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.
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.
Constitutional and legal context
The constitutional foundation comprises several connected rules. Article (27) establishes the inviolability of public funds and every citizen's duty to protect them; Article (47) enshrines separation of powers; Article (61) assigns legislative and oversight functions to the Council of Representatives; and Article (102) expressly identifies the Commission of Integrity as independent, subject to parliamentary oversight and regulated by law. This structure requires strong preventive and investigative integrity legislation without turning the Commission into a disciplinary authority above the judiciary, Parliament or other constitutional authorities.
The Commission of Integrity and Illicit Gain Law No. (30) of 2011, following its amendment in 2019, expanded asset disclosure, added illicit gain and conflicts of interest, identified broad categories of declarants and required declarations on taking office, leaving office and annually. It also authorised the Commission to examine declarations, investigate data and seek assistance from official bodies, and prescribed sanctions for refusal, illicit gain, concealment of information and disclosure of form data.
Instructions No. (1) of 2026 regulated receipt of corruption and illicit-gain information and reports, recognising multiple channels including informants, courts, official correspondence, Public Prosecution, email, hotlines, field teams and media. This is an important organisational step, but focuses on receiving and handling information and does not alone establish comprehensive protection against employment or contractual retaliation.
The Protection of Witnesses, Experts, Informants and Victims Law No. (58) of 2017 provides a specialised framework where risks connected with criminal proceedings exist, supported by subsequent regulations and instructions. It remains essential for security protection but does not replace protection from the initial moment of reporting, before a criminal case arises.
Legislative Gap
| Field | Current position | Proposed remedy |
|---|---|---|
| Conflicts of interest | A 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 disclosure | A 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. |
| Whistleblowers | Existing 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. |
| Coordination | Multiple integrity, oversight and judicial bodies. | Referral and data-exchange protocols without creating a new authority. |
| Privacy | Strict 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
Chapter 1 — Definitions, Objectives and Scope
Article (1) — Definitions
For the purposes of this Law, the following expressions shall have the meanings set out below: Commission: The Federal Commission of Integrity. Covered body: Any authority, ministry, body not attached to a ministry, independent body, institution, department, public or mixed company, local government, administrative unit or body managing federal public funds or exercising a federal public competence, with due regard to the constitutional limits of regional jurisdiction. Public employee: Any person entrusted with a permanent, temporary, acting, assigned or contractual public office or service, paid or unpaid, who exercises public authority or disposes of public funds. Declarant: A person required to submit an asset or interests declaration under this Law.
The termprivate interest means any identifiable financial, professional, commercial, family, organisational or non-financial benefit accruing to the declarant, spouse, dependent children or a closely connected person that may reasonably affect impartiality. Anactual conflict of interest means a conflict between public duty and an existing private interest; apotential conflict of interest means a situation reasonably capable of becoming an actual conflict; and anapparent conflict of interest means a situation involving objective facts that would cause an ordinary person reasonably to doubt the impartiality of a decision, even where no actual private benefit is established.
The termfull financial declaration means the detailed confidential statement of assets, rights, liabilities and interests specified in this Law; thepublic statement of interests means the summary of job-related interests published under Article (30). Thebeneficial owner means the natural person ultimately owning or controlling, directly or indirectly, an asset, holding, entity or benefit.
Awhistleblower means any natural person who, in the context of current, former or prospective work, service, contracting or professional relations, reports information they had reasonable grounds to believe true at the time, concerning corruption, illicit gain, abuse of authority, waste of public funds, serious conflicts of interest, concealment or obstruction of inquiries into these matters.Retaliation means any direct or indirect act or omission arising from reporting or assisting it that causes or may cause unlawful professional, employment, financial, legal or social harm.
Article (2) — Objectives
This Law aims to establish a unified framework for preventing corruption before it occurs, managing conflicts of interest, increasing the reliability of asset disclosure, providing effective whistleblower protection and strengthening public confidence that public decisions serve the public rather than private interests.
