We are pleased to share our most recent report highlighting the critical decisions issued by the Board of Directors of the Financial Regulatory Authority (FRA) during the second quarter of 2026.
To access the second issue, click on the attachment below.
Introduction
On 2 April 2026, the Official Gazette published law no. 3 of 2026 (the “Amending Law”), which amends the real estate tax law no. 196 of 2008 (the “Real Estate Tax Law”). The Amending Law entered into force on the day following its publication (the “Effective Date”). The Executive Regulations of the Real Estate Tax Law are expected to be amended within six (6) months of the Effective Date to implement the changes and reforms introduced by the Amending Law.
The Amending Law forms part of the Egyptian government’s broader tax reform agenda, and aims to ease the burden on taxpayers, simplify compliance, promote transparency, and modernise administrative processes.
Further tax reform measures followed shortly thereafter as part of the government’s ongoing tax reform plan, introduced through the following laws, recently issued and published in the Official Gazette on 28 July 2026:
This publication focuses on the Amending Law, which introduces changes carrying immediate practical consequences for property owners in Egypt, from a substantially higher exemption threshold to new mechanisms for resolving long-standing disputes with the Real Estate Tax Authority (“RTA”). Where relevant, it also situates these changes within the broader tax reform package summarised above.
The key reforms examined in this publication include:
It further considers related developments introduced as part of the same reform wave, including amendments to the Real Estate Disposal Tax under the Income Tax Law and relevant changes to the Value-Added Tax Law.
Key Reforms
Pursuant to the Real Estate Tax Law, real estate tax is imposed on built properties at a rate of 10% (ten per cent) of the property’s annual rental value. For the purpose of calculating the tax base, a statutory deduction of 30% (thirty per cent) of the annual rental value is available for residential properties, while a deduction of 32% (thirty-two percent) applies to non-residential properties. These deductions are deemed to cover all expenses incurred by the taxpayer in relation to the property, including maintenance costs.
The Real Estate Tax Law provides for the establishment of committees in each governorate (the “Inventory and Valuation Committees”) responsible for assessing the annual rental value of real properties. These committees survey real properties and assess their annual rental value based on properties’ classification according to certain standards. In this respect, the RTA conducts a comprehensive inventory of all real properties in Egypt every five (5) years to reassess their rental values. Furthermore, an annual inventory is conducted to identify newly constructed buildings, as well as any additions or substantial modifications made to existing buildings.
The Amending Law refines the framework governing the assessment of the annual rental value of the properties, increasing valuation transparency while maintaining the tax rate and the existing five (5) year valuation cycle.
The assessed annual rental value remains effective for a period of five (5) years, with the newly assessed value becoming applicable as of the day following the expiry of the preceding valuation period. The Amending Law also retains the existing requirement that reassessment procedures be initiated no less than one (1) year and no more than three (3) years before the expiry of each valuation cycle.
Importantly, the Amending Law introduces a new obligation requiring the RTA to publish indicative pricing maps at least ninety (90) days before the implementation of new valuations. The Executive Regulations are to set out the bases and criteria for valuation, as well as the applicable reassessment procedures.
A cornerstone of the reform is the substantial increase in the real estate tax exemption threshold for a property used as the primary residence of the taxpayer and their family, comprising taxpayer’s spouse and minor children, to EGP 100,000 (one hundred thousand Egyptian pounds). According to the RTA’s official website, this corresponds to a market value threshold of EGP 8,000,000 (eight million Egyptian pounds). Any amount exceeding such threshold shall be subject to tax. Secondary homes of taxpayers remain fully taxable.
Moreover, the Amending Law provides that the Cabinet is authorised to increase the above exemption threshold based on economic and social considerations.
The Amending Law introduces a more structured and enhanced framework governing tax return filing obligations, in particular through two (2) key adjustments: (a) a consolidated tax return covering all real estate properties owned or utilised by the taxpayer; and (b) the option to file tax returns electronically.
The Amending Law retains the filing deadlines prescribed under the Real Estate Tax Law prior to its amendment. However, it grants the Minister of Finance (the “Minister”) the authority to extend the statutory deadlines for the submission of tax returns for a period not exceeding six (6) months.
Taxpayers remain required to submit their real estate tax returns to the competent tax office with jurisdiction over the relevant property. The Amending Law, however, addresses a long-standing procedural burden for taxpayers owning or utilising multiple properties in different jurisdictions. Rather than filing a separate tax return with each competent tax office, such taxpayers may now submit a single consolidated tax return to any competent tax office, provided that the return includes details of all properties subject to the filing.
From a procedural standpoint, the Amending Law expressly permits the taxpayers to submit their tax returns either electronically or in physical form. The Executive Regulations will prescribe the applicable filing procedures, the required information and data fields, and any other formal requirements governing such submissions.
The Amending Law imposes additional reporting obligations on certain third parties, reflecting an evident aim to strengthen the RTA data infrastructure and enable more accurate identification and valuation of taxable properties independently of taxpayer self-reporting.
Licensed operators of hotel establishments, owners’ associations, and managers of residential compounds are required to submit specified data on persons holding rights over the relevant properties whether ownership, usufruct, or exploitation rights to the competent tax office, within the prescribed deadlines. Such data must include their names, national identification numbers, place of residence, the area size of each property, and any additional data specified under the Executive Regulations.
