Strategic Review

Regulatory Affairs

Zain Group operates within a complex and rapidly evolving regulatory environment shaped by cross-sector‭, ‬sector-specific‭, ‬and extraterritorial legislation‭. ‬The company also navigates national licensing regimes and policy frameworks that govern the development of telecommunications infrastructure‭, ‬delivery of digital services‭, ‬customer protection‭, ‬pricing structures‭, ‬data governance‭, ‬and the secure handling of information across consumer‭, ‬enterprise‭, ‬and government segments‭. ‬As Zain’s footprint continues to expand beyond traditional telecommunications into broader ICT and digital ecosystems‭, ‬regulatory engagement and compliance remain central to safeguarding operational continuity‭, ‬investment sustainability‭, ‬and long-term value creation‭. ‬

In 2025‭, ‬the telecommunications and digital services landscape accelerated their transformation‭, ‬driven by the convergence of 5G‭ ‬expansion‭, ‬cloud adoption‭, ‬artificial intelligence‭, ‬IoT‭, ‬fintech‭, ‬and data-driven business models‭. ‬Regulators across Zain’s markets intensified their focus on spectrum optimization‭, ‬infrastructure sharing‭, ‬competition dynamics‭, ‬customer protection‭, ‬cybersecurity‭, ‬and data privacy‭, ‬while simultaneously recalibrating regulatory frameworks to support national digital transformation agendas‭. ‬Against this backdrop‭, ‬Zain maintained a proactive regulatory posture—balancing compliance with strategic advocacy—to enable innovation while mitigating regulatory risk‭. ‬

Spectrum and technical regulation developments remained a defining theme in 2025‭. ‬Across multiple markets‭, ‬Zain advanced spectrum acquisition‭, ‬renewal‭, ‬and optimization initiatives‭, ‬supported regulatory consultations‭, ‬and engaged authorities on auction design‭, ‬pricing‭, ‬licence duration‭, ‬and technology neutrality‭. ‬Notable progress included new spectrum awards‭, ‬extensions linked to rollout obligations‭, ‬successful advocacy to defer or recalibrate auction timelines‭, ‬and constructive engagement on quality-of-service frameworks to ensure alignment with international benchmarks and sustainable investment models‭. ‬These efforts strengthened‭ ‬Zain’s readiness for advanced 5G and future network evolution while preserving capital efficiency‭. ‬

Infrastructure regulation and deployment also featured prominently during the year‭. ‬Zain continued to engage regulators on passive and active infrastructure sharing‭, ‬fiber rollout‭, ‬tower regulation‭, ‬international gateways‭, ‬and fixed network frameworks‭. ‬Through sustained engagement‭, ‬Zain progressed site deployments‭, ‬resolved legacy regulatory constraints‭, ‬influenced the timing and structure of new infrastructure regulations‭, ‬and advanced cross-border connectivity initiatives‭. ‬These efforts supported network‭ ‬resilience‭, ‬rural connectivity‭, ‬and long-term digital-infrastructure development across Zain’s operating markets‭. ‬

In parallel‭, ‬regulatory developments in taxation‭, ‬levies‭, ‬and competition required focused intervention‭. ‬Zain actively challenged disproportionate regulatory fees‭, ‬secured favorable judicial outcomes‭, ‬progressed royalty fee reform discussions‭, ‬and advocated for balanced competition frameworks to safeguard market sustainability‭. ‬The Group also remained engaged on mobile number portability‭, ‬wholesale regulation‭, ‬national roaming‭, ‬and market review processes‭, ‬ensuring regulatory remedies remained proportionate‭ ‬and investment friendly‭. ‬

Customer affairs‭, ‬data protection‭, ‬and cybersecurity commanded heightened regulatory attention in 2025‭. ‬Zain sustained compliance with evolving SIM registration‭, ‬e-KYC‭, ‬customer protection‭, ‬and personal data protection requirements while adapting operational processes to new national frameworks and enforcement expectations‭. ‬In parallel‭, ‬cybersecurity governance matured further as national cybersecurity frameworks‭, ‬licensing regimes‭, ‬and security controls were introduced or enhanced across key markets‭, ‬reinforcing Zain’s commitment to safeguarding customer trust and network integrity‭. ‬