The Law adopts proportionality: a private interest does not presume corruption but requires disclosure and management; an unsubstantiated report does not presume malicious reporting, and liability arises only upon proof of knowing falsity and intent to cause harm under this Law.
Article (3) — Scope of Application
This Law applies to federal bodies; governorates not incorporated into a region within federal competences; public and mixed companies and entities managing federal funds; and private persons and entities to the extent that they receive public funds, implement public contracts or exercise a statutory concession or public service.
The constitutional independence of the judiciary, Council of Representatives and independent bodies shall be respected. Disciplinary measures concerning their members shall follow constitutional procedures and the laws governing each authority, without exemption from disclosure duties, criminal provisions or whistleblower protection.
This Law shall not prejudice the Kurdistan Region's constitutional powers. The Commission shall coordinate with the Region's competent body on shared matters, while federal jurisdiction remains over federal offences, funds and bodies.
Article (4) — Principles of Public Integrity
Covered bodies shall observe legality, impartiality, primacy of the public interest, transparency, accountability, merit, equal treatment, protection of public funds, and non-exploitation of office, information or influence for private benefit.
This Law shall be interpreted to protect constitutional rights, the presumption of innocence, defence rights and privacy, while preventing secrecy or administrative immunity from obstructing lawful reporting or concealing conflicts of interest.
Article (5) — Relationship with Stricter Rules
This Law establishes minimum integrity standards and does not prevent special laws or professional rules from imposing stricter standards consistent with the Constitution and without diminishing whistleblower safeguards.
Where a general public-conduct rule conflicts with a specific provision of this Law on conflicts of interest, financial declarations or whistleblower protection, the specific provision herein shall prevail.
Article (6) — Integrity Risk Management
Each covered body shall, within its existing structure, periodically assess corruption and conflict-of-interest risks in its most exposed roles and operations, particularly procurement, contracts, licences, appointments, grants, asset management, oversight and inspection.
The body shall take preventive measures proportionate to risk. Assessments shall not expand employee surveillance beyond what law permits or collect personal data unrelated to the purpose.
Chapter 2 — Integrity and Public-Conduct Duties
Article (7) — Duty to Put the Public Interest First
Public employees shall perform their duties objectively and independently and refrain from using office, status, institutional resources or non-public information for private benefit to themselves or others.
Leadership officeholders shall exemplify compliance and take reasonable measures to prevent violations within their supervisory remit when they know, or ought to know given their responsibilities, of such violations.
Article (8) — Gifts, Hospitality and Benefits
Soliciting or accepting gifts, hospitality or benefits is prohibited where they could influence, or reasonably appear capable of influencing, independent public decision-making, or are offered by a person directly interested in a decision, contract or licence before the body.
Protocol courtesies or symbolic gifts that cannot be refused without official offence may be accepted, provided they are recorded and surrendered to the body if they exceed the threshold set by instructions. An aggregate register of senior officials' official gifts shall be published without information compromising security or privacy.
Article (9) — Outside Work and Activities
Public employees shall not undertake outside work or activity that obstructs their duties, creates a continuing conflict of interest or enables exploitation of official information or influence. Outside work in high-risk positions shall require prior approval under published rules.
Non-conflicting academic, scientific or professional activity shall not be prohibited in itself. Restrictions must be necessary and proportionate to the role.
Article (10) — Public Information and Resources
Confidential or unpublished information obtained through employment shall not be used for profit or advantage to the employee or others, nor unlawfully leaked. Reporting a violation covered by this Law to the competent body shall not constitute prohibited disclosure where protection conditions are met.
State funds, vehicles, equipment, digital accounts and working time shall serve public purposes under applicable laws and instructions and shall not be diverted to personal, party-political or electoral benefit except where expressly permitted by law.
Article (11) — Procurement, Contracts and Committees
Every member of a purchasing, evaluation, negotiation, award or acceptance committee, and anyone substantially participating in a contractual decision, shall submit a transaction-specific interests declaration before work begins and update it immediately upon any new interest arising.
