Overview

In line with a series of decrees issued by the Ministry of Labour since the enactment of Egypt’s new Labour Law No. 14 of 2025 (the “Labour Law”) on 1 September 2025, the Minister of Labour issued Decree No. 194 of 2025 (the “Decree”) on 18 September, regarding the facilitation of rules and procedures for adjusting the status of foreign employees in small enterprises within Egypt.

Subsequently, on 24 September 2025, the General Administration for Licensing and Regulation of foreign employees, in accordance with the Decree, issued Guideline No. 2 of 2025 the “Guidelines”) concerning foreign work permits.

Scope of Application

The Decree applies to foreigners working in small enterprises within Egypt. Although the Decree does not define small enterprises, it is to be noted that restaurants, public facilities and shops, and sole proprietorships (“Small Enterprises”) are exclusively referred to under the Decree and Guidelines.

Grace Period

A three (3) month grace period has been granted from the date of the Decree’s issuance, during which foreign nationals must apply for work permits.

Application Process and Documents

Applications must be submitted by the foreign employee, or the legal representative of the Small Enterprise to the relevant local Labour Directorate (based on geographic jurisdiction), within the three (3) month period.

Applicants are required to provide the following documents:

• a copy of the Company’s commercial register, or operating license;
• a copy of the tax card, accompanied by the original for review;
• a copy of the foreign national’s passport, accompanied by the original for review;
• a medical certificate (HIV);
• Form 1 permit, and six (6) copies of Form 3 permit; and
• eight (8) personal photographs.

Work permits shall only be issued after security clearance is obtained from the relevant security authorities.

Key Facilitation and Exemption

Foreign employees of Small Enterprises are now exempt from the usual statutory licensing and recruitment requirements, including the submission of contracts, experience certificates, or residence permits.

In addition, Small Enterprises are temporarily exempt, during the three (3) month grace period, from the statutory quota limiting the proportion of foreign to national employees. It is worth noting that this exemption has not been tested in practice; accordingly, the legal status of foreign employees hired during the grace period, after the lapse thereof, remains uncertain.

• Permit Fee: EGP 3,000 (three thousand Egyptian pounds) per year, in addition to EGP 200 (two hundred Egyptian pounds) in card fees.
• Permit Duration: Work permits are issued for up to one (1) year, or a shorter period upon request, with the first year being calculated from the date of the permit’s issuance, as opposed to the date of entry into Egypt.
• Permit Cancellation: The permit may be cancelled in the event of a criminal conviction, the provision of false information, the use of the permit to work in a job or entity other than that for which it was issued, or security concerns.

Conclusion

The Decree and Guidelines both aim to facilitate procedures, while granting a significant opportunity to foreign nationals who have recently relocated to Egypt, and are employed by Small Enterprises, by allowing them to regularise their status and work legally, in order to achieve the public interest.

ADSERO is closely monitoring the issuance of further decrees and regulations that are expected to provide additional clarity on the implementation of the Labour Law.

The contributors to this article are Alia Monieb, Partner and Head of Employment, Rawan Roshdy, Managing Associate, and Hoda Khira, Junior Associate.