Electricity, water, sanitation, and natural gas companies, as well as local municipalities, public authorities, and other public legal persons, are required to provide the RTA with the data and supporting documentation requested for purposes of identifying taxable properties and determining their annual rental value.
Under the Real Estate Tax Law, annual rental value assessments are publicly announced, and a notice thereof is published in the Official Gazette. Taxpayers are subsequently notified of the assessed annual rental value and are entitled to challenge the assessment within sixty (60) days from the date of such notification.
Appeals are heard by the Appeal Committees established in each governorate, the composition and decision-making procedures of which are prescribed under the Real Estate Tax Law. The Amending Law retains the existing requirement that an Appeal Committee must issue its decision within thirty (30) days from the date on which the appeal is filed, and that such decision is final. Importantly, the Amending Law confirms that the tax shall become due and payable based on the Appeal Committee’s decision. The filing of a judicial challenge against such decision before the competent court shall not prevent the collection of the tax or the commencement of administrative attachment proceedings for its recovery.
Furthermore, the Amending Law introduces two (2) major enhancements, as follows:
In addition to the existing channels, the Amending Law allows taxpayers to submit appeals challenging rental value assessments by approved electronic means.
The Amending Law cancels the right of the Real Estate Tax Districts to challenge inventory and assessment decisions issued by the Inventory and Valuation Committees. Prior to the Amending Law, the Real Estate Tax Districts had the right to challenge such decisions where they considered the assessed value to understate the actual rental value.
Further, the Amending Law introduces a provision requiring the dismissal of appeals filed by the Real Estate Tax Districts that remain undecided as of the Effective Date.
The Amending Law also broadens the circumstances in which real estate tax ceases to apply. In addition to the existing grounds for the cessation of tax, relief is now available where unforeseen circumstances or events of force majeure prevent the use or exploitation of a property, whether in whole or in part.
In this regard, the tax ceases to be payable pursuant to a decision issued by the competent Real Estate Tax District, either on its own initiative or upon an application submitted by the taxpayer together with supporting documents. Such cessation shall take effect from the date on which the relevant ground for relief arises and shall continue until the date on which such ground ceases to exist.
An important amendment introduced by the Amending Law is that applications for the cessation of tax liability are now determined by the competent Real Estate Tax District, whereas, prior to the Amending Law, such applications were decided by the Inventory and Valuation Committees. Appeals against such decisions continue to be submitted to the Appeal Committees.
A tax incentive is granted to taxpayers who timely submit their tax returns, in the form of a deduction from the annual tax due for the relevant tax period. The incentive is set at 25% (twenty-five per cent) for residential properties and 10% (ten per cent) for non-residential properties.
The Amending Law grants the Ministry of Finance (the “MoF”) the authority to establish a tax incentive at a 5% (five per cent) rate for taxpayers who make advance payments on account of the tax. The incentive is intended to encourage taxpayers to timely file their tax returns and make payments on account of the tax.
In line with Egypt’s digital transformation agenda and subject to the provisions of Law No. 18 of 2019, which regulates the use of non-cash payment methods, the Amending Law requires that all real estate tax liabilities, including late payment charges, be settled through electronic payment methods in accordance with procedures to be issued by the MoF. Accordingly, receipts issued in accordance with such procedures shall constitute valid proof of payment.
In this respect, it is important to highlight that the RTA announced on its official website that the MoF, in cooperation with RTA and E-Tax, launched Egypt’s first Real Estate Tax mobile application. The application enables taxpayers to access key real estate tax services electronically without visiting tax offices.
The application allows users to file real estate tax returns, pay outstanding tax liabilities, make payments on account of tax, and submit applications for the principal residence exemption. The initiative forms part of the Egyptian government’s digital transformation strategy, with the aim of simplifying procedures, improving access to real estate tax services, and enhancing the overall taxpayer experience. It is worth noting that the mobile application was only recently launched and, accordingly, there has not yet been sufficient user feedback to assess its practical effectiveness.
The Amending Law introduces a framework allowing for the partial or full write-off of tax liabilities, including late payment charges, in the following circumstances:
Applications for tax write-off are decided by committees established by a decision of the Minister or his authorised representative. The committee must decide the application within thirty (30) days from the date of its submission or its referral by the competent tax office. The committee’s recommendations become effective upon approval by the Minister or his authorised representative. The approval decision may be withdrawn within the legally prescribed period if it is subsequently found to have been based on incorrect grounds.
The Amending Law introduces several relief mechanisms aimed at resolving outstanding real estate tax obligations, as per the following:
Taxpayers who settle outstanding real estate taxes on built properties either prior to the Effective Date or within six (6) months thereafter, extendable once for an equivalent period by the Minister, are exempt from late payment charges.
Furthermore, a cap has been introduced on late payment charges, such that they may not exceed the principal amount of the tax due.
For the avoidance of doubt, the waiver of late-payment charges referenced above constitutes a transitional measure that applies only to taxpayers who settle outstanding real estate taxes on built properties either prior to the Effective Date or within six (6) months thereafter. By contrast, the cap on late-payment charges, such that they may not exceed the principal tax amount, is a permanent provision newly introduced by the Amending Law.