Where a material actual or apparent conflict is identified, the person shall refrain from accessing confidential bids or participating in deliberations or voting. Reasons for recusal shall be recorded in the committee minutes without publishing unnecessary personal data.
Article (12) — Relatives and Nepotism
Employees shall not use their authority to appoint, promote or grant an employment privilege to a spouse or relative up to the second degree in a unit under their direct authority, nor participate in assessing or selecting a relative up to the fourth degree where they have material influence over the decision.
Kinship alone shall not prevent meritorious employment based on competition and merit if the authority holder's influence is removed from the entire decision process and this is documented.
Article (13) — Post-Employment Restrictions
For one year after leaving a high-risk office or position, its holder shall not represent a private person before the body over which they exercised direct decision-making authority in matters in which they personally participated. The period shall be two years for ministers, heads of independent bodies, deputy ministers and equivalent officials concerning contracts, licences or regulatory decisions in which they directly participated.
This shall not generally prevent return to professional practice or employment. The Commission may issue a binding opinion narrowing the restriction where full application is demonstrably unnecessary to prevent conflicts of interest.
Article (14) — Institutional Codes of Conduct
Covered bodies shall issue or update codes of conduct consistently with this Law, including practical examples concerning conflicts of interest, gifts, outside work, use of resources and safe reporting.
A code of conduct shall not create an offence or criminal penalty. Disciplinary violations shall be defined and open to challenge under law.
Chapter 3 — Conflicts of Interest and Their Management
Article (15) — Duty to Disclose Conflicts
Any employee or declarant facing an actual, potential or apparent conflict of interest shall disclose it in writing to the competent body immediately upon becoming aware and, where possible, before participating in the decision.
Disclosure shall identify the nature of the interest and its connection to the matter to the extent necessary to assess the conflict. Unrelated private data need not be disclosed.
Article (16) — Graduated Management Measures
Conflicts shall be managed through the least restrictive measures that effectively remove the risk, including disclosure, recusal from a specific decision, restricted information access, reassignment, independent oversight, divestment of a financial interest, cessation of outside activity or transfer where necessary.
An employee or declarant shall not be required to leave their job or office unless the conflict is substantial and continuing and cannot be managed through a lesser measure, subject to constitutional and legal procedures applicable to elected and judicial offices.
Article (17) — Recusal from a Decision
Recusal shall be written or recorded in official minutes and shall include non-participation in discussion, recommendation, voting or indirect influence. The administrative head or competent authority shall appoint a substitute where necessary to continue work.
Where recusal is impossible because of an unavoidable constitutional or legal necessity, the conflict shall be declared and the decision independently reviewed and documented before taking effect, except in emergencies, when subsequent review shall occur without delay.
Article (18) — Divestment and Asset-Management Arrangements
A declarant may address a continuing financial conflict by genuinely divesting the asset or interest or placing it under independent management in which they cannot direct investment or obtain detailed knowledge of management decisions while in office, under Commission instructions and applicable financial laws.
A sham transfer to a spouse, relative or declarant-controlled company shall not constitute divestment for this Article.
Article (19) — Interests Register
Every covered body shall establish a secure register of conflict-of-interest disclosures and management decisions and provide the Commission with periodic standardised case data without publishing confidential details.
For senior positions, information necessary for public accountability shall be published, including the type of interest and action taken, with addresses, account numbers, minors' data and protected security information redacted.
Article (20) — Decisions Tainted by an Unmanaged Conflict
Where a person knowingly participates in a decision despite a substantial undisclosed conflict of interest, the competent body may suspend implementation and have it reassessed impartially. The decision shall not be void by operation of law unless a competent court so determines or a special law provides otherwise.
Reconsideration shall not affect good-faith third parties' rights beyond what law permits.
Article (21) — Preventive Advice
An employee or declarant may seek advance confidential advice on a potential conflict from their body's integrity unit or the Commission. Following that advice in good faith shall indicate compliance unless the facts supplied were deliberately incomplete or have materially changed.