Aligned with Zain Group’s strategic evolution under the‭ ‬‘4WARD‭ ‬–‭ ‬Progress with Purpose’‭ ‬strategy‭, ‬regulatory oversight now extends across an increasingly diverse portfolio spanning traditional telecom services‭, ‬5G‭, ‬cloud‭, ‬IoT‭, ‬fintech‭, ‬digital platforms‭, ‬and emerging technologies‭. ‬Zain engages regulators through structured consultations‭, ‬industry forums‭, ‬targeted lobbying‭, ‬and collaborative policy development—positioning‭ ‬
the Group as a constructive partner in shaping forward-looking‭ ‬
regulatory ecosystems‭.‬

The Group Regulatory team held their 6th‭ ‬Annual Forum‭ (‬20-22‭ ‬January 2025‭) ‬in Kuwait bringing together Regulatory executives and professionals from Zain Group‭, ‬OPCOs‭, ‬ZainTECH‭, ‬Dizlee and Omantel‭, ‬as well as key personnel from most cross-functional teams at the Group‭. ‬​

The forum featured keynote presentations from internal and external speakers commencing with a showcase on Zain’s new‭ ‬‘4WARD’‭ ‬strategy‭, ‬followed by presentations on Sustainability with a focus on applying integrated thinking concepts‭, ‬Low Earth Orbit satellite technologies‭, ‬a masterclass on digital infrastructure‭, ‬regulatory compliance implementation and outcomes for Zain OPCOS‭,‬‭ ‬regulatory community building initiatives and a panel discussion on regulatory challenges with value-added services and more‭.‬​

All operating companies also provided detailed presentations and insights into regulatory successes‭, ‬challenges‭, ‬and priorities‭.‬​

The three-day event facilitated collaboration‭, ‬engagement‭, ‬and team building among community members and cross-functional counterparts‭, ‬providing an opportunity to share knowledge‭, ‬discuss challenges‭, ‬and align on common approaches‭!‬

Regulatory Compliance Program - RCP

Zain has advanced substantially in embedding regulatory compliance across the organization‭, ‬reinforcing our commitment to robust‭ ‬governance and exceptional regulatory standards‭. ‬We launched RCP‭ (‬Regulatory Compliance Program‭) ‬in 2022‭ ‬and has made market leading advancements‭, ‬including getting ISO 37301‭ ‬certification for 2‭ ‬OpCos‭, ‬i.e‭. ‬Kuwait and Bahrain‭. ‬

RCP has now been successfully implemented in Zain Bahrain‭, ‬Zain Kuwait‭, ‬Zain Sudan‭, ‬Zain Jordan‭, ‬Zain South Sudan and Zain Iraq‭ ‬and all 6‭ ‬OpCos are now in Sustenance Phase‭. ‬As part of the Sustenance Phase‭, ‬key activities covered include updates to the Compliance Universe with new issuances‭/ ‬amendments issued by Authorities‭, ‬enhanced monitoring of regulatory developments‭ (‬such as change in compliance owners‭, ‬potential fines‭/ ‬penalties‭, ‬new products launched etc‭.), ‬compliance gap assessments‭, ‬and ISO 37301‭ ‬certification aligned with global standards which will bolster investor confidence‭.‬

Furthermore‭, ‬the new RCP Portal was launched in 2025‭. ‬The new RCP Portal equips our OpCos with it’s enhanced user interface including key functionalities such as centralized repository‭, ‬documentation databases‭, ‬role clarity‭, ‬automated reminders‭, ‬management dashboards‭, ‬and digitized workflows‭. ‬

In 2026‭, ‬RCP will be rolled out in Zain KSA and ZainTECH‭. ‬Compliance obligations have been identified in Zain KSA and ZainTECH in the ongoing phase‭. ‬Post RCP roll out for Zain KSA and ZainTECH, ‬Sustenance Phase will commence for these entities‭. ‬Further‭, ‬Zain Jordan and Zain Iraq will proceed for ISO 37301‭ ‬certification‭. ‬

We will continue ensuring compliance excellence remains integral to our operations‭.‬

RCP Sustenance

Monthly updates to Compliance Universe

Monthly monitoring of key regulatory development

Monthly OpCo Regulatory Compliance Report issued

Compliance Status Assessment

ISO 37301‭ ‬certification for Zain Kuwait and Zain Bahrain

RCP under implementation​

Compliance obligation ‭ ‬identification​

Stakeholder mapping

RCP in 2026

RCP Sustenance for ZainTECH and Zain KSA

ISO 37301 certification for Zain Jordan and Zain Iraq

RCP in 2025

ISO 37301 Certification Maintenance​ Sustaining ISO 37301 Certification highlights commitment to global compliance and continuous improvement.