The taxpayer shall be exempt from paying any real estate tax due or outstanding in respect of buildings that have not previously been inventoried, had their annual rental value assessed, or been recorded in the registers and records of the RTA, or in respect of which no tax notification has been issued, for the tax periods preceding the Effective Date. Such exemption shall apply provided that the taxpayer submits the tax return in accordance with the Real Estate Tax Law within one (1) year from the Effective Date.
The Amending Law permits the settlement of disputes pending before the Appeal Committees or the courts, at any stage of litigation, upon payment of 70% (seventy per cent) of the disputed tax amount. The taxpayer must submit a settlement application to the RTA within six (6) months from the Effective Date, extendable for an additional six (6) months by the Minister. Upon payment by the taxpayer of the prescribed percentage, the taxpayer shall be released from liability in respect of the disputed tax.
Other tax reforms
On 28 July 2026, the Income Tax Law No. 91 of 2005 was amended pursuant to Law No. 151 of 2026 (the “Amendment”) introduces certain key changes to the applicable real estate disposal tax, while leaving the core structure of the tax, including its 2.5% (two point five per cent) rate, its scope, and several existing exclusions intact.
Prior to the recent Amendment, Item 28 of the list of goods and services exempt from value-added tax (“VAT”) under the VAT Law No. 67 of 2016 included the sale and lease of vacant land, agricultural land, and residential and non-residential buildings and units.
Pursuant to the recent Amendment introduced by Law No. 149 of 2026, the scope of this exemption has been narrowed with respect to non-residential buildings and units. The exemption no longer applies to the lease of buildings and units used as independent premises for the management of a business activity, even if such premises have a commercial character and involves dealings with customers. However, an exception is made for buildings and units used as premises for religious, charitable, social, health, educational, and other activities as may be proposed by the Minister in accordance with the public interest.
Conclusion
The Amending Law represents a significant step in the continued modernisation of Egypt’s real estate tax regime. By combining greater transparency, digital filing and payment options, a more structured appeals process, and targeted relief measures and tax incentives, the Amending Law seeks to improve compliance while easing administrative burdens on taxpayers.
At the same time, the reforms place greater emphasis on timely reporting, payment, and engagement with the RTA’s procedures. Property owners should therefore review their existing positions carefully and prepare for the practical implications of the new rules.
Taken together with the other amendments to the Income Tax Law and the VAT Law, the broader reform package also signals a wider effort to refine the tax treatment of real estate disposals and lease of certain non-residential properties, while preserving the core structure of the relevant taxes. These developments reinforce the government’s commitment to modernising the tax framework, enhancing clarity, and strengthening administrative efficiency across the tax landscape affecting real estate properties.
The contributors to this article are Dr. Mohamed Fathy, Partner and Head of Real Estate, Tourism and Hospitality, Hadil Helmy, Senior Associate, and Hannah Mahran, Associate.
We are pleased to share ADSERO’s contribution to the Legal 500: Litigation 2026 Country Comparative Guide – Egypt.
This guide provides an overview of litigation laws and regulations applicable in Egypt. It outlines the methods of resolving disputes, procedural rules, and the structure of local courts. It also highlights key developments, including the digitisation of litigation proceedings, the integration of artificial intelligence, and the impact of economic reforms on commercial disputes.
Authored by Osman Mowafy, Senior Partner, Head of Dispute Resolution: Litigation; Gareer Ali, Managing Associate; Ahmed Owis, Associate; Mahmoud Magdi, Associate and Ali Shabaan, Junior Associate.
View ADSERO's contribution here.
View the full guide here.
Highlights
On 1 July 2026, the Central Bank of Egypt (the “CBE”) issued a circular addressed to banks operating in Egypt (the “Circular”), setting out the decisions adopted by the CBE’s Board of Directors (“BoD”) at its session held on 17 June 2026 and establishing a set of rules limiting banks’ investments in corporate and securitisation bonds.
The Circular was issued in the context of the CBE’s continuous monitoring of the banking sector and its developments, and in light of the recent unprecedented growth in banks’ investments in bonds. It aims to establish an effective supervisory framework for limiting the rising risks associated with this type of investment, especially risks arising from investments in real estate securitisation bonds backed by receivables arising from undelivered units.
Scope of Application
The Circular limits banks’ investments in both:
The requirements under the Circular address banks’ internal governance, concentration limits, capital treatment, due diligence, ongoing monitoring, and the interaction of bond investments with banks’ other exposures to the same obligor.
Key Requirements:
Banks must ensure that their investments in corporate bonds and securitisation bonds of each company are included within the bank’s total exposures when calculating the maximum limit for the bank’s exposures to a single client and that client and its related parties.
Banks must apply the following risk weights to their investments in corporate bonds and securitisation bonds:
| Credit rating of long-term bonds | AAA | AA+ to AA- | A+ to A- | BBB+ to BBB- |
| Risk weight | 100% | 150% | 200% | 300% |
| Credit rating of short-term bonds | A-1 / P-1 | A-2 / P-2 | A-3 / P-3 |
| Risk weight | 150% | 200% | 300% |
Banks must prepare a comprehensive study on all bonds in which they intend to invest, identifying all risks that may affect the expected cash flows. Such study must include an assessment of the creditworthiness of the originating/issuing company, based on a review of the available financial and non-financial information.