Article (22) — Prompt Disclosure of Changed Circumstances
A declarant shall update their interests disclosure within thirty days of any material change, and immediately where the change relates to a decision required before that period expires.
Chapter 4 — Asset Disclosure and Verification
Article (23) — Categories Required to Declare
Full financial declarations shall be required from the President of the Republic and deputies; the Speaker, Deputy Speakers and members of the Council of Representatives; the Prime Minister, deputies, ministers and equivalents; Federation Council members once constituted; the President of the Supreme Judicial Council, judges and members of Public Prosecution; the President and members of the Federal Supreme Court; heads of independent bodies and deputies; deputy ministers, holders of special and senior grades, directors-general and equivalents; governors, deputies, assistants and advisers, district and subdistrict heads; public university presidents and college deans; chairs and board members of public and mixed companies; investment-authority leadership; Commission of Integrity and Supreme Judicial Council investigators; and officers and security positions specified by instructions according to authority and risk.
By a reasoned decision based on risk or credible information, the Commission may require a public employee or public-service assignee not listed above to declare. The decision shall be challengeable and shall not be used on political or discriminatory grounds.
Article (24) — Declaration Deadlines
A declarant shall submit an initial declaration within ninety days of taking office or employment, an annual declaration during January each year, and a final declaration within ninety days of leaving the office or employment.
A person holding several covered positions simultaneously may submit a consolidated declaration covering all relevant interests.
Article (25) — Contents of the Full Financial Declaration
The standard declaration shall cover: real estate and rights in rem; accounts, deposits, investments and securities; company holdings and direct and indirect beneficial ownership; vehicles and high-value movable assets specified by instructions; material debts and liabilities; income sources; outside positions, work and board memberships; substantial gifts and benefits; digital assets with financial value; and any other interest necessary to identify conflicts or unexplained increases in wealth.
The Commission shall adopt reasonable standard thresholds for movable assets and gifts to avoid collecting negligible data of no oversight value, periodically updating those thresholds on an objective basis.
Article (26) — Spouse and Dependent Children's Data
To the extent necessary to verify conflicts of interest and illicit gain, declarations shall include material financial data of the spouse, minor children and persons financially dependent on the declarant, with strict confidentiality safeguards and no publication of their detailed data.
Where obtaining information about an independent adult is legally or practically impossible, the declarant shall record this and the reasons. No criminal liability shall arise for information outside their control unless collusion or deliberate concealment is established.
Article (27) — Electronic Submission and Proof
The Commission shall provide a secure electronic declaration platform with a paper alternative where digital access is unavailable. Declarants shall receive a dated acknowledgement and reference number. A declaration shall be deemed submitted only when it contains the minimum required particulars or the Commission accepts it subject to completion.
Article (28) — Risk-Based Verification
The Commission shall check all declarations electronically and administratively for completeness, subjecting a proportion to detailed verification under risk criteria whose substance is published, including seniority, financial authority, unusual wealth changes, inconsistent data, credible reports and risk sectors.
Selection for detailed audit shall not be based on political affiliation, opinion, ethnicity, religion, sex or any discriminatory ground.
Article (29) — Verification and Interagency Cooperation
Under law and to the extent necessary for verification, the Commission may request data from real-estate registration, traffic, tax, customs, companies, banks, oversight bodies and relevant registers, observing any legally required judicial orders for banking, communications or other protected data.
Every access to or query concerning a declaration shall be electronically logged to permit subsequent audit and prevent unlawful use.
Article (30) — Public Statements of Senior Officials' Interests
The Commission shall publish statements of interests for the President and deputies, the Council of Representatives' leadership and members, the Prime Minister and deputies, ministers, heads of independent bodies, governors and other senior officials specified by instructions. Statements shall be limited to asset and interest types, fields and appropriate aggregate value bands, outside work, company memberships and substantial gifts, excluding addresses, account numbers, minors' details and information threatening personal safety.