ISO 37301 certification for Zain Kuwait and Zain Bahrain​

Excellence Across Operations

Since its launch in 2022‭, ‬Zain’s Regulatory Compliance Program‭ (‬RCP‭) ‬has set a benchmark for governance and compliance excellence across the organization‭. ‬Our‭ ‬achievements underscore Zain’s unwavering commitment to robust regulatory standards and investor confidence‭.‬

Key Milestones Achieved

ISO 37301‭ ‬Certification‭: ‬Successfully obtained for Zain Kuwait and Zain Bahrain‭, ‬reinforcing adherence to global compliance standards‭.‬

RCP Implementation

Completed across 6‭ ‬OpCos‭ ‬–‭ ‬Zain Bahrain‭, ‬Zain Kuwait‭, ‬Zain Sudan‭, ‬
Zain Jordan‭, ‬Zain South Sudan‭, ‬and Zain Iraq‭. ‬All are now in the Sustenance Phase‭.‬

Regulatory Community Developments

Regulatory Leadership Council​

In 2025‭, ‬the Regulatory Leadership Council‭ (‬RLC‭) ‬strengthened Group-wide regulatory alignment by advancing key initiatives including the unified Data Privacy Framework‭, ‬the rollout of the V-Comply compliance platform‭, ‬and the development of the Regulatory‭ ‬Academy‭. ‬The Council also coordinated Zain’s regional position on emerging areas such as satellite and D2D regulation‭, ‬reinforcing Zain’s role as a proactive leader in shaping future regulatory frameworks‭.‬​

VAS Working Group

Introduced a unified OpCo reporting template and completed a cross-market regulatory scan across our operating markets‭; ‬it prioritized fraud mitigation‭, ‬billing transparency‭, ‬and licensing consistency‭, ‬and agreed next steps including knowledge-sharing on KSA self-regulation and evaluating a WASPA-style self-regulatory model with regulators‭.‬

Data Privacy Working Group

Zain Group established the Data Privacy Working Group to drive alignment on data protection across all OpCos. Through collaborative sessions, the group developed and finalized the Personal Data Privacy Policy and Privacy Notice, both of which were approved by the Group Board. This initiative laid the foundation for the upcoming Group Data Privacy Framework, reinforcing Zain’s commitment to responsible data governance.

AI Working Group

The AI Working Group advanced Zain’s leadership in responsible AI by mapping regional regulations, aligning OpCo compliance practices, and launching a unified AI regulatory template across all markets. The group’s work strengthens Zain’s readiness for emerging AI policies and supports safe, efficient adoption of AI technologies.

Spectrum & Technical Regulations

New Spectrum Acquisition & Auctions

Kuwait

A testing request has been formally submitted to CITRA covering the following spectrum bands‭:‬

  • Band N77‭ (‬100‭ ‬MHz‭)‬
  • Band N258‭ (‬26‭ ‬GHz‭, ‬1‭ ‬GHz bandwidth‭)‬

Saudi Arabia

Zain KSA brought forward its 600‭ ‬MHz rollout commitments and effectively engaged with CST to secure a suspension of the cost-intensive 2022‭ ‬QoS framework‭, ‬thereby positioning itself as a leader in technical and regulatory reform‭.‬

Sudan

Zain strengthened its spectrum strategy by acquiring 2×10‭ ‬MHz in the 700‭ ‬MHz band‭, ‬subject to TPRA’s confirmation‭, ‬to enhance LTEquality of service and drive revenue growth‭.‬​

The acquisition will be paid through three equal annual installments totaling USD 19.5‭ ‬million‭.‬​

Iraq

Zain secured access to 75MHz in the 2.6GHz band in 11‭ ‬governorates for an overall price of USD 34.6‭ ‬million‭. (‬Baghdad 75‭ ‬MHz‭, ‬Basrah 75‭ ‬MHz‭, ‬Karbala 75‭ ‬MHz‭, ‬Najaf 75‭ ‬MHz‭, ‬Anbar 40‭ ‬MHz‭, ‬Babil 40‭ ‬MHz‭, ‬AlQadisya 40‭ ‬MHz‭, ‬Muthanna‭ ‬40‭ ‬MHz‭, ‬ThiQar 40‭ ‬MHz‭, ‬Missan‭ ‬40‭ ‬MHz‭, ‬Ninawa 40‭ ‬MHz‭).‬