Banks must put in place procedures and controls for monitoring the performance indicators of all bonds, and must prepare quarterly reports on the results, to be presented to the bank’s risk committee, which shall, in turn, submit its recommendations to the BoD.
Banks must obtain a certificate from the auditor confirming the compliance of the originating/issuing companies with the maximum ratio of the value of due instalments to the monthly income of individuals, as prescribed by the CBE pursuant to its circular dated 19 December 2019, with respect to the companies to which such limit applies.
Banks must ensure that securitisation bonds relating to real estate development companies or real estate finance companies are backed by receivables arising from units that have been actually delivered to their purchasers.
The Circular reiterates the requirement set out under the CBE’s circular letter dated 24 September 2025 to obtain a letter from the Financial Regulatory Authority (the “FRA”) prior to any placement, including the granting or renewal of credit facilities and securitisation transactions, with any company subject to the FRA’s supervision, confirming the soundness of the company’s performance, its compliance with the standards and rules governing the conduct of its activities as prescribed by the FRA, and the absence of any outstanding violations or administrative measures or sanctions.
The Circular further reiterates the requirement set out under the CBE’s credit granting rules to obtain the prior approval of the CBE before guaranteeing bonds issued by companies and institutions, together with the submission of a comprehensive study in this regard, including the cash flows of the company or institution issuing the bonds, as well as those of the originator of the securitisation portfolios.
In this regard, banks may not invest in bonds issuances in respect of which they have issued letters of guarantee for the same issuance.
Banks are granted a period of six (6) months from the date of issuance of the Circular to align their positions with the new requirements.
Implications
The Circular aims to:
Conclusion
The Circular establishes a comprehensive supervisory framework governing banks’ investments in corporate bonds and securitisation bonds, combining board-approved internal policies and concentration limits with rating-based risk weights, a minimum credit rating requirement, enhanced due diligence, and ongoing monitoring and reporting obligations. The Circular is expected to strengthen prudential oversight of banks’ bond investment portfolios while mitigating concentration, credit and delivery risks associated with such investments.
The contributors to this article are Hossam Gramon, Partner and Head of Banking and Project Finance, Nour Osama, Associate, and Karim Madian, Junior Associate.
Check out our latest interview in which our newly joined Senior Partner, Dr. Ziad Bahaa-Eldin, Head of the Financial Regulatory and Capital Markets Department, speaks to The Enterprise Company about why modern financial transactions require an integrated legal approach, the true meaning of legislative reform for investor predictability, and his macroeconomic outlook on Egypt's resilience amid global shocks.
To read the full article, click here.
We advised Tawasoa for Factoring on the successful completion of its capital increase and its subsequent transfer from the SMEs Market to the Main Market of the Egyptian Exchange (EGX).
This transaction marks a significant milestone in Tawasoa for Factoring’s growth trajectory, reflecting the company’s strong performance, continued expansion, and commitment to enhancing its position within the Egyptian non-banking financial services sector. The transfer to the Main Market further enhances the company’s market presence and provides access to a broader investor base.
The transaction was led by Ahmed Adib, Partner, and Ibrahim El Messery, Counsel, with the support of Dr. Ahmed Abdelgawad, Partner and Co-Head of M&A and Capital Markets; Ehab Feda, Partner and Head of General Corporate; Hussien Moustafa, Managing Associate; and Abdelrahman Amgad, Associate.
We extend our congratulations to Mohamed Zaghloul, Samer Daoud, Hussein Sedky, and Ahmed El Sayed, as well as our appreciation to all stakeholders who contributed to the successful execution of the capital increase. We congratulate Tawasoa for Factoring on this important achievement and look forward to witnessing its continued success and growth in the Egyptian capital markets.
For more information, check out EGX’s coverage here.
The Egyptian Ministry of Labour issued two (2) ministerial decrees published in the Egyptian Gazette on 17 May 2026, both entering into force on 18 May 2026:
This publication is a brief overview of the labour law no. 14 of 2025 (the “Labour Law”)supplementary decrees and should not be treated as a legal advice or relied upon in any manner whatsoever. Separate legal advice should be sought where appropriate.
In line with Article 53 of the Labour Law, the WEDecree confirms once again that all Labour Law provisions applicable to the working conditions of employees shall equally apply to women without discrimination. It also expressly reiterates the principle of equal pay for work of equal value, encompassing all forms of wages and their components, including cash and in-kind benefits, bonuses, incentives, and allowances.
Employers are prohibited from assigning female employees work involving risks that may affect their reproductive health, pregnancy, fetuses, or children’s health during protected pregnancy and breastfeeding periods. Prohibited work under the WE Decree includes chemical, physical, biological, and engineering hazards. The WE Decree lists all categories of work that fall under these hazards.
Notwithstanding the above prohibitions, and without prejudice to their statutory maternity rights, women may be employed during pregnancy and breastfeeding in administrative and supervisory roles that do not involve exposure to the risks set out above.