Publication shall enable scrutiny of potential interests and material changes without exposing a person's entire private financial life.
Article (31) — Confidentiality of the Full Declaration
Full financial declarations, attachments and verification documents shall be confidential, accessible only to authorised employees and judicial or oversight bodies permitted by law. They shall not be used for tax, political or commercial purposes unrelated to combating corruption unless another law independently authorises data exchange.
Article (32) — Clarification and Correction
Where the Commission finds an omission, inconsistency or increase requiring clarification, it shall notify the declarant in writing and allow an appropriate period not exceeding sixty days to respond or correct, unless urgent judicial necessity or a serious risk of evidence destruction exists.
Voluntary correction of non-material information before investigative proceedings begin shall not, by itself, establish intent to conceal.
Article (33) — Referral Concerning Illicit Gain
Where verification yields credible evidence of a substantial increase inconsistent with lawful resources or of a corruption offence, the Commission shall refer the file to the competent investigating judge under the Commission of Integrity and Illicit Gain Law and Criminal Procedure Code.
Financial declarations shall not shift the burden of proof in criminal proceedings contrary to constitutional safeguards. Conviction remains subject to legally prescribed evidence and standards, without prejudice to operative illicit-gain provisions until expressly amended.
Article (34) — Failure to Submit a Declaration
If a declaration is late, the declarant shall receive a final demand allowing thirty days. Thereafter, non-essential allowances or office-related privileges may be suspended by reasoned decision until compliance, subject to constitutional rules for elected and judicial positions.
Suspension shall not affect the basic pension earned through prior service, deprive the family of its rights, or preclude disciplinary or criminal liability where deliberate refusal or concealment under Article (55) is established.
Chapter 5 — Reporting and Whistleblower Protection
Article (35) — Protected Persons
Protection covers employees, contract workers, trainees, volunteers, former workers, job applicants, contractors, suppliers, contractors' workers, board members, professionals and anyone obtaining information in a professional, employment or contractual context connected with public funds or public service.
Protection extends to those assisting the whistleblower and to their spouse, family, colleagues or associated companies where retaliation occurs because of their connection to the report.
Article (36) — Conditions for Protection
A whistleblower qualifies for protection if, at the time of reporting, they had reasonable grounds to believe the information true and within this Law's scope, even if inquiries do not substantiate the violation.
Whistleblowers need not prove an offence or classify it legally and shall not lose protection for a good-faith factual assessment error. Protection excludes persons proven to have fabricated information they knew false with intent to cause harm.
Article (37) — Internal Reporting Channels
Covered bodies shall establish confidential reporting channels relatively independent of ordinary administrative hierarchies. Smaller bodies may share channels if confidentiality and independence are ensured. The channel's manager must not be someone who could be the subject of the report.
A whistleblower need not use internal channels before approaching the Commission, Public Prosecution or the competent oversight body.
Article (38) — External Reporting Channels
The Commission shall receive reports directly in person, by email, secure platform, hotline and other approved means, with referral to Public Prosecution, the Federal Board of Supreme Audit or sectoral oversight authorities according to competence.
This Article shall operate consistently with applicable instructions on receiving information and reports concerning corruption and illicit gain, supplemented by this Law's protections.
Article (39) — Anonymous and Pseudonymous Reporting
Anonymous or pseudonymous reports may be received and investigated where they contain verifiable information. They shall not be rejected solely because identity is undisclosed.
If an anonymous whistleblower later reveals their identity to the competent body, protection shall cover earlier and later retaliation where Article (36)'s conditions are met.
Article (40) — Acknowledgement and Follow-Up
Where identity and contact details are known, the whistleblower shall receive acknowledgement within seven days and appropriate follow-up information, or reasons why it cannot be provided, within ninety days. For complex cases, the period may extend to one hundred and eighty days with notification.
The right to follow-up shall not require disclosure of investigative secrets, compromise subjects' rights or reveal information liable to obstruct judicial proceedings.
