Advance Customs Declaration Under Cabinet Decision 569: Exclusive Prerequisite for Foreign Exchange

1. Key takeaways

Cabinet Decision No. 569 (2025), in force from 2025-12-01, establishes the advance customs declaration as the exclusive mandatory prerequisite for outward foreign exchange transfers for imports: before receiving an advance declaration issued through ASYCUDA, bearing a QR code and verified through the Ur platform, together with its attached documents, a bank must not process the outward remittance. Banks must enter the declaration number into the SWIFT message in place of other data; once the outward remittance is completed, the content of the declaration must not be modified; and where goods have still not arrived more than 6 months after remittance, the General Customs Authority must notify the bank and report to the Central Bank of Iraq. GRZAN’s judgement: this moves the main battlefield of Iraqi import compliance from the clearance stage to the remittance stage — without a complete document set, the money cannot go out first.

• The advance customs declaration is the exclusive prerequisite for outward foreign exchange for imports, effective 2025-12-01.
• Banks must not remit before receiving the ASYCUDA-issued, QR-coded, Ur-verified declaration with attachments.
• The declaration number replaces other data in the SWIFT message; after remittance the declaration content is locked.
• Goods not arrived within 6 months of remittance trigger notification to the bank and a report to the Central Bank of Iraq.

2. Legal basis

The instruments below carry the decision and its forwarding chain.

Source level: primary, verified — the official PDF, a 3-page scanned document with OCR applied. The subject is regulating and facilitating import procedures, protecting non-oil revenues and facilitating duty collection.

Summary of the decision’s points. (1) The advance customs declaration is designated the exclusive mandatory prerequisite for outward foreign exchange for imports. (2) The importer must submit to the bank an advance declaration issued through ASYCUDA, bearing a QR code and verified through the Ur platform, stating the declaration number; the commercial contract or final invoice including total value, HS code and quantity, used once only; exporter; importer; country of origin; country of shipment; bank name and code; importer company code; border crossing; chassis number; and customs broker. (3) A bank must not process outward remittance before receiving the advance declaration and its attachments. (4) Banks must enter the advance declaration number in the SWIFT message in place of other data. (5) Where goods have not arrived more than 6 months after remittance, the General Customs Authority must notify the bank and report to the Central Bank of Iraq, copying the central bank’s banking supervision department for review. (6) After the declaration is issued, the bank number and name may not be modified. (7) Once outward remittance is completed, the content of the declaration may not be modified. (8) Customs centre duties: complete procedures and verify the conformity of the goods with the advance declaration; collect duties and protect domestic products. (9) Where applicable, the Customs Law, Customs Tariff Law, Trade Law, Central Bank of Iraq Law, Banking Law and anti-money-laundering and counter-terrorism financing law apply. (10) Earlier decisions and circulars in conflict cease to apply. (11) In force from 1 December 2025.

3. Expert insights

The main battlefield of compliance has moved from the customs desk to the payment desk. Point 3 writes the rule that banks must not remit into explicit text. The old sequence — book shipping, prepare documents, complete the file at the port — is forced into preparing documents first, the bank releasing payment second and shipping third. GRZAN has already moved document preparation forward in client project schedules, from pre-shipment to immediately after contract effectiveness.

Remittance locks the declaration — the most easily underestimated point. Point 7 locks the declaration content once outward remittance is completed. Many companies read the advance declaration as a forecast for customs; that is wrong — it is fixed at the moment the foreign exchange leaves. The HS code, origin, shipment country, border crossing and importer company code of point 2 leave no remediation window after payment for any wrongly filled field. Read together with article 30 (HS classification) and article 34 (duty modelling), one classification error here amplifies simultaneously into a wrong rate, wrong documents and no possibility of correction.

Non-arrival within 6 months triggers central bank review — foreign exchange control and physical import are bound together. Point 5 is not an isolated customs clause; it wires bank, customs and central bank into one line: the money has gone out, the goods have not come in, and the central bank will know. For device orders with long delivery cycles and split shipments, this point requires active management of the gap between remittance and arrival rather than treating it as a logistics issue.

The officially listed set of six laws shows this is not a customs-only matter. Point 9 names side by side the Customs Law, the Customs Tariff Law, the Trade Law, the Central Bank of Iraq Law, the Banking Law and the anti-money-laundering and counter-terrorism financing law. The value of the list is that a company’s customs, finance and legal functions must align simultaneously, and leaving the matter to the broker alone is insufficient.

Read with article 36, this decision is the first segment of a closed loop. This decision governs documents and remittance (from 2025-12-01); the decision in article 36 governs duty prepayment (from 2026-10-01); and the customs conformity check between goods and declaration in point 8 closes the loop. All three share the ASYCUDA plus banking channel. Separately three administrative requirements; together one mechanism locking foreign exchange outflow, tax collection and physical entry to each other.

4. Practical recommendations

• Build the thirteen fields of the advance declaration into a fixed template and complete it when signing the contract with the Iraqi buyer, not at booking. Practical estimate: the field list comes from point 2 of the decision; the filling order is an internal work arrangement (no official provision found).
• Complete a written classification confirmation of the HS code before remittance, kept consistent with the classification method of article 30 and the duty modelling of article 34.
• Maintain a remittance-to-arrival ledger and issue an early warning for batches not arrived after 3 months, avoiding the 6-month red line of point 5. Practical estimate: the 3-month warning line is an internal GRZAN setting (no official provision found).
• Confirm with the issuing bank in advance whether it accepts the advance declaration as the sole remittance basis and how the SWIFT fields are to be filled. Practical estimate: implementation details differ between banks and no unified official provision was seen.
• For split-shipment orders, state the correspondence between partial shipments and partial remittances in the commercial contract, avoiding document-to-goods mismatches that trigger the conformity check of point 8.

5. Verification checklist

• □ Download the official PDF of Decision 569 and re-check the effective date 1 December 2025 in Article 11.
• □ Check points 1 to 10 one by one, focusing on point 3 (no remittance before documents) and point 7 (no modification after remittance).
• □ Confirm with the issuing bank the SWIFT filling format of the advance declaration number (point 4).
• □ Re-check the order in which the six laws are listed in point 9 of the decision text.
• □ Check that the forwarding chain of letter 4147/6 (2025-11-20) and letter 7141 (2025-08-11) is consistent.
• □ Cross-check with articles 30 (HS classification), 34 (duty modelling) and 36 (prepayment loop) that the positions for the same consignment are consistent.
• □ Re-check whether the official documents cited here have been replaced by later instructions or decisions (verification baseline date: 29 October 2026).

Regulatory information verified as of 29 October 2026.

How GRZAN can help. GRZAN provides medical device and IVD registration, quality system, authorised representative and local testing support for the Iraqi market. Our team coordinates local importer arrangements, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com