The WE Decree provides that female employees who are not pregnant or breastfeeding may work in the above-mentioned prohibited jobs, provided that all occupational health and safety requirements are satisfied.
In the event of failure to implement the prescribed occupational safety and health precautions, the competent administrative authority may order the full or partial closure of the establishment or the suspension of machinery until the source of danger is eliminated.
Employers are required to provide an alternative daytime shift arrangement in lieu of night shift for female employees in the following cases:
A Central Coordinating Labour Market Observatory within the Ministry of Labour (the “Central Observatory”) is to be established to support employment policies through labour market data, coordinate regional observatories, and help align education and training outcomes with labour market needs.
The Central Observatory is tasked with several functions, including but not limited to:
Each regional Labour Market Observatory shall be managed by a steering committee comprising representatives from relevant public, private, industrial, and academic entities, and an executive committee responsible for operational implementation, with the possibility of including representatives from other concerned bodies where necessary.
The LMO Decree further provides for the establishment of an executive committee for each Regional Labour Market Observatory, headed by a specialist and composed of representatives from the relevant entities, to carry out the observatory’s activities and functions in coordination with its members, with its formation to be issued by a decision of the Director of the Labour Directorate.
The LMO Decree imposes certain obligations on the Ministry of Labour, other ministries, and relevant governmental authorities, including the following:
Also, the LMO Decree imposes certain obligations on the Investors’ Association and the Businessmen’s Association including, but not limited to, the following:
The LMO Decree provides that the Training and Qualification Financing Fund established under the Labour Law shall finance the establishment and operation of the observatories (central and regional), subject to the Board of Directors (“BoD”) approval.
The Central Observatory’s resources are derived from multiple sources, including allocations identified through cooperation with the Training and Qualification Funding Fund, funds allocated by the BoD, and fees generated from approved labour market research and studies.
Additional funding includes accepted grants, donations, and subsidies approved by the BoD, revenues from the publication of research and studies, as well as other financing sources from partner entities or development projects, subject to the BoD’s approval.
Also, the LMO Decree specifies permitted expenditure categories, including but not limited to, office supplies and operational requirements, field visit costs such as transportation, accommodation, and subsistence, and communication expenses and telephone and internet).
The LMO Decree assigns the General Administration for Labour Market Information to monitor the performance of observatory staff, assess their training needs, and propose capacity-building programmes in line with actual requirements and new assigned tasks.
Additionally, the LMO Decree provides for the establishment of administrative and technical committees or working groups, as required by the volume of work, operational needs, and its development, to assist in preparing the work of the Central Observatory’s BoD, follow up on the implementation of its decisions and recommendations, and coordinate among the partner entities.
With respect to the WE Decree, employers operating in manufacturing, industrial, chemicals, petroleum and petrochemicals, mining and quarrying, construction, healthcare, logistics, agriculture, leather and tanning, meat processing, glass, metals, rubber, shipbuilding, energy and utilities, and related sectors should review occupational health and safety compliance, pregnancy and maternity policies, shift scheduling practices, transportation arrangements for female employees, and labour inspection preparedness to ensure compliance with the Labour Law provisions.
On the other hand, the LMO Decree strengthens employers’ role in labour market governance by involving them in data sharing, consultations, and decision-making through structured institutional mechanisms. It also improves their access to labour market information and sets clearer expectations for participation in training, research, and policy implementation to better align workforce needs with education and skills development.
The WE Decree establishes a more structured regulatory framework governing female employment conditions in Egypt, particularly regarding hazardous work environments and night work. The latter decree further imposes enhanced compliance obligations on employers while reinforcing equal treatment principles and maternity related protections under Egyptian labour law.
The LMO Decree establishes a coordinated system linking the central and regional labour market observatories with relevant public and private stakeholders to collect and analyse labour market data and issue reports. It aims to improve coordination, support skills matching, and ensure employment policies are based on reliable labour market information.
The contributors to this publication are Alia Monieb, Partner - Head of Employment, Seif El Kably, Managing Associate, Khaled Omar, Associate, Hoda Khira, Associate, and Seif Eldin Hamad, Junior Associate.
We advised Nile Sugar on its senior loan agreement with the IFC - International Finance Corporation. The financing will fund the cultivation of 13,711 feddans of sugar beet in Minya. This project advances Egypt’s 2030 agricultural targets and boosts domestic sugar production to counter global price swings.
The transaction was led by Hossam Gramon, Partner and Head of Banking and Project Finance and Dr. Mohamed Fathy, Partner and Head of Real Estate, Tourism, and Hospitality, assisted by Hadil Helmy, Senior Associate, Hussien Moustafa, Managing Associate, Nour Osama, Associate, and Karim Madian, Junior Associate.
We extend our congratulations to Emad Farid, Chief Executive Officer, and Rafik Joseph, Chief Financial Officer at Nile Sugar, on this achievement.
Pleased to have worked alongside the IFC and Baker McKenzie Cairo - Helmy, Hamza & Partners on this transaction.
For more information, check out the Enterprise's coverage here.
The Decree takes effect on 3 April 2026, with the remote work requirement to be implemented beginning Sunday 5 April 2026.