Article (41) — Confidentiality of Identity
The whistleblower's identity and any identifying information shall be confidential, disclosed only with consent or by order of a competent judicial authority where necessary for defence rights or judicial proceedings and no less intrusive alternative exists.
Before judicial disclosure, the whistleblower shall be notified where this does not threaten the investigation or safety. Addresses, contact details and other information unnecessary to the defence may be withheld.
Article (42) — Prohibition of Retaliation
Dismissal, suspension, demotion, denial of promotion, punitive transfer, intimidation, harassment, threats, blacklisting, termination of a contract or tender, withholding entitlements, malicious litigation or any adverse action because of reporting or assistance with it is prohibited.
Contractual terms preventing reporting to competent bodies or prospectively waiving protection shall be void to that extent.
Article (43) — Interim Measures and Burden of Proof
Depending on the legal relationship, a whistleblower may ask the Administrative Court, Labour Court or competent judicial authority temporarily to suspend retaliation and restore the previous position pending determination, upon presenting serious indications connecting the action to the report.
Where the whistleblower establishes a protected report followed by adverse action in circumstances suggesting a connection, the body or employer shall explain the legitimate reasons independent of the report that caused the action, without prejudice to the court's assessment of evidence.
Article (44) — Remedies
An affected whistleblower shall be entitled, as appropriate, to annulment of retaliation, reinstatement to employment or contract, correction of employment records, compensation for material and moral harm, lost income and litigation costs, and any appropriate measure removing retaliation's effects.
Compensation shall not preclude disciplinary or criminal liability for threats, coercion, violence or unlawful identity disclosure.
Article (45) — Security and Judicial Protection
Where risk assessment indicates a threat to life or physical safety, the Commission shall immediately coordinate with the judiciary and Ministry of Interior to apply measures under the Protection of Witnesses, Experts, Informants and Victims Law No. (58) of 2017 and its implementing regulations and instructions.
Employment or administrative protection under this Law does not require criminal proceedings to have begun or the conditions for specialised security protection under Law No. (58) of 2017 to be met.
Article (46) — Protected Public Disclosure
A whistleblower shall be protected upon public disclosure if an internal or external report received no appropriate follow-up within reasonable periods, or if there are reasonable grounds to believe in an imminent or serious public-interest danger, risk of evidence destruction, possible collusion by the competent body or retaliation rendering ordinary reporting unsafe.
This Article does not permit publication of security-classified information or sensitive personal data beyond necessity. The court shall assess proportionality between the public interest and potential harm.
Article (47) — Support and Assistance
The Commission shall provide free, clear information on reporting channels and protection rights and may refer whistleblowers, where necessary, to legal, psychological or social assistance available through State institutions and accredited organisations.
A support fund or programme may be established through a separate legislative or budgetary decision if experience demonstrates need. This Law creates no open-ended financial obligations without an identified funding source.
Article (48) — Malicious Reporting
A whistleblower shall not incur criminal or disciplinary liability merely because a report is unsubstantiated. Liability arises only upon proof that a material allegation was knowingly false and made to harm a particular person.
Application shall ensure that malicious-report proceedings are not used to silence whistleblowers or expose their identities before investigation of the underlying report is completed.
Article (49) — Records Retention and Data Protection
Report records shall be kept securely, separating identity from file contents where possible, defining and electronically logging access rights, and destroying unnecessary data after statutory retention periods expire.
Data-protection, privacy and professional-confidentiality rules shall be observed. Personal copies of reports outside approved institutional systems are prohibited.
Chapter 6 — Powers, Oversight and Sanctions
Article (50) — Powers of the Federal Commission of Integrity
The Commission shall administer the federal financial-declaration system and interests register, establish disclosure forms, conduct risk-based verification, receive external reports, monitor compliance with conflict-of-interest and whistleblower-protection provisions, and issue guidance and instructions within this Law.
The Commission shall not replace the judiciary, Public Prosecution, Federal Board of Supreme Audit or sectoral oversight bodies. Its investigators shall conduct criminal investigations under an investigating judge's supervision and applicable laws.