Zain was granted an additional 20‭ ‬MHz in the 2.1‭ ‬GHz band to enhance spectrum capacity in 15‭ ‬governorates on a renewable basis​

Technical Regulations

Jordan

Settlement Agreement with the government

  • Zain fulfilled all obligations under the Agreement through the installation and operation of 180 sites and the payment of the third installment amounting to JOD 6.1 million, thereby securing a five-year extension of its spectrum licenses. ​
  • The Company advanced its 5G rollout obligations under the same agreement, achieving 36% population coverage, with 1,068 new sites brought on air and 233 neighborhoods fully covered.
  • Quality of service (QoS):The TRC issued draft Quality of Service instructions that impose KPIs and rollout obligations more stringent than prevailing international benchmarks​

Iraq

900‭ ‬MHz‭ / ‬2100‭ ‬MHz interference‭: ‬A joint declaration signed by GSMA‭, ‬MSI‭, ‬Nokia and Huawei was submitted to CMC‭, ‬highlighting urgent interference concerns and the need for immediate spectrum allocation to enhance QoS‭.‬

New Developments

Bahrain

The TRA planned Q4‭ ‬2025‭ ‬spectrum award of 700‭ ‬MHz‭, ‬2300‭ ‬MHz‭, ‬2500‭ ‬MHz‭, ‬and 3800‭ ‬MHz through auction did not proceed following sustained multi-level lobbying by MNOs‭.‬​

MNOs‭, ‬including Zain‭, ‬are lobbying for a deferral beyond 2026‭ & ‬a managed assignment model in place of an auction‭.‬

South Sudan

Zain secured a NCA regulatory approval for LTE 900‭ ‬MHz to activate services across rural areas and to progress toward full activation in Juba‭, ‬strengthening nationwide LTE capacity‭.‬

Iraq

Following an Industry engagement, the CMC modified the QoS Regulation with a streamlined compliance framework, which led to penalty reduction.

Infrastructure

Infrastructure Sharing

Jordan​

Instructions‭ & ‬directives‭: ‬​

  • Successful lobbying to get the TRC hold back its draft Interconnection‭, ‬Infrastructure sharing and Mobile National Roaming instructions to avoid Zain’s infrastructure usage by 3rd‭ ‬parties without fair compensation‭.‬​
  • New PM Council directive requires trenchless digging to protect roads‭, ‬increasing fibre rollout costs​

WLA Agreement‭: ‬Zain concluded the WLA Agreement with Orange with interconnection pending TRC approval‭.‬

FTTH‭: ‬Subscription fees imposed by MoLA were cancelled after Zain won the case‭.‬

Bahrain​

Zain completed the fibre asset transfer negotiation with Bnet on favorable terms‭, ‬including financial compensation and replacement products‭, ‬marking a milestone in Bahrain’s telecom sector separation process‭.‬

South Sudan​

Zain restarted tower deployments in Juba after regulatory suspension‭, ‬advanced site-sharing renegotiations with MTN‭, ‬and continued lobbying for international gateway reassignment to operators‭.‬​

Sites Deployment & Fixed Network​

Bahrain

After the release by TRA of an updated NRU guidance that may impact how enterprise connections are supported through in-building‭ ‬systems‭:‬​

  • Zain secured the withdrawal of a TRA Draft Article 35‭ ‬Order alleging NRU non-compliance‭ & ‬breach that removed enforcement risk including a proposed BHD 120k fine‭ & ‬daily penalties‭.‬
  • Zain challenged retroactive application of NRU obligations while implementing a WDC-based configuration in parallel as a risk mitigation measure preventing forced migration of enterprise IBS‭ & ‬mobile-site links to higher-cost wholesale products‭. ‬​
  • Zain continues to coordinate with the Ministry of Transportation and Telecommunications and other authorities to work toward a balanced and sustainable resolution‭.‬​

Sudan​

Sustained pressure by Zain on TPRA to finalize the new fixed-license framework and‭ ‬​

Continued push for the resolution of the Sudatel infrastructure-sharing conflict‭, ‬keeping strategic projects active despite regulatory delays‭.‬

Kuwait​

Tower and Site Regulation Review​

  • New instructions issued by MOF in DEC’25‭  ‬regarding the Towers rental excluding the indoor sites‭. ‬​
  • New Site sharing bylaws issued by CITRA in DEC‭ ‬‘25‭;‬​
  • Zain Focus remains on continuity of service‭, ‬regulatory compliance‭, ‬and cost optimization

