Iraq – Kurdistan Region Introduces Mandatory UPN Registration

The Kurdistan Regional Government (KRG) has introduced a mandatory Unique Personal Number (UPN) registration requirement for employees working in the Kurdistan Region of Iraq (KRI).

The initiative forms part of a broader effort to strengthen tax administration, improve workforce transparency and enhance oversight of employment records across both the public and private sectors.

Under Decision No. 3411, issued on the 10th of May 2026, the requirement applies to both local and foreign employees, including managers and directors. Companies operating in the KRI should begin reviewing employee records and preparing for compliance ahead of the implementation deadline.

Regulatory Background

The UPN system has been introduced by the General Directorate of Tax and State Real Estate as a centralized identification mechanism that links individuals to their employment records.

The initiative is intended to improve the accuracy of workforce data and enable authorities to cross-reference private sector payroll records against public sector employment databases. The requirement forms part of wider government efforts to combat tax evasion, identify dual public-private sector employment and strengthen regulatory oversight.

The registration obligation applies broadly across the workforce and covers local employees, foreign nationals, managers and directors, regardless of nationality or role.

Applicability and Scope

The requirements apply to entities operating within the Kurdistan Region of Iraq, including:

• Limited liability companies
• Branches of foreign companies
• Local entities and businesses

The registration requirement applies to all employees, managers and directors, whether local or foreign nationals.

Key Dates and Compliance Deadline

Decision No. 3411 took effect on the 10^th of May 2026.

Companies must complete implementation of the UPN registration process by the 31^st of December 2026.

Following this deadline, Personal Income Tax (PIT) forms and certain related submissions may not be accepted unless the relevant employee’s UPN information has been included.

Practical Considerations and Ongoing Obligations

Each employee must attend a designated federal bank in person to complete the registration process and provide the required biometric information.

The registration process typically takes one working day and includes:

• Presenting a valid identification document and passport
• Requesting UPN registration at the designated bank
• Providing fingerprints and other digital biometric information
• Receiving confirmation of registration via a QR code containing the registered information

Companies should review employee records, identify individuals who have not yet registered and coordinate registrations well in advance of the year-end deadline.

Particular attention should be given to foreign employees, managers and directors who may need additional support in completing the process.

Risks of Non-Compliance

Failure to complete UPN registration by the prescribed deadline may result in the rejection of applications and requests submitted to the authorities, including Personal Income Tax (PIT) filings.

This could affect a company’s compliance standing and may impact its ability to obtain certain official approvals, confirmations or support letters from the relevant authorities.

How Mercator® by Citco (Mercator) Can Help

Mercator can assist with:

• Assessing the applicability of the UPN requirements across your workforce
• Reviewing employee records and identifying registration gaps
• Supporting coordination of the UPN registration process
• Advising on compliance obligations and implementation timelines
• Liaising with local advisers and authorities where required

For assistance, please contact [email protected]