Article (51) — Institutional Integrity Officer
Each covered body shall designate an employee or existing unit to coordinate conflict disclosures, reporting channels and awareness. No new administrative formation is required unless necessary and legally authorised.
The integrity officer shall have sufficient functional independence in handling reports and shall not receive instructions from a person who is their subject.
Article (52) — Oversight Coordination
The Commission, Federal Board of Supreme Audit, Public Prosecution and sectoral oversight mechanisms shall establish protocols for referrals and data exchange within their competences, preventing duplication and protecting whistleblower confidentiality.
The Federal Board of Supreme Audit shall audit declarations of the Commission's chair, two deputies, senior officials and legally designated staff, ensuring that the Commission does not exclusively audit its own leadership's assets.
Article (53) — Parliamentary Oversight and Annual Report
The Commission shall submit a public annual implementation report to the Council of Representatives, covering declaration submission rates, conflict-of-interest cases and their management, report numbers and processing stages, and retaliation complaints and outcomes, without disclosing identities or confidential investigative data.
Under the Constitution, the Council of Representatives may summon the Commission's chair to discuss compliance indicators without intervening in an individual case before the courts.
Article (54) — Disciplinary and Administrative Sanctions
Without prejudice to harsher penalties, disciplinary violations include failure to disclose a known conflict; participating despite a recusal duty; accepting a prohibited benefit; failing after warning to establish a required reporting channel; obstructing protection; or unjustifiably failing to declare after the final deadline.
Sanctions shall increase according to seriousness, harm, intent and recurrence, from notice, warning and exclusion from a specific task to disciplinary penalties under special laws. A member of a constitutional authority shall be penalised only under the applicable constitutional system and governing law.
Article (55) — Offences Connected with the System
First: Deliberate disclosure without legal basis of a protected whistleblower's identity or full financial-declaration data, with intent to harm or knowledge of likely serious harm, shall be punishable by detention for up to three years unless a more serious offence is constituted.
Second: Threatening, coercing or committing serious material retaliation against a whistleblower or witness because of protected reporting shall be punishable by detention for up to three years, without prejudice to harsher penalties for violence, threats or the underlying offence.
Third: Deliberately concealing a material asset or interest or making a materially false financial declaration to conceal a serious conflict of interest or illicit gain shall be punishable by detention for between one and three years.
Fourth: Deliberately reporting a fabricated allegation known to be false with intent to harm shall be punishable by detention for up to one year. Error, insufficient evidence or closure of the report shall not constitute the offence.
Fifth: In addition to punishment, the court may order restitution of benefits obtained through a conflict-of-interest violation and compensation under law, without prejudice to corruption-asset recovery proceedings.
Article (56) — Administrative Review and Judicial Appeal
A conflict-management decision, refusal of whistleblower protection or declaration-related administrative measure may be challenged administratively within thirty days of notification and subsequently before the administrative judiciary or competent court according to the decision's nature.
An appeal shall not suspend interim whistleblower protection except by a reasoned judicial decision.
Article (57) — Compliance Indicators
The Commission shall establish a limited set of indicators covering timely declarations, conflict-case processing time, reporting response time, established retaliation cases and rates of resolving institutional risks. Indicators shall not become incentives for superficial closure of reports or unjustified increases in penalties.
Chapter 7 — Transitional Provisions, Alignment and Commencement
Article (58) — Implementing Instructions
After consulting the Supreme Judicial Council, Federal Board of Supreme Audit and relevant bodies, the Commission shall issue implementing instructions within one hundred and eighty days of publication, particularly on declaration forms, high-risk position classifications, gift management, declaration auditing, reporting channels and retaliation-assessment criteria.
Draft instructions of general effect shall be published for comment for an appropriate period before issue unless urgent necessity justifies otherwise.
Article (59) — Digital System
Within one year of commencement, the Commission shall develop a unified digital system for declarations, the interests register and reports, with permission and access audit logs and lawful connectivity to government registers.