Fixed Network Development Project‭: ‬Evaluation of the submitted bids expected to be completed by Q4‭ ‬2025‭ ‬but delayed to H1‭ ‬2026

Saudi Arabia​

Successful lobbying by Zain to halt CST proposal to fiberize all HUB tower‭, ‬thus avoiding substantial‭, ‬unjustified capital investment while maintaining network performance efficiency‭.‬

Cross border terrestrial cable​

Kuwait

In 2025‭, ‬Zain Kuwait applied for a terrestrial cable application on behalf of Zain KSA and ZOI‭.‬

CITRA approval has been secured

The final contractual arrangements are currently under execution‭, ‬enabling enhanced regional connectivity for Zain KSA

USF Projects

Saudi Arabia

Zain secured SAR 1.3‭ ‬Billion‭ ‬in USF subsidies‭, ‬made progress rural broadband expansion‭.‬

Industry Taxation & Levies​

Regulatory fees​

Jordan

New FTTH Fees Decision‭: ‬The decision issued by Ministry of Local Administration‭ (‬MoLA‭) ‬imposing fees on FTTH subscriptions has been cancelled by court with Zain winning the case at the first and second‭ (‬Final‭) ‬degrees courts‭.‬​

Revenue share‭: ‬Revision of the revenue share mechanism with the TRC‭, ‬to achieve a more efficient calculation through a more relevant way of including services

Saudi Arabia

Zain kept driving the royalty-fee reduction effort currently 10%‭, ‬strengthening its role in shaping long-term fiscal reform for‭ ‬the telecom sector‭.‬

Zain‭, ‬successfully‭, ‬negotiated with CST to hold the implementation of financial fees on Manafith 2‭ ‬preserving Zain from the annual 13M SAR agent’s fees‭. ‬

South Sudan

Zain successfully implemented the Automatic Tariff Adjustment‭ (‬ATA‭) ‬mechanism—closing the FX gap‭, ‬stabilizing revenues‭, ‬and unlocking critical 2026‭ ‬CAPEX funding‭.‬

Sudan​

Zain achieved a reduction in MW‭, ‬USF‭, ‬and annual license fees after successfully clarifying the exclusion of non-operational microwave links and third-party costs—optimizing regulatory payments with proper documentation that led to USD 600K in savings‭.‬

Iraq​

The Telecoms Industry secured the exclusion of devices sales from the revenue-share calculation basis‭.‬

Competition and Market Developments​

Market Developments​

Jordan

Mobile Number Portability‭ (‬MNP‭)‬

  • The TRC shared a draft of the MNP Clearinghouse instructions with operators‭; ‬Zain and Orange submitted joint feedback and requested further review‭.‬​
  • Both operators informed the TRC that internal system upgrades are required before MNP can be implemented‭, ‬with readiness expected after 2027‭.‬​

Managing telecom infrastructure within commercial complexes​

  • Zain engaged with the TRC and the Ministry of Industry and Trade regarding commercial matters related to telecoms services in major complexes‭, ‬and has provided all required documentation‭.‬​

New Services​

  • Zain secured the necessary approvals to operate Cell Broadcast Service‭ (‬CBS‭) ‬making Zain the 1st operator to operate this service in Jordan

Pricing​

  • A government case concerning pricing and competition practices is ongoing and currently in the witness-hearing stage

Iraq

  • 4th‭ ‬License‭: ‬Zain is challenging the 5G exclusivity given to Al Salam and is preparing for national roaming with Vodafone who is expected to manage the 4th operator‭.‬​
  • Mobile Number Portability‭: ‬CMC has suspended MNP procedures as of June 2025‭.‬​
  • Following extensive efforts by Telecoms industry highlighting concerns over the adverse CMC draft VAS regulation‭, ‬the Board of Commissioners paused enforcement of the VAS regulation‭.‬

Sudan​

Zain secured an exceptional regulatory approval for Shoofa‭+ ‬until end-2025‭, ‬coordinating with Dizlee and Group Digital to formalize the service’s legal setup and maintain uninterrupted content availability‭.‬​

Mobile Termination Rate‭ (‬MTR‭): ‬the MTR has been adjusted from 3‭ ‬SDG to 12‭ ‬SDG in order to control the national offnet traffic‭, ‬to uplift the market and promote investments through interco revenue increase‭.‬​

