Highlights

On 27 March 2025, the Ministry of Tourism and Antiquities (the “Ministry”) issued decree no. 209 of 2025 (the “Decree”), which was published in the Official Gazette on 12 May 2025. The Decree establishes the regulatory framework for licensing holiday homes in Egypt (the “Holiday Homes”), and sets out the mandatory facilities, specifications, and amenities required for such accommodations. It also details the obligations of owners and operators, along with the applicable licensing fees.

We have observed a notable increase in the number of Holiday Homes available in the market, offering an alternative solution to help offset the shortfall in hotel capacity across Egypt. In light of the growing reliance on these accommodations, the Decree has been issued to regulate Holiday Homes. It also aims to ensure that accommodations provided to tourists and visitors meet minimum quality standards, thereby enhancing Egypt’s appeal as a tourist destination.

Although the Decree refers specifically to “Holiday Homes,” we note that the concept resembles that of serviced apartments, which are regulated under the Hotel and Tourist Establishments Law No. 8 of 2022. However, the Decree seeks to regulate a new, more simplified category of accommodation within the tourism sector by setting less restrictive requirements and standards.

Scope of Application

The Decree defines Holiday Homes as accommodation units that meet the following criteria:

• Consist of a minimum of one (1) room, suite, or villa, located within a standalone building or a portion thereof;
• offer basic services, such as internal housekeeping;
• are located in a tourist area or a distinctive residential complex; and
• are intended to accommodate both Egyptian and foreign guests.

It is worth noting that the Decree does not provide a specific definition for “distinctive residential complexes.” However, under Building Law No. 119 of 2008, “residential complexes” are described as a group of residential, service, and entertainment buildings developed in accordance with an approved detailed plan. The practical application of this Decree will likely reveal how the Ministry chooses to define and interpret “distinctive residential complexes.”

Holiday Homes Licensing Requirements

Owners or operators of Holiday Homes must obtain the required licence, referred to as the Touristic Eligibility Certificate (the “Certificate”). To be eligible for licensing, Holiday Homes must comply with the structural, access, facility, amenity, and general standards stipulated in the Decree.

Additionally, Holiday Homes must meet occupational health and safety requirements as issued by the Ministry of Labour. The owner or operator must notify the Ministry electronically using the designated form available on the Ministry’s website, submit all required documents (whether the owner/operator is an individual or legal entity) as listed in the Decree, and pay all applicable taxes and fees in order to obtain the Certificate.

Fees to Obtain and Renew the Certificate

• EGP 3,500 (three thousand and five hundred Egyptian pounds) for the initial operation inspection of the Holiday Home;
• EGP 3,500 (three thousand and five hundred Egyptian pounds) for the first-time issuance of the Certificate; and
• EGP 3,100 (three thousand and one hundred Egyptian pounds) as an annual inspection fee for renewal of the Certificate.

Conclusion

The Decree establishes a regulatory framework for Holiday Homes in Egypt, reflecting the Ministry’s efforts to standardise this accommodation category. By enforcing consistent quality and operational requirements, the Decree seeks to improve the experience of tourists and visitors and support the broader development of Egypt’s tourism sector.

The contributors to this article are Mohamed Fathy, Partner and Head of Real Estate, Tourism & Hospitality, and Ameerah Abdelnaem, Junior Associate.