Existing methods shall continue until the new system operates. Delayed digital transformation shall not invalidate a properly submitted declaration or report.
Article (60) — Transition for Existing Declarations
Any asset declaration submitted under the Commission of Integrity and Illicit Gain Law before commencement shall remain valid to the end of its annual cycle. The next declaration shall use the new form at the subsequent annual deadline.
Senior officials subject to public statements of interests shall submit their first statement within one hundred and twenty days of the approved form taking effect.
Article (61) — Alignment with the Commission of Integrity and Illicit Gain Law
First: Upon commencement, this Law's financial-declaration, conflict-of-interest and whistleblower-protection provisions shall apply as the newer special provisions. References to declarants, declarations and conflicts in the Commission of Integrity and Illicit Gain Law No. (30) of 2011, as amended, shall be read consistently with them.
Second: Illicit-gain, investigation and recovery provisions in Law No. (30) of 2011, as amended, shall remain effective. This Law shall not repeal an offence or reduce an existing penalty without an express provision.
Third: Within one year, the Council of Ministers and Commission of Integrity shall prepare a legislative revision bill removing duplication between Articles (16–20) of Law No. (30) of 2011, as amended, and this Law, without creating gaps in criminalisation of illicit gain or investigative powers.
Article (62) — Alignment with the Witness Protection Law
Administrative and employment protection under this Law is independent of security protection under Law No. (58) of 2017. When a corruption report becomes a criminal case and a risk within that Law arises, the Commission and judiciary shall enable the whistleblower to request its protective measures.
Article (63) — Repeal of Conflicting Provisions
Lower-ranking regulatory rules inconsistent with this Law shall be repealed or amended from the commencement of the new instructions. Existing rules shall continue insofar as consistent until replaced.
Article (64) — Commencement
This Law shall enter into force ninety days after publication in the Official Gazette. Provisions requiring a new form or platform shall commence according to the transitional deadlines specified herein.
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.
Alignment with Existing Legislation
| Legislation or Framework | Relationship | Treatment |
|---|---|---|
| Commission of Integrity and Illicit Gain Law No. (30) of 2011, as amended | Covers financial declarations, illicit gain and conflicts of interest. | Remains the foundation for the Commission, investigations and illicit gain, while this Law provides the newer substantive rules on declarations, interests and protection; legislative revision to remove duplication is required within one year. |
| Witness Protection Law No. (58) of 2017 | Security and judicial protection in covered proceedings. | Complementarity, not replacement: employment protection starts earlier; security protection falls under the special Law where danger exists. |
| Instructions No. (1) of 2026 on Reports | Regulate reporting sources and procedures within the Commission of Integrity. | Continue insofar as compatible, supplemented by confidentiality, anti-retaliation and follow-up rules. |
| Employee disciplinary rules and codes of conduct | General duties and discipline. | Remain effective, with this Law providing special rules on interests, gifts and reporting. |
| Laws governing the judiciary, Parliament and independent bodies | Institutional independence and special procedures. | Apply integrity duties while respecting each authority's constitutional accountability procedures. |
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
| Reference | Principle | Reflection in the bill |
|---|---|---|
| United Nations Convention against Corruption | Employee 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 Integrity | Graduated conflict management, practical guidance and a risk-based approach. | Recusal, reassignment, divestment, preventive advice and risk-directed auditing. |
| European Directive 2019/1937 | Internal 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
- Iraqi Constitution — Iraqi Council of Representatives
Iraqi Constitution and legislation
Iraqi Constitution — Council of Representatives - 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 - 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 - 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 - 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/ - 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/ - 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/ - 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 - Ministry of Planning: Implementation of the National Integrity and Anti-Corruption Strategy 2025–2030
Iraqi government bodies
https://mop.gov.iq/archives/36397 - 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 - United Nations Convention against Corruption – official text
International treaties and conventions
https://www.un.org/en/ethics/assets/pdfs/UN_Convention_Against_Corruption.pdf - 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 - 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