The provisions of the Decree apply to all establishments and entities subject to the Labour Law. Employers, whether natural or legal persons, must comply with its provisions.
Employers in the sectors specified below, must implement a remote work system on Sundays of every week, beginning Sunday, 5 April 2026, provided that business operations are not disrupted.
The remote work requirement applies primarily to establishments operating in:
The obligation further extends to administrative functions across all other sectors and activities, including HR, accounting, legal affairs, and office/administrative services, where remote work does not affect operational continuity.
Notwithstanding the above, employees working in the following establishments and sectors are exempt from the application of this Decree and may continue to operate as required:
The Decree does not prejudice existing employee rights, wages, or benefits provided under applicable laws, regulations, collective agreements, or employment contracts.
The Decree does not expressly prescribe penalties for non-compliance. However, employers remain subject to the general enforcement framework under the Labour Law.
Accordingly, failure to implement the remote work requirement may expose employers to:
In addition, the Decree establishes a technical committee chaired by the Minister of Labour tasked with monitoring implementation and submitting weekly reports to the Prime Minister, which may result in increased regulatory scrutiny.
While the Decree does not currently provide specific sanctions, employers are advised to comply with its requirements given the authorities’ supervisory powers and the possibility of further implementing measures or enforcement guidance.
We are thrilled to announce ADSERO’s ranking in the Legal 500 EMEA 2026 edition.
Firm Rankings:
- Corporate, Commercial, and M&A: Tier 1
- Dispute Resolution: Litigation: Tier 1
- Projects & Infrastructure: Tier 1
- Energy: Tier 2
- Employment: Tier 2
- Banking & Finance: Tier 2
- TMT: Tier 2
Furthermore, we are delighted to highlight the recognition of our leadership members in their respective fields:
Leading Partners:
- Ragy Soliman – Corporate, Commercial, and M&A
- Osman Mowafy – Dispute Resolution: Litigation
- Ahmed Abdelgawad – Corporate, Commercial, and M&A
- Mohamed Abdelgawad – Corporate, Commercial, and M&A
- Hossam Gramon – Banking & Finance
Next Generation Partners:
- Alia Monieb – Employment
- Malak Khalil – Energy
Leading Associates:
- Dina Sherif – Corporate, Commercial, and M&A
- Karima Seyam – Banking & Finance
We extend our sincere gratitude to our clients for their continued trust and to our exceptional team for their hard work and dedication.
To explore our full rankings, client testimonials, and more ,click here.
To view our full rankings and editorial coverage
As part of the implementation of Egypt’s labour law no. 14 of 2025 (the “Labour Law”), the Ministry of Labour continues to issue supplementary decrees to clarify and support its application.
This article outlines the key provisions under the following decrees:
Decree no. 48 of 2026 regulating the framework governing the provision of childcare services for employees’ children in connection with the workplace (the “Nursery Decree”);
decree no. 49 of 2026 establishing the categories of hazardous, difficult, and remote work (the “Hazardous Work and Remote Areas Decree”); and
decree no. 50 of 2026 regulating child employment and training (the “Child Employment Decree”).
This publication is merely a brief overview of the Labour Law’s supplementary decrees and may not be treated as a legal opinion or relied on in any manner whatsoever. Separate legal advice should be sought, where appropriate.
1. Nursery Decree
On the 3rd of March 2026, the Ministry of Labour issued the Nursery Decree introducing a comprehensive framework governing the provision of childcare services for employees’ children in connection with the workplace. The decree was published on the 18th of March 2026 with an effective date of 19 March 2026.
The Nursery Decree is issued pursuant to the Labour Law and complements existing legislation regulating nurseries and child welfare, including Law No. 50 of 1977 on Nurseries and the Child Law No. 12 of 1996 and its Executive Regulations.
The Nursery Decree aims to enhance employee welfare, particularly for working mothers by ensuring access to safe, regulated, and accessible childcare facilities.
The Nursery Decree applies to all employers subject to the Labour Law, with specific obligations determined based on the number of female employees at a single workplace.
The obligation applies to female employees with children up to the age of four (4), in line with the Child Law.
For the purposes of the Nursery Decree:
The Nursery Decree introduces the following key obligations and regulatory requirements:
Workplace nurseries must:
All nurseries must comply with the applicable legal and licensing requirements, including regulations related to location, construction, health, and safety, and must obtain approval from the Ministry of Social Solidarity. Workplace nurseries are also subject to the general regulatory framework governing nurseries under the Child Law and the Nurseries Law.
Employees benefiting from nursery services must contribute as follows:
For any additional children beyond the third, the employee bears the full cost of care.
Where it is not feasible to establish a nursery, employers may:
2. Hazardous Work and Remote Areas Decree
The Ministry of Labour issued the Hazardous Work and Remote Areas Decree on the 3rd of March 2026, setting out the categories of hazardous, difficult, and remote work that entitle employees to the additional seven (7) days of annual leave, as stated under the Labour Law.
The Hazardous Work and Remote Areas Decree is issued pursuant to the Labour Law and aligns with Egypt’s international labour commitments. It provides a detailed and sector-specific framework identifying the types of work and geographic areas that warrant enhanced leave entitlements due to their nature or conditions.
