Iraq Signals Antitrust Enforcement: Competition Council Issues Procedural Guide On Mergers And Restrictive Practices

In October 2025, the Iraqi Competition and Antitrust Council (“Council”) issued a procedural guide titled “The Impact of Mergers and Restrictive Commercial Practices on Companies Operating in the Iraqi Market.” (the “Guide”). The Guide represents the first substantive publicly available guidance issued by the Council since its establishment in July 2023 – and is therefore highly significant. The guide indicates a potential shift toward more active enforcement—outlining short review windows, registration steps, and possible penalties for non‑compliance, though the scope and timing of implementation remain unclear.

Scope of the Guide

Prepared under Article 7(6) of the Competition and Anti‑Monopoly Law No. 14 of 2010 (the “CAL”), the Guide consolidates procedural rules for mergers, acquisitions, and restrictive commercial arrangements and applies to public, mixed, and private entities. A separate guide on monopoly matters is expected.