Saudi Arabia​

Zain has optimized its numbering resources—achieving cost savings—and has actively reshaped CST’s coverage and speed commitments toward more balanced market conditions‭.‬​

Zain successfully completed the first phase of the Open Access Platform in collaboration with CST helping the users to check the‭ ‬coverage of FTTH services using interactive map and potentially improving the overall experience of the customers‭. ‬

South Sudan​

Through sustained regulatory engagement‭, ‬Zain secured NCA support to pressure MTN toward fairer site-sharing‭, ‬improving competitive infrastructure access‭.‬

Customer Affairs and Data Protection​

SIM Registration ​

Bahrain

Zain has successfully introduced facial recognition as a secure method for SIM card registration‭, ‬following years of lobbying and collaboration with operators and TRA‭.‬​

Jordan

e-KYC has been fully enabled by Zain for prepaid and postpaid registrations‭; ‬available online and in shops‭.‬

Around 10%‭ ‬of e-KYC transactions completed via Sanad‭.‬​

Saudi Arabia​

Zain implemented a new digital authentication method via Absher across Zain and Yaqoot channels during Hajj reducing regulatory‭ ‬and identity fraud risk during Hajj season‭ ‬

South Sudan

Zain launched eSIM services and a digital registration app following NCA eSIM approval‭.‬

Sudan​

Mobile numbers recycling‭:‬‭ ‬the Recycling Freezing Decision has been revised allowing the number recycling to resume in Jan 2027‭. ‬Thus‭, ‬Zain avoid investing
USD 20‭ ‬Million in acquiring a new numbering block‭. ‬​

SIM Registration‭: ‬A penalty of USD 200K has been cancelled‭.‬​

Base registration rectification/Clean-up‭ : ‬Zain reviewed and corrected its SIM registration records to comply with regulatory requirements with 1.2‭ ‬Million SIM cards adjusted and the avoidance of USD 3‭ ‬Million penalty‭.‬

Kuwait​

Customer Registration Restrictions‭:‬‭ ‬Zain successfully completed Phase 2‭ ‬of the CID update for the historical customer backlog​

MOI restrictions‭:‬‭ ‬they are impacting self-registration channels‭, ‬E-SIM replacement processes and issuance of e-cards‭. ‬Zain is aligning internal processes to ensure full compliance while minimizing customer impact

Customer Protection​

Sudan​

Despite the National Registry blocking digital access‭, ‬Zain maintained compliance through manual ID verification and internal validation‭, ‬ensuring continued customer-acquisition stability‭.‬

Data Protection​

Saudi Arabia​

Zain maintained a full compliance with CST’s customer-protection and data-privacy requirements‭.‬​

Jordan

The‭ ‬“Right of the Data Subject”‭ ‬bylaw was approved by the Prime Minister‭; ‬Zain is aligning internal processes with upcoming Data Privacy Law requirements‭.‬​

TRC is reviewing handset regulation updates‭ (‬ACEIR‭); ‬RFP under preparation‭.‬

Kuwait

A new bylaws was issued by the National Cybersecurity Authority on data classification​

Zain is aligning internal governance‭, ‬systems‭, ‬and processes to align with the new cybersecurity obligations‭.‬

Cybersecurity​

Jordan

In August 2024‭, ‬Jordan Cybersecurity Center has issued Jordan’s National Cybersecurity Framework‭.‬​

In November 2024‭, ‬the Jordan National Cyber Security Center has issued a By-Law on the Licensing of Cybersecurity Service Providers in Jordan‭.‬​

5G

5G Developments​

Kuwait

Zain has been awarded a nationwide 5G Advanced License by CITRA​

5G Advanced License fee is KD 1‭ ‬million while the annual payment for the attached 100MHz in 2.6GHz band is KD 2‭ ‬Million‭.‬

Saudi Arabia

Zain has aligned its 5G rollout with CST targets‭, ‬leveraging new 600‭ ‬MHz spectrum to strengthen nationwide coverage and future 5G-Advanced readiness‭.‬​

Jordan

Zain started the phase no‭. ‬3‭ ‬of its roll out plan which aims to cover main cities‭, ‬industrial and commercial zones by Feb 2026‭ ‬with 35.7%‭ ‬of the population and 204‭ ‬neighborhoods covered‭.‬

B2B, Cloud, IoT & ICT Focus Areas​

B2B, Cloud, IoT & ICT Focus Areas​

Saudi Arabia

Zain secured the Vehicle tracking license and requested approvals by CST for two IoT MVNOs, expanding its enterprise and wholesale digital ecosystem.