The Hazardous Work and Remote Areas Decree applies to all employers and employees subject to the Labour Law, specifically:
Employees engaged in specified hazardous, difficult, or health-damaging activities across various sectors; and
Employees working in officially designated remote areas.
The Hazardous Work and Remote Areas Decree provides an extensive list of industries and activities considered hazardous, difficult, or harmful to health, including:
Manufacturing Sector:
Extractive Industries:
Energy and Radiation Sector:
Agriculture and Agricultural Research:
Healthcare Sector:
Construction Sector:
Employees working in designated remote areas are also entitled to an additional seven (7) days of annual leave.
Key remote areas include:
3. Child Employment Decree
The Child Employment Decree establishes a comprehensive framework governing the employment and training of children in Egypt. It regulates (i) the minimum age requirements, (ii) permissible working conditions, (iii) prohibited activities and sectors and (iv) employer compliance and monitoring obligations.
For the purposes of the Child Employment Decree, a child is defined as any individual who has not reached eighteen (18) years of age.
The Child Employment Decree further provides that children may not be employed before completing basic education or before reaching the age of fifteen (15) years, whichever is greater. However, it permits training from the age of fourteen (14), provided that such training is conducted in a manner that does not expose the child to risk or harm.
The Child Employment Decree imposes strict prohibitions on the employment or training of children in hazardous activities or environments. In particular, children may not be engaged in any work that could endanger their physical or psychological health, compromise their safety or morals, or interfere with their education. It also expressly prohibits the worst forms of child labour, as reflected in international conventions ratified by Egypt.
In addition, the Child Employment Decree contains a detailed schedule identifying specific categories of hazardous or prohibited work in which childred under the age of 18 are not permitted to work or receive training. These notably include industries and activities involving exposure to hazardous substances, such as chemical manufacturing and handling; heavy industrial operations, including metalworks and machinery-intensive processes; extractive industries such as mining and quarrying; and environments involving high temperatures, excessive noise, or dangerous equipment. The schedule also captures activities involving biological, chemical, or physical risks, as well as work performed in confined, elevated, or otherwise inherently dangerous settings.
The Child Employment Decree introduces strict limitations on working hours and conditions for children who are legally permitted to work.
In terms of leave entitlements, the Child Employment Decree provides that child employees are entitled to annual leave exceeding that of adult employees by seven (7) days.
Under the Child Employment Decree, employers engaging or training children are subject to a range of compliance obligations, including but not limited to the following:
Furthermore, employers who engage or train children are subject to numerous administrative and reporting obligations. For example, employers must:
The contributors to this article are Alia Monieb, Partner - Head of Employment; Hana Abouelmagd and Seifeldin Hamad, Junior Associates.
We are pleased to share our most recent report highlighting the critical decisions issued by the Board of Directors of the Financial Regulatory Authority (FRA) during the second half of 2025.
To access the second issue, click on the attachment below.
Introduction
Further to our previously published update on Egyptian Drug Authority (the “EDA”) decree no. 161 of 2025 governing the unified coding of pharmaceutical products and medical supplies in Egypt (the “Decree”), and the publication regarding the complementary decree no. 475 of 2025 (the “Complementary Decree”) regarding the establishment and operation of a national system for tracking human and biological pharmaceutical products (“System”); the EDA issued Decree No. 804 of 2025 on 18 December 2025, which sets out the Complementary Decree’s implementation guidelines governing the operation of the System (“Guide”).
Scope of Application and Exclusions
It should be noted that each of the above exclusions remains subject to the relevant regulatory controls applicable thereto.
Key Provisions
Purpose
The System is designed to electronically record and track each pharmaceutical product pack across its full supply chain, starting from manufacturing and importation up to dispensing to the patient, using international standards, notably the Electronic Product Code Information Services (“EPCIS”). The System aims to ensure transparency and product safety.
Major Obligations
Timeline
1. The System shall apply as follows:
i) on imported fully finished pharmaceutical products: as of 1 February 2026; and,
ii) on primary and/or secondary bulk imported and locally manufactured pharmaceutical products: as of 1 August 2026.
This is subject to the System implementation timeline issued by the EDA’s chairman.
Pharmaceutical products produced or imported by, maximum, the above-mentioned dates shall remain on the market until consumption.
2. Pharmaceutical products produced or imported by, maximum, the above-mentioned dates shall
remain on the market until consumption.
Non-Compliance Consequences
The EDA’s inspection department may take legal measures, including seizure, destruction of pharmaceutical products, written warnings with correction deadlines, temporary suspension of trading and importation, and the imposition of fines, against infringing pharmaceutical products set forth under Article 5 of the Complementary Decree, that are produced or imported after 1 February 2026 and 1 August 2026, as applicable.
The contributors to this article are: Fagr Moheb, Senior Associate and Alaa’ Elmekhashen, Junior Associate.
Egypt’s primary data privacy framework was established with the issuance of the personal data protection law no. 151 of 2020 (the “PDP Law”), marking a significant legislative step towards regulating personal data practices in Egypt. While the PDP Law set out the core principles governing the protection and processing of personal data, including obligations for controllers and processors, the rights of data subjects, and regulating cross-border transfers, its application remained suspended pending the issuance of the Executive Regulations (the “ER”), which were required to bring the law into force.
