suppliers or move inventory funds.
Inside the sandbox, the CBI could temporarily allow higher wallet limits for a controlled group of verified merchants. If no misuse or fraud appears, those higher thresholds could later become formalized policy.
The third example is the “payment facilitator” gap we covered earlier.
Companies like Wayl aggregate hundreds of informal merchants who do not individually integrate with banks. There is currently no clearly defined license category tailored for such aggregators.
Under a traditional rulemaking approach, this creates a gray zone. The company either operates under broad payment licenses that were not designed for its model, or it waits for legislation.
Under the sandbox model, the CBI can admit Wayl into a supervised testing lane. The regulator can observe how Wayl conducts merchant vetting, how funds are moved, how compliance is handled, and where risk occurs. Resulting learnings can then inform the creation of a properly structured aggregator license category.
The CBI’s shift from theory to observed evidence is what readers should take away from this piece.
Lastly: interoperability
Beyond the sandbox, additional reforms are tackling another blocker to scale: interoperability. Interoperability is the ability of different payment systems to "talk" to each other so a customer can pay any merchant, regardless of which bank or wallet they use.
Today, the Iraqi market is fragmented in that regard. Whether a merchant can accept a digital payment often depends on which specific bank, wallet, or processor they are connected to. The NFIS strategy has made solving this fragmentation a top priority by mandating interoperable QR codes and prioritizing a unified national payment gateway to act as the "national plumbing" for all digital transactions.
These initiatives aim to eliminate the "multiple integrations" problem, where a merchant currently needs 4-5 separate contracts to cover different payment channels. By creating a framework that allows traditional banks and fintech wallets to work on the same network, Iraq is building a "national public infrastructure" where digital payments become as universal and convenient as cash.
This is the same “national rails” playbook of other large cash-heavy markets used to break fragmentation. Brazil’s Pix, run by its central bank, turned instant transfers into a default consumer and merchant habit and led to a sharp fall in cash’s share of transactions from 2020 (42%) to 2023 (22%).
The NFIS also highlights e-KYC and tiered KYC rules as priorities. Currently, onboarding requirements can be heavy relative to the risk profile of small users. A tiered approach allows low-risk accounts to open with simplified documentation while maintaining stricter rules for higher-value transactions. Given that baseline account ownership is just 11%, lowering onboarding friction is essential.
On the demand side, the most forceful lever is the announced plan to end cash payments in government institutions by July 2026. If enforced at scale, this moves digital payments from optional behavior into required interaction for everyday public services.
That said, mandates alone do not create trust. The difference this time is sequencing. The NFIS pairs the government-use mandate with interoperability reform, e-KYC simplification, and infrastructure upgrades. In other words, exposure is being introduced alongside usability improvements, ensuring that the rails work when behavior is nudged.
Finally, the reliability of bank partners is being addressed through a parallel reform track. The CBI’s Standards Booklet 2025 introduces binding pathways for banks, framed as “Stay, Merge, or Exit,” and ties them to enforceable standards in governance, operational resilience, and payment system capabilities. For fintech founders, stronger banks mean more reliable settlement partners. A modern payments ecosystem cannot scale on top of weak counterparties.
These efforts outline what the CBI is attempting to build: a supervised testing lane for gray-zone models, an interoperability layer to reduce acceptance fragmentation, a modernized onboarding regime to lower inclusion friction, a government-led mandate to expand recurring usage, and a bank reform program to make counterparties more dependable.
These initiatives are concrete and directionally coherent, unlike Iraq’s past payments regulatory agenda.
The RO’s outlook
After researching Iraq’s fintech ecosystem and speaking with founders, investors, and regulators, one conclusion becomes clear: Iraq’s transition toward digital payments will be driven by the gradual rebuilding of financial trust, not technology alone.
Living in Iraq, the persistence of cash is visible everywhere. In my own experience, around 90% of everyday transactions still happen in cash. Groceries, restaurants, cafés, shopping malls, taxis, and even large purchases such as cars or property are typically settled with cash. Digital payment options technically exist in many places. POS terminals are increasingly available in malls, restaurants, and major retail outlets. They are rarely used. The expectation from both merchants and consumers is still that payment will happen in cash.
