Overview

On 25 September 2025, the Financial Regulatory Authority (the “FRA”) issued two (2) landmark decrees effective as of the day following their publication in the Official Gazette (i.e., 26 September 2025) establishing the legal and operational framework for conducting insurance brokerage and insurance distribution digitally in Egypt:

• Decree No. 198 of 2025, regulates the digital operations of licensed insurance brokers in Egypt.
• Decree No. 199 of 2025, governs the issuance and distribution of insurance policies by insurance companies through digital networks.

These Decrees aim to enhance the digital transformation of the insurance sector by integrating financial technology standards, ensuring data protection, and promoting transparent and efficient customer interaction channels.

1. Digital Insurance Brokerage (Decree No. 198 of 2025)

Scope of Application

This Decree applies to all companies licensed by the FRA to conduct insurance brokerage activities digitally (“Digital Insurance Broker”).

Licensing and Approval Requirements

Companies licensed by the FRA to practice insurance brokerage activities are required to obtain the FRA’s approval before operating digitally, provided that the following requirements are met:

• holding a valid insurance brokerage license issued by the FRA;
• providing the FRA with a business plan for digital insurance brokerage operations, duly approved by the company’s board of directors;
• identifying the products and services to be offered to customers;
• complying with the cybersecurity requirements set out under FRA Decree No. 139 of 2023;
• complying with requirements of the FRA Decree No. 140 of 2023 concerning digital service delivery; and
• providing the FRA with a live demonstration of the digital platform, including the services offered and the results of penetration and vulnerability testing for such platform.

Technical and Data Requirements

Digital Insurance Brokers’ platforms must be integrated with insurers’ technological systems through instant electronic interfaces (Web Service APIs), to enable the issuance of insurance quotations and policies, as well as the submission of insurance applications.

Digital Insurance Brokers must:

• ensure the preparation of insurers’ technological infrastructure, prior to connection therewith, in order to allow for secure, real-time data exchange;
• store customer and insurer data on secure servers; and
• maintain data confidentiality.

Digital Insurance Broker Obligations

Digital Insurance Brokers are required to:

• display their license details and the FRA’s approval to conduct digital insurance brokerage activities on the platforms;
• disclose the nature of the services provided to customers on the platform;
• prepare customer declarations for approval prior to the issuance of insurance policies;
• prepare a list of linked insurers with which a digital connection is established;
• provide transparent and objective product comparisons, and ensure direct customer service communication through the platform;
• refrain from collecting premiums or insurance fees through private accounts, by ensuring that only authorised electronic payment channels are utilised;
• conduct periodic penetration and vulnerability tests and submit the results to the FRA;
• comply with cybersecurity requirements; and
• update and develop the platform regularly or as necessary to ensure continued functionality and compliance.

Insurer Responsibilities

Insurance companies cooperating with Digital Insurance Brokers must:

• verify that the Digital Insurance Broker’s holds a valid approval prior to entering into any contractual arrangement;
• ensure that the purpose of the electronic connection is strictly limited to the provision of digital insurance brokerage services;
• confirm that their technological infrastructure is duly integrated to enable secure platform connectivity, real-time data exchange and communication;
• display insurance product prices in accordance with the technical standards approved by the FRA;
• maintain satisfactory results of penetration and vulnerability test, and promptly notify the FRA of any digital security breaches; and
• facilitate direct digital payments of premium from customers into the insurer’s accounts through licensed electronic collection channels.

2. Digital Insurance Issuance and Distribution (Decree No. 199 of 2025)

Scope of Application

This Decree permits insurance companies to issue and distribute insurance policies digitally, either through their information systems or via FRA-approved intermediaries, subject to obtaining the FRA’s prior approval.

Approval Process

Insurance companies seeking to issue and distribute insurance policies digitally must submit an application to the FRA that includes the following:

• a statement of the procedures for digital issuance and distribution of insurance policies, including fulfilling all insurance requirements for policy issuance, informing customers both in writing and via video of the insurance product, its terms, and associated risks, and digitally verifying customers’ acceptance of policy terms; and
• a pledge to abide by technology infrastructure, fintech outsourcing, and digital identity regulations issued by virtue of the FRA Decrees Nos. 139, 140, and 141 of 2023.

Payment Rules

• Premiums must be paid by customers directly to the insurer through non-cash electronic payment methods (i.e., POS, direct debit, or bank cards).
• Marketing and distribution agents contracted by the insurer are prohibited from collecting fees, premiums, or any other amounts due from customers through private accounts. Such amounts must be collected exclusively through non-cash electronic payment methods.

Disclosure and Consumer Protection

When issuing insurance policies in accordance with the Decree, insurers must, inter alia:

• clearly display minimum policy data, instructions, and conditions on their digital interfaces;
• ensure that the validity of the insurance coverage is linked to actual collection of the first premium;
• verify customer information (i.e., national ID validity, mobile number ownership, inclusion on AML lists) prior to policy issuance;
• notify customers that the distribution agent’s role is strictly limited to marketing and distribution channel, with no liability for the terms and conditions of the insurance products being promoted; and
• maintain a call centre to service digital policyholders, respond to inquiries, and receive complaints.

Authorised Distribution Channels

Subject to the submission of a request to the FRA, insurers may market and distribute insurance policies through:

• FRA-licensed digital insurance brokers;
• CBE registered banks, the National Postal Authority, Nasser Social Bank, airlines, telecommunications companies, or e-commerce platforms; or
• other channels approved under microinsurance policy issuance and distribution regulations.

In addition to holding the necessary licenses to practice their respective activities, the aforementioned entities must obtain the approval of the competent authorities to market and distribute insurance policies in accordance with the Decree.

The marketing and distribution agreement concluded between the insurer and the marketing or distribution agent must be submitted to the FRA. The agreement must specify the type of insurance policies to be marketed and distributed, including confidentiality commitments, defined the marketing and distribution plan and its outlets, and set out the financial obligations of the contracting party.

The contributors to this article are Ibrahim ElGengehy, Partner, Ibrahim El Messery, Counsel, and Zeina Jowett, Associate.