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POL-10

This is a proposal for discussion, not an enacted law.

Ali Zuweid's Political Programme

Proposed legislation · State, Constitution, Justice, Rights and Governance

Integrity, Conflicts of Interest, Asset Disclosure and Whistleblower Protection Bill

A unified framework for preventing corruption before it occurs: broadening conflicts of interest into a manageable issue rather than merely grounds for removal; developing asset disclosure into risk-based verification with limited public statements for senior officials; and giving whistleblowers practical protection from retaliation through secure channels and direct links to the judiciary and witness-protection system.

Document number
POL-10
Version
1.0
Document type
Proposed legislation
Axis
State, Constitution, Justice, Rights and Governance
Publication date
6 October 2026
Last updated
6 October 2026
Scope
Republic of Iraq · Federal level within constitutional limits
Website
alizuweid.com

Executive Summary

Iraq already has an actual legal foundation for integrity and asset disclosure, rather than a complete legislative vacuum. Article (102) of the Constitution establishes the independence of the Commission of Integrity and its oversight by the Council of Representatives. The Commission of Integrity and Illicit Gain Law No. (30) of 2011, amended by Law No. (30) of 2019, regulates asset disclosure and illicit gain and defines conflicts of interest. There is also the Protection of Witnesses, Experts, Informants and Victims Law No. (58) of 2017, while new instructions regulating receipt of information and reports concerning corruption and illicit-gain cases were issued in 2026.

The central problem is that these instruments operate in adjacent tracks more than as a single preventive system. The current conflict-of-interest definition focuses on the financial interests of declarants and close relatives without distinguishing actual, potential and apparent conflicts. Current remedies tend towards eliminating the conflict or leaving office, without a clear graduated set of less restrictive measures such as recusal from a particular decision, reallocation of competences or orderly divestment. Asset disclosure has a broad legal basis and is applied to thousands of declarants, but needs to move from merely receiving forms to risk-based verification, with a clear distinction between the full confidential declaration and senior officials' limited public statement of interests.

Commission of Integrity data published in 2026 show that the system exists and is active: the Commission announced receipt of 14,387 asset-disclosure forms in April 2026, identification of 32 conflicts of interest and 87 verification visits. Realistic reform therefore requires developing the powers and procedures of the existing Commission and linking them to a clearer institutional system for managing interests and protecting whistleblowers, rather than creating a new body.

Whistleblower protection presents a different gap. The 2017 Law provides important security and judicial protection in covered proceedings, but protection from employment or contractual retaliation needs an independent framework beginning at the moment of reporting, without waiting for information to become a criminal case or for physical danger to materialise. The bill therefore distinguishes broad administrative and employment protection under this Law from specialised security protection under Law No. (58) of 2017 where life or safety is threatened.

The bill adopts an approach consistent with the United Nations Convention against Corruption, to which Iraq acceded on 17 March 2008, particularly requirements to strengthen integrity, prevent conflicts of interest, disclose activities, interests and assets, facilitate corruption reporting and consider protecting reporting persons. It also draws on Organisation for Economic Co-operation and Development guidance and the structure of the European whistleblower-protection directive, without copying them verbatim or creating obligations unsuited to Iraq's constitutional system.

Legislative Gap

Principal gaps addressed by the bill
FieldCurrent positionProposed remedy
Conflicts of interestA definition focused on financial interests of relatives up to the second degree, with limited remedies.Actual/potential/apparent conflicts, with graduated management beginning with disclosure and recusal and requiring departure from office only where necessary.
Asset disclosureA broad mandatory, confidential system with existing verification powers.Retain the full confidential declaration, add a limited public statement of senior officials' interests, and apply risk-based auditing.
WhistleblowersExisting reporting channels and security protection linked to cases and risks.Protection from retaliation from the moment of reporting, internal and external channels, a balanced civil/administrative burden of proof, and interim measures.
CoordinationMultiple integrity, oversight and judicial bodies.Referral and data-exchange protocols without creating a new authority.
PrivacyStrict confidentiality of the full declaration.Maintain confidentiality while publishing a limited interest summary excluding addresses, accounts and minors' data.

The bill does not assume that every conflict is corruption or that every unusual increase in wealth proves a crime. Good prevention distinguishes legitimate private interests from abuse of power and provides mechanisms to address conflicts before they produce biased decisions. Similarly, the bill separates administrative verification from criminal proof, which remains subject to the courts and fair-trial safeguards.