I personally follow the same pattern. I pay cash for almost everything in physical stores. I only use digital payment tools when something cannot be purchased with cash. For example, I use a Qi Visa Card to pay for online purchases from international websites or when booking hotels and flights. I also use digital wallets to recharge internet or phone credit and sometimes to transfer money to merchants when I buy something online within Iraq.
Part of the reason is practical. Most Iraqis simply do not keep money inside bank accounts or digital wallets. Many people deposit funds only when they need to complete a specific transaction, such as booking a flight, purchasing a product online, or paying for an international service. Once the transaction is completed, balances are withdrawn back into cash. In other words, digital tools often function as temporary transaction channels rather than a place where money is stored.
Trust explains much of this behavior. Over the past two decades, many Iraqis experienced banking instability, frozen funds, or bureaucratic obstacles when trying to access their own money. Even though the banking system has stabilized significantly in recent years, the reputation damage from that period still shapes consumer psychology.
This trust gap is why fintech adoption in Iraq behaves differently from many other markets. Technology is not the main barrier. Smartphones are widespread, internet penetration is high, and Iraq’s population is young and digitally literate. What the ecosystem lacks are compelling use cases and institutions that people trust enough to store value with.
Yet, one of the most surprising insights from researching this ecosystem is how much progress is happening behind the scenes.
The Central Bank of Iraq has begun shifting its regulatory posture in ways that would have been difficult to imagine only a few years ago. Conversations with advisors working closely with the regulator reveal a clear generational shift inside the institution. Younger teams with exposure to global fintech supervision are increasingly shaping policy discussions. Initiatives such as the regulatory sandbox, interoperability reforms, and the extension of license tenures signal a move toward a more consultative and experimentation-friendly regulatory environment.
Among these developments, one of the most important milestones is the CBI’s upcoming regulatory sandbox. For years, one of the biggest obstacles for fintech founders was the mismatch between traditional banking regulations and new technology-driven business models. The sandbox introduces a supervised environment where startups can test products and business models legally without expensive licenses.
This marks a monumental shift in how the Iraqi government is approaching digital payments. For the first time ever the government is taking a proactive and supportive approach towards innovation and technology rather than a protective approach. In practical terms, it allows both founders and regulators to learn from real market behavior rather than relying solely on theoretical risk assumptions.
Other reforms could further accelerate adoption. Interoperability initiatives are designed to allow banks, wallets, and merchants to operate on shared payment rails, reducing the fragmentation that currently complicates digital transactions. At the same time, the introduction of licensed digital banks could significantly reduce the friction of opening bank accounts by allowing users to onboard entirely through smartphones rather than through long and often frustrating in-branch processes.
Together, these developments create the strongest policy tailwinds Iraq’s fintech sector has experienced so far.
However, policy reforms alone will not produce a cashless economy.
The missing ingredient remains compelling use cases. For most consumers, digital payments must clearly outperform cash in reliability, safety (the trust element) or financial benefit before behavior changes. Mandates alone cannot produce that shift, as earlier experiments demonstrated. Adoption will occur when digital payments become more useful than cash, not simply when they become available.
Companies like Simma and Wayl illustrate how that migration may happen. Their growth suggests that Iraqi consumers and merchants are willing to adopt digital tools when those tools solve real problems. The demand already exists. What has been missing are the infrastructure layers, regulatory clarity, and trust mechanisms needed to convert that demand into digital transactions.
For founders building in Iraq, the lesson is clear. Fintech here is not purely a technology challenge. It is a trust problem layered on top of institutional complexity. Products must be reliable, transparent, and easy to use. Reputation matters enormously. Word of mouth spreads quickly, and credibility can determine whether users are willing to try a financial product at all.
I believe Iraq will almost certainly become less cash-dependent over the next decade. For now, Iraq’s fintech transformation is unfolding silently. The direction of policy, the expansion of digital infrastructure, and the growing presence of fintech startups all point toward gradual change. But that change will be incremental, not explosive. Adoption will expand as trust builds, use cases improve, and the financial system proves itself more consistently reliable.
Disclaimer: we have done our absolute best to verify the veracity of all facts we mention. Some facts are more subjective than others and are thus prone to dispute. If you find errors, please email tim@realisticoptimist.io
The Realistic Optimist’s work is provided for informational purposes only and should not be construed as legal, business, investment, or tax advice.