Innovative Digital & Emerging Services​

Innovative Digital & Emerging Services​

Sudan

Zain achieved a major milestone with Bede Ltd officially going live under its Central Bank license‭, ‬expanding fintech reach‭.‬

South Sudan

Zain formally exited the mGURUSH JV—pivoting toward securing its own fintech license for a cleaner‭, ‬more compliant entry into digital finance‭.‬​

The NCA granted Zain a‭ ‬“Letter of No Objection for Mobile Money Platform”​‭.‬

Saudi Arabia

Developing Local Digital Content‭: ‬Zain avoided penalties under Decision 508‭ ‬related to Accessing Internet Content Hosted Locally which obligates Zain to peer with‭ ‬other Exchanges and protected commercial flexibility by demonstrating compliance while challenging mandatory local-peering obligations‭.‬​

Regulatory Focus Areas Underpinned by Regulatory Compliance

Where to play?

Spectrum & Technical Regulations

  • Spectrum Management‭ & ‬Technical Regulation​
  • Radio Access Network Spectrum
  • Microwave Backhaul Spectrum
  • National Spectrum Roadmaps​
  • Cross Border Frequency Coordination

Customer Affairs & Data Protection

  • Personal Data Protection and Privacy​
  • Consumer Protection‭ ‬​
  • SIM-Registration‭ / ‬SIM-Caps​
  • Customer Complaints Handling​
  • Others‭: ‬Billing‭ / ‬Collection‭ / ‬Spam

Infrastructure & Climate Action

  • Service Licences​
  • Sites/Masts/Active/Passive Sharing/TowerCo​
  • National/Intercity/Metro Fibre/Open Access​
  • International Connectivity/Submarine Cables​
  • Data Centres/Cable Landing Stations

Competition & Market Developments

  • Strategic Market Reviews and Remedies​
  • Access‭ & ‬Interconnection​
  • Competition Matters​
  • Telecom Law Reviews​
  • Others‭: ‬New Entrants/OTT Players​

5G

  • 5G Policy Development​
  • 5G Licensing Rollout Obligations​
  • Strategic Approach to Verticals​
  • 5G Security and Privacy​
  • Demand Stimulation for Use Cases

Industry Taxation and Levies

  • Operator Regulatory Fees​
  • Consumer Levies​
  • Value Added Taxation​
  • Universal Service Fees​
  • Tracking of Regulatory Financial KPIs

B2B, Cloud, IoT and ICT Focus Areas

  • B2B Enablement​
  • IoT Regulatory Framework​
  • eCall Regulations​
  • Cloud Computing Frameworks​
  • Cyber-security regulatory mandates​

Innovative Digital & Emerging Services

  • Artificial Intelligence​
  • Digital On-Boarding/Electronic Transaction Laws​
  • FinTech/Insurtech/e-Payments Regulations​
  • AML/CFT Laws and Regulations​
  • Digital Content‭ / ‬E-Sports

How to play?

Constant alignment with Group Corporate Strategy ‘4Ward’

Engagement with Group Divisions and OpCo Plans

Regulatory Compliance, Risk Evaluation, Prioritisation and Mitigation​

Regulatory Authority Engagement​

Public Consultation Responses​

International Institutional Agenda Alignment​

Increased Management Regulatory Awareness​

Training and Capacity Building​

Best Practices Benchmarking​

Regulatory Strategic Direction Across Eight Pillars

Spectrum & Technical Regulations

Lower spectrum prices for new acquisitions and​‭ ‬license renewals considering inflation‭, ‬cost of deployment

Grant Longer License Duration‭ (>‬20‭ ‬years‭) ‬in line with international best practice for investment certainty

Guarantee technology neutrality across all bands considering the sunset of certain technologies‭.‬

Favorable Payment Models‭: ‬Installment over license tenure‭; ‬deferred payment schemes

Accelerated release​‭ ‬of IMT spectrum in markets with limited spectrum holdings

Regulator-led cross border frequency‭ & ‬synchronisation​coordination across all bands

Contiguous spectrum allocation‭ ‬​for efficiency and higher speed

Proactive Publication​‭ ‬of National Spectrum Roadmap for Coordinated Planning

Infrastructure

Support right to deploy fibre or regulated access to fibre on fair price and non-price terms​