Proposed legislative policy

The document adopts a standalone substantive law using existing institutions rather than establishing a new body. The Commission of Integrity centrally administers financial declarations, the interests register and external reports; the Federal Board of Supreme Audit remains an audit partner; Public Prosecution and the judiciary handle judicial proceedings; and government bodies manage conflicts and internal reporting channels day to day.

The bill distinguishes the “full declaration” from the “public statement”. The former is a confidential oversight-verification tool containing necessary financial details; the latter supports democratic accountability for senior officials and is limited to job-related interests and appropriate value bands. Transparency thus does not become publication of account numbers, property addresses or children's data.

Whistleblower protection depends on an objective standard: reasonable grounds to believe the information was true when reported, rather than the investigation's final outcome. This prevents punishment of good-faith reporting of suspicions that are not substantiated, while retaining liability for deliberately fabricated reports intended to cause harm.

Text of the bill

Proposed promulgation formula: In the name of the people, and pursuant to what the Council of Representatives adopts under clause (First) of Article (61) and clause (Third) of Article (73) of the Constitution of the Republic of Iraq, the following Law is issued.

Statement of reasons

This Law is enacted to strengthen corruption prevention, protect public funds and institutional trust, regulate conflicts through disclosure and proportionate management, improve the effectiveness and privacy safeguards of asset disclosure, protect whistleblowers from employment and contractual retaliation while connecting this protection to existing security and judicial safeguards, fulfil the Republic of Iraq's obligations under the United Nations Convention against Corruption, and modernise integrity instruments according to contemporary institutional practices.

Explanatory memorandum

1. Why Is the Existing Law Insufficient on Its Own?

The 2019 amendment made significant progress by introducing illicit gain, expanding financial declarations and defining conflicts of interest. The system nevertheless remains more oriented towards responding after a problem emerges than managing it preventively. The current definition is relatively narrow and financially focused, although conflicts can arise from professional relationships, outside positions, organisational interests or promises of future employment. The bill does not criminalise these relationships in themselves, but makes them disclosable, assessable and manageable.

Official practice shows that the Commission of Integrity already has machinery to examine declarations and verify conflicts. An additional authority would duplicate institutions; greater effectiveness comes from unified standards, digital tools and risk-based verification, while retaining external oversight of declarations by Commission leaders.

2. Conflicts of Interest Are Not Synonymous with Corruption

The central rule is that a private interest does not imply corruption. An official may lawfully own shares or be related to someone dealing with the State. The problem arises when they participate in a public decision affected by that interest without disclosure or appropriate management. The Law therefore distinguishes actual, potential and apparent conflicts and provides graduated remedies beginning with recusal and ending, where management is impossible, in divestment or departure from the assignment or office under law.

This approach is more practicable than a binary rule requiring either no private interests or resignation. It also retains professional expertise while preventing improper influence.

3. Reforming Asset Disclosure

The bill retains the main declarant categories and the entry, annual and departure declaration cycle, adding three improvements: data covering beneficial ownership, digital assets and professional interests; risk-based auditing rather than identical treatment of every form; and limited public interest statements for senior officials.

The limited public statement is deliberate. Publishing full declarations creates security and privacy risks without always adding oversight value, while withholding everything reduces the press's and society's ability to identify conflicts. The middle course publishes the nature of interests, appropriate value bands, outside activities and substantial gifts while retaining precise details with the Commission.

4. Protecting Whistleblowers before They Become Witnesses

Witness Protection Law No. (58) of 2017 matters where testimony or reporting connects with proceedings and life or safety is at risk. Much retaliation begins earlier: employee transfers, frozen promotions, terminated supplier contracts or coercive litigation. The bill therefore creates administrative and employment protection independent of criminal proceedings.

Internal channels are not mandatory: reporting a manager or an internal influence network may make them unsafe. Whistleblowers may approach the Commission of Integrity or the competent judicial or oversight body directly.

5. Balancing the Rights of Persons Named in Reports

Whistleblower protection does not presume the reported person's guilt. The bill protects investigative confidentiality and defence rights, limits judicial disclosure of identity to necessary cases, and does not publish names merely because they appear in a report. Malicious reporting is confined to deliberate fabrication with knowledge of falsity and intent to harm, preventing its use to threaten good-faith whistleblowers.

6. Relationship with the 2025–2030 Integrity Strategy

Government bodies in 2026 refer to implementing the National Integrity and Anti-Corruption Strategy 2025–2030 through corruption-risk analysis and institutional remedies. The bill accords with this direction by turning scattered administrative risk-management practices into a general legal duty for the most exposed roles and operations, leaving implementation details to competent bodies.

