AzkiVam vs. SnappPay: Breaking Exclusivity in Iran’s Emerging BNPL Market
As Iran’s digital economy continues to grow, new sectors are beginning to take shape within the platform landscape. One such space is short-term installment credit, commonly referred to as BNPL—Buy Now, Pay Later. Globally, BNPL has emerged as a popular tool for consumers seeking flexible payment arrangements, and Iran has followed suit. Yet, as the market took form, concerns quickly emerged over unfair market conditions and exclusionary practices by dominant players.
This blog post traces the legal and economic battle waged by AzkiVam, a subsidiary of Afra Digital Capital, against SnappPay, Iran’s leading BNPL platform. The case, brought before the Competition Council and ultimately resolved in AzkiVam’s favor, reveals how entrenched power in digital ecosystems can be challenged—if the right institutional and analytical tools are deployed.
At the heart of the complaint was a simple yet powerful principle: market access should not be gated by exclusivity. SnappPay’s contracts with major merchants were, according to the complaint, structured to prevent competition and lock retailers into a single provider. The result was not just harm to AzkiVam—it was harm to the entire marketplace, including consumers and smaller merchants. With the help of Bana, Iran’s Center for Development and Competition Studies, AzkiVam built a legally and economically robust case that exposed these practices and led to a consequential regulatory ruling.
Entering a Closed Market
In 2023, AzkiVam prepared to enter the Iranian BNPL market with a vision to offer users greater financial flexibility, particularly for online purchases. Technologically equipped, operationally ready, and backed by competitive credit offerings, AzkiVam expected to scale rapidly by partnering with large retail chains, just as SnappPay had done in earlier years.
However, this plan met a near-immediate obstacle. Major merchants across several key sectors had already signed exclusive contracts with SnappPay, preventing them from collaborating with any other BNPL platform. In some cases, even exploratory discussions were discouraged. The few that attempted to diversify payment options faced severe contractual penalties—ranging from early termination fees to withdrawal of preferential commercial terms.
In effect, SnappPay had created a sealed market, in which it alone could offer installment payment services through high-volume retail partners. Despite AzkiVam’s readiness, it was shut out of critical distribution channels, undermining its ability to scale or even test its model in meaningful volumes.
From a legal standpoint, this situation raised serious red flags. AzkiVam and Bana identified it not as a result of organic competition, but as an abuse of dominance by a market incumbent leveraging exclusivity clauses to prevent entry and suppress innovation.
Building the Legal and Economic Argument
AzkiVam turned to Bana for strategic support. With experience in regulatory advocacy and a track record of supporting legal action in the digital economy, Bana worked closely with AzkiVam leadership—particularly CEO Mohammad-Mahdi Momeni—to frame a complaint that would hold up under competition law standards.
The strategy began with a detailed definition of the relevant market. While SnappPay might have argued it was merely one actor in a broader payments or e-commerce ecosystem, Bana argued otherwise. The complaint defined the relevant market as digital short-term consumer credit solutions (BNPL)—a narrower and more precise market in which SnappPay held dominant share, both in terms of user access and merchant integration.
Bana’s team analyzed both supply- and demand-side dynamics. They showed that access to top merchants was a key determinant of success in BNPL, and that SnappPay had used this access not just for growth, but to exclude all others. The analysis included contractual reviews, economic modeling, field interviews, and market simulations to show how the ecosystem would look in the absence of restrictive agreements.
Their findings revealed a recurring contractual pattern designed to suppress competition and ensure merchant loyalty through coercive means. Many of SnappPay’s contracts included strict exclusivity clauses that explicitly barred retailers from offering BNPL credit through any competing platforms. Merchants who attempted to exit these agreements faced heavy financial penalties, making withdrawal prohibitively expensive. Additionally, preferential algorithmic treatment—such as higher visibility or better platform support—was made contingent on merchants’ refusal to cooperate with rival services. In some cases, SnappPay even offered financial incentives or bonuses, but only if retailers agreed to remain exclusive, effectively using short-term rewards to enforce long-term dependence.
