In a circular addressed to “All branches of foreign companies registered in Iraq,” the Department required the submission of a document from the parent company’s main office. The document must be:

The New Requirement

Issued by the Main Headquarters: This must come from the main company’s headquarters, not the local Iraqi office.
Duly Certified: The document must be properly authenticated. Firstly, from the parent company to the competent authority then authenticated from the foreign affairs ministry and direct it to the Iraqi embassy in the country of the parent company, send it by mail to the Iraq foreign affairs ministry and after their authentication will be archived in the company registration department.
Confirm specific statuses. The certificate must expressly state that the parent company is:

1.Legally established and operational.
2.Not being liquidated.
3.Not insolvent.
4.Not suspended from operations.

Not subject to any domestic or international sanctions.
Renewed Every Six Months: Importantly, this is not a one-time submission. The certified document must be updated and resubmitted every six months.

Key implications for businesses.
This development marks a substantial shift in the regulatory environment for foreign investment in Iraq. The key implications include:
Increased Administrative Burden: Legal and compliance teams will be required to develop a rigorous, semi-annual process for obtaining, certifying, and delivering this document to their parent firm. Failure to maintain this cycle may result in penalties or the branch being considered non-compliant.

Enhanced Scrutiny and Transparency: The decision suggests a shift by Iraqi authorities toward greater transparency and ongoing control of foreign parent businesses’ financial and legal status. The emphasis on sanctions is particularly noteworthy, matching with worldwide compliance trends.

Operational Risk: If a parent firm has financial hardship (liquidation/insolvency) or legal/regulatory issues (sanctions) within a six-month period, the legal standing of its Iraqi branch may be jeopardized immediately upon the next mandatory filing.

Potential Delays: The certification and legalization of overseas documents might be time-consuming. Companies must plan ahead of each six-month deadline to accommodate for processing delays in their home countries.

Recommended Action
Foreign enterprises with registered branches in Iraq should take quick action:
Notify the parent company’s legal and secretarial departments about this new recurrent need.
Establish a process: Create a calendar-driven process for generating the status certificate, obtaining the required certifications (notarization, apostille, and so on), and submitting it to the Iraqi Companies Registration Department.
Seek Legal Guidance: To avoid operational disruptions, consult with local Iraqi legal counsel to confirm the specific certification requirements and ensure the submitted documents fully comply with the directive.