Financial and Implementation Implications

No new federal authority is required. Costs centre on upgrading the digital platform, information security, linking registers, training integrity and human-resources units, and developing risk-based audit mechanisms. Existing Commission of Integrity, Board of Supreme Audit and government infrastructure can be used, reducing establishment costs compared with a new independent body.

No published data support a reliable estimate of the unified platform's cost or staffing needs in each body, so the bill gives no hypothetical figure. In preparing instructions and implementation, the Council of Ministers should attach a cost estimate covering technical infrastructure, licences and cybersecurity, training, any additional staff, and specialised security-protection costs when activated.

Practical viability should be assessed through compliance indicators, audit quality and response times, not solely form or report counts. Increased reporting can reflect greater trust, while fewer reports can indicate fear or poor access rather than less corruption.

Brief International Comparison

Standards Adopted without Copying
ReferencePrincipleReflection in the bill
United Nations Convention against CorruptionEmployee integrity, prevention of conflicts, declarations of activities, investments, assets and gifts, facilitation of reporting and consideration of whistleblower protection.Expanded declarations, conflict management, secure channels and protection from retaliation.
OECD Public IntegrityGraduated conflict management, practical guidance and a risk-based approach.Recusal, reassignment, divestment, preventive advice and risk-directed auditing.
European Directive 2019/1937Internal and external channels, confidentiality, prevention of retaliation, protection of assistants and conditional protection for public disclosure.No mandatory internal reporting first, confidential identity, interim measures and a balanced burden of proof.

The bill adopts no single foreign model, using these standards to test safeguard adequacy while retaining jurisdiction, investigations and institutional structures within Iraq's existing system.

Sources and references

  1. Iraqi Constitution — Iraqi Council of Representatives
    Iraqi Constitution and legislation
    Iraqi Constitution — Council of Representatives
  2. Commission of Integrity and Illicit Gain Law No. (30) of 2011 — Iraqi Legislation Database
    Iraqi Constitution and legislation
    https://iraqld.msla.iq/legislations/showlegislation?asc=110120127533544
  3. First Amendment to the Commission of Integrity Law No. (30) of 2011, Law No. (30) of 2019 — Iraqi Official Gazette issue 4568
    Iraqi Constitution and legislation
    https://www.undp-aciac.org/resources/Commission%20Of%20Integrity%20Law%20-%202019%20Amendment.pdf
  4. Instructions No. (1) of 2026: Mechanism for Receiving Information and Reports concerning Corruption and Illicit Gain
    Iraqi Constitution and legislation
    https://iraqld.msla.iq/legislations/showlegislation?lawbookid=54793
  5. Protection of Witnesses, Experts, Informants and Victims Law No. (58) of 2017 — Ministry of Justice
    Iraqi Constitution and legislation
    https://www.moj.gov.iq/view.3194/
  6. Regulation No. (9) of 2018 Defining Cases Covered by the Protection Law — Ministry of Justice
    Iraqi Constitution and legislation
    https://www.moj.gov.iq/view.4075/
  7. Instructions No. (1) of 2019 Facilitating Implementation of the Protection Law — Ministry of Justice
    Iraqi Constitution and legislation
    https://www.moj.gov.iq/view.4216/
  8. Integrity Commission: 14,387 asset-disclosure forms and 32 conflicts of interest in April 2026 — Iraqi News Agency
    Iraqi government bodies
    https://ina.iq/ar/local/262810-14387.html
  9. Ministry of Planning: Implementation of the National Integrity and Anti-Corruption Strategy 2025–2030
    Iraqi government bodies
    https://mop.gov.iq/archives/36397
  10. United Nations Convention against Corruption – UN Treaty Collection
    International treaties and conventions
    https://treaties.un.org/Pages/ViewDetails.aspx?chapter=18&mtdsg_no=XVIII-14&src=TREATY
  11. United Nations Convention against Corruption – official text
    International treaties and conventions
    https://www.un.org/en/ethics/assets/pdfs/UN_Convention_Against_Corruption.pdf
  12. OECD Public Integrity Handbook / conflict-of-interest guidance
    International institutions and comparative references
    https://www.oecd.org/en/publications/oecd-public-integrity-handbook_ac8ed8e8-en.html
  13. Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law
    Comparative legislation
    https://op.europa.eu/en/publication-detail/-/publication/cc54a8ef-1036-11ea-8c1f-01aa75ed71a1

POL-10 · Integrity, Conflicts of Interest, Asset Disclosure and Whistleblower Protection Bill · Ali Zuweid's Political Programme · 6 October 2026

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