These practices, the complaint argued, violated multiple provisions of Iran’s competition law—specifically those that prohibit the abuse of dominant position and the imposition of unreasonable contract terms that distort the market.
Filing the Complaint—and Standing Alone
In August 2023, AzkiVam submitted its formal complaint to the Competition Council. At that stage, no other platform had joined the challenge. Many feared retaliation, or believed a ruling against a powerful player like SnappPay was unlikely.
Nonetheless, AzkiVam pushed ahead. Over the course of five legal and economic review sessions held jointly by the Council and the National Competition Center, the evidence and analysis presented by Bana helped solidify the case. Eventually, another major platform—Digipay—joined the complaint, citing similar exclusionary experiences with SnappPay. AzkiVam, rather than treat this as competition, chose to collaborate and share its data, documents, and analysis with Digipay. Bana continued to act as a unifying coordinator across both cases.
This collaboration resulted in the consolidation of the two complaints, giving the Competition Council a clearer and more comprehensive picture of how widespread SnappPay’s conduct had become.
The Verdict: A Landmark Decision
Following months of deliberation, the Competition Council issued a decisive ruling. It found SnappPay guilty of anti-competitive practices in its use of exclusivity clauses and restrictive contracts. The ruling, issued based on Articles 45 and 44 of Iran’s Competition Law, specifically cited SnappPay’s violation of market fairness principles and confirmed its abuse of ecosystem-driven dominance.
SnappPay was ordered to remove all exclusivity terms from current contracts and prohibited from including them in future agreements. The Council emphasized that the power derived from being part of a larger platform ecosystem (Snapp Super App) should not be used to block market access or silence competition in adjacent service verticals.
The ruling represented a watershed moment in Iran’s digital regulatory landscape. It was one of the first times a ruling not only targeted exclusivity, but also addressed platform conglomerate effects—where dominance in one digital service spills over to give unfair leverage in another.
Lessons and Broader Implications
The AzkiVam vs. SnappPay case offers valuable lessons for Iran’s digital players, regulators, and policymakers.
First, it proves that a well-documented, data-driven legal challenge can succeed, even when mounted against a powerful and entrenched incumbent. AzkiVam’s persistence—combined with Bana’s analytical and strategic depth—shows that the tools of competition law can be used effectively in emerging markets.
Second, the case demonstrates the dangers of unchecked exclusivity in digital ecosystems. In BNPL, as in food delivery or ride-hailing, market access depends on visibility, interoperability, and the freedom to choose. When those channels are blocked, innovation suffers, prices stagnate, and consumers lose.
Third, it shows the value of regulatory institutions that are willing to adapt. The Competition Council not only admitted the complaint but engaged deeply with the legal and economic arguments—ultimately issuing a substantive and enforceable ruling that sets a precedent for future disputes in digital markets.
Finally, the case provides a roadmap for other challengers. Success came not from public campaigns or political pressure, but from methodical legal reasoning, precise market analysis, and internationally informed argumentation.
Conclusion: A Step Toward Fair Digital Credit
The outcome of the AzkiVam vs. SnappPay case is more than a corporate victory. It is a foundational precedent for digital competition enforcement in Iran. It protects consumer choice, affirms the rights of emerging platforms, and signals that dominant players cannot build moats through contract rather than competence.
By choosing a path of documentation, legal rigor, and collaboration, AzkiVam not only carved a space for itself in the BNPL sector—it helped shape the rules of the game for everyone else. As digital finance continues to grow in Iran, this ruling will stand as both a warning and a guide: monopoly is not inevitable, and exclusion is not a right.
For other companies navigating Iran’s evolving digital landscape, the lesson is clear. When the market is unfair, regulation can—and should—step in. And when backed by evidence, expertise, and resolve, even a new player can move the system