Liberalisation of international gateway and cable landing stations

To lower IP transit costs‭, ‬advocate landing of more submarine cables

Site roll-out regulations aligned to international best practices

Favourable legislation for passive/active infrastructure sharing‭ & ‬TowerCo establishment​

​Offer unified or integrated licences to permitting fixed and mobile services for converged offerings​

Accelerate initiatives to support digital infrastructure‭: ‬Data centres‭, ‬IXPs‭, ‬etc‭.‬

Favourable legislation for renewable energy generation‭ /‬production

Industry Taxation and Levies

Lower levels of industry-specific fees‭ (‬revenue share‭, ‬licensing‭, ‬numbering‭) ‬on national operators

​Where possible‭, ‬eliminate industry-specific utility prices or differential tax rates​

Create incentive to deploy IoT/M2M by lowering regulatory costs to enable these to thrive​

Reasonable rental fees for passive infrastructure owned by government entities

Lower Government-imposed activation charges on customers‭ (‬SIM‭, ‬connection taxes‭)‬

Lower handsets taxes to enhance affordability

Lower Usage Taxes‭ (‬excise duties‭, ‬higher VAT rates‭…)‬

Minimal or no fee that will hinder digital services development

Competition & Market Developments

Periodic Strategic market reviews to assess effectiveness of any ex-ante obligations

Implement proportionate remedies‭ ‬–‭ ‬only apply tariff pre‭- ‬approvals on dominant operators

Avoid stringent regulations or government behavior that impede competition‭ (‬e.g monopolies‭)‬

Market liberalisation should consider ability of existing players to sustain and recoup investments​

Lobby for Retail Tariff increase when inflation rates and Forex are out of normalcy

Ensure Cost-based pricing for Wholesale and access services

Implement regulations addressing price wars that destroy market value

Regulate number of MNOs/MVNOs to a level that does not deter further investment

Customer Affairs & Data Protection

Enact consumer protection legislation to guard against unfair terms and foster transparency​

Develop Robust Standalone Data Protection Laws Across All Sectors​

Create a safer‭, ‬cyber-secure internet experience for consumers‭, ‬businesses and society

Create flexible and reasonable SIM Registration Requirements

Develop legislation enabling the use of artificial intelligence without impeding personal data protection

Promote transparency in Customer Privacy Information collection and use by 3rd‭ ‬parties​

Avoid onerous consumer protection rules impeding operators’‭ ‬marketing strategy

Create light touch or favourable roaming regulations governing usage‭, ‬price‭, ‬price caps and terms‭ ‬

5G

Ensure 5G rollout obligations are not onerous

Licensed spectrum dedicated to MNOs and not to Verticals

Government-led 5G investment support in exchange for accelerated rollout of 5G​

Government to stimulate 5G demand and cross sector collaboration to support use-cases

Collaborative actions to tackle 5G Security Challenges that Service Providers are facing‭.‬

Promote the development of private 5G-network-as-a-service provided by MNOs​

Release new spectrum for 5G to drive bandwidth availability for advanced use cases​

Promote fiber roll-out for speedy 5G backhauling and effectiveness​

B2B, Cloud, IoT and ICT Focus Areas

Lobby for Unified Licenses or Right to Offer Fixed/Data Centre Services

Accelerate adoption of Cloud regulations through favourable legislation

Permit cross-border transfer of non-personal data for centralized processing​

Create favourable regulatory frameworks to IoT/M2M deployment and service provision

Lobby for incentives and subsidies to attract investment to boost Datacenters capacity​

Develop cybersecurity legislation to prevent attacks and secure applications and infrastructure

Incorporate balanced regulations‭, ‬supportive of data protection and Big data analytics development

Create favorable regulations‭ ‬​and alignment amongst authorities for the civil use of unmanned aircraft‭ (‬drones‭)‬​

Innovative Digital & Emerging Services

Develop policies and legislation supportive of Artificial intelligence adoption

Accelerate adoption of digital identity‭, ‬e-KYC and e‭- ‬Authentication procedures

Enforcement of electronic contracts and signatures in judicial system

Lobby for legislation that promotes the usage of direct operator billing by operators

Enactment of laws which are supportive of FinTech and InsureTech growth

Enactment of laws and regulations which are supportive of digital health​

Enactment of legislation which is supportive of e-gaming growth‭ ‬​and development

Promote creation of regulatory sandboxes for emerging technologies