On 9 February 2026, the Competition Appeals Board upheld Decision No. 742 of the Competition Council dated 13 May 2025, confirming that SnappPay had engaged in anticompetitive conduct in the short-term consumer credit (“Buy Now, Pay Later” – BNPL) market. The Appeals Board dismissed SnappPay’s appeal and confirmed that its exclusive arrangements with merchants must be terminated.

The proceedings were initiated following separate complaints by AzkiVam and DigiPay, alleging that SnappPay leveraged its dominant position by imposing exclusive dealing obligations supported by incentive schemes and penalty mechanisms that restricted competing platforms and deterred market entry.

The Appeals Board confirmed the Council’s assessment that such contractual provisions had restrictive effects and ordered their immediate cessation. SnappPay is required to refrain from imposing exclusivity clauses or adopting conduct that may prevent the entry or expansion of competitors.

Pursuant to the Iranian Competition Law, the Appeals Board’s decision is final and enforceable. Any action before the Administrative Justice Court does not suspend implementation. From the date of notification, failure to comply may expose the company to damages claims by affected parties.

Bana represented AzkiVam throughout the proceedings, including the development of legal arguments and the preparation of supporting economic evidence.