Following a prolonged period of regulatory inactivity and uncertainty for stakeholders already engaged in the processing of personal data, the ER were finally issued pursuant to Ministerial Decision No. 81 of 2025, thereby activating the PDP Law and rendering its provisions operational. The ER were published in the Official Gazette on 1 November 2025 and were subsequently made publicly available on 25 December 2025.
Personal Data Protection Centre
The PDP Law previously introduced the Personal Data Protection Centre (the “PDPC”) as the competent authority responsible for implementing the PDP Law by regulating and supervising personal data processing activities in Egypt. Under the PDP Law, the PDPC is tasked with overseeing compliance, issuing licences and permits, developing regulatory policies and standards, and exercising enforcement powers. As the primary data protection regulator, the PDPC plays a central role in implementing the PDP Law, a role that has now been operationalised through the ER.
The PDPC continues to hold significant supervisory responsibilities, including ensuring that parties obtain the required licences and permits, with the duration and costs now specified under the ER. Additionally, parties must implement PDPC-approved mechanisms that enable data subjects to exercise their statutory rights.
The PDPC has also issued a series of preliminary guidelines on various topics, including consent, legal bases for processing, records of processing activities, and Data Protection Officers ( “DPO”) and their categories. It has further published guidelines concerning privacy notices. These resources are intended to assist stakeholders in understanding and complying with the PDP Law and the ER.
Licensing
The PDP Law briefly stated that entities collecting personal data should be duly licensed by the PDPC. Building on the PDP Law, the ER proved detailed guidance on the classification and categories of licences and permits, as well as the conditions applicable to controllers and processors of Sensitive Personal Data. This includes setting out licensing procedures and fees for cross-border data transfers, direct electronic marketing, and the use of visual surveillance means in public places, alongside rules for renewal of such licences and permits. Furthermore, the ER introduce a formal accreditation scheme for natural or juristic persons, enabling them to qualify to provide consultations in the field of personal data management and protection. This scheme sets out eligibility criteria, conditions, and procedures for obtaining accreditation.
A clear distinction is drawn between licences and permits. Licenses are granted on an ongoing basis to authorise continuous processing of personal data. Permits, on the other hand, are issued to controllers and processors for specific and temporary purposes, for varying periods not exceeding one (1) year.
Limited exceptions are also introduced regarding fees, including a key exemption from licensing fees for controllers and processors handling one (1) to one-hundred thousand (100,000) records, and an exemption from permit fees for personal data records ranging between one (1) to twenty-five thousand (25,000) records.
Consent
The ER set out detailed requirements governing consent as a lawful basis for processing personal data. In this regard, valid consent must be personal (provided directly by the data subject or by their authorised legal representative), explicit, informed, freely given, and limited to specific, clearly defined processing purposes.
At a minimum, consent obtained from the data subject must at least clearly cover the following information:
Further, the ER mandates that consent must be stored in a secure electronic register, including the date of such consent and the form in which it was provided.
The provision of personal data by a data subject for the purpose of receiving legitimate services or transaction shall be deemed to constitute valid consent to obtain and process the data for that purpose. Such data may not be used for other purposes without prior consent.
It is important to note that the processing of Sensitive Personal Data is subject to stricter requirements, whereby consent in such cases must be in writing, either on paper or electronically.
Electronic Records
There is an additional mandate to maintain electronic logs (records of processing activities) documenting all actions performed on personal data. The PDPC reserves the right to inspect all data-handling entities through its inspectors, acting in their capacity as judicial officers to review these electronic logs and verify compliance with standard benchmarks and technical procedures for data security and protection.
Enhanced Regulatory Oversight for Sensitive Personal Data and Children’s Data
The ER provides detailed regulatory controls for processing Sensitive Personal Data. Further, children’s data is expressly treated as a heightened category of Sensitive Personal Data, subject to age-based consent requirements and specific restrictions on use.
New Breach Notification Requirements
The ER specifies strict timelines for notifying the PDPC in the event of data breaches: seventy-two (72)-hour notification in general cases, while immediate notification where national security is implicated. The controller/processor then notifies the affected Data Subject of the breach three (3) business days after notifying the PDPC. The ER further introduces requirements for corrective and preventive measures, therefore emphasising the importance of incident response documentation.
DPO Extensive Framework
Beyond the PDP Law’s requirement to appoint a DPO, the ER introduces an exhaustive regulatory framework governing DPO appointment, registration, and replacement procedure. The DPO must hold academic qualifications or professional certifications and possess practical experience in relevant fields in accordance with the standards approved by the PDPC. In addition, the DPO must pass tests approved by the PDPC in accordance with the nature and volume of personal data activities.
The PDPC will also maintain an electronic registry in which DPOs must be recorded. Guidelines relating to DPOs have been published by the PDPC to assist stakeholders in meeting these requirements.
Cross-Border Transfer of Personal Data
The ER set out mechanisms for governing cross-border data transfers, requiring prior authorisation from the PDPC and compliance with conditions relating to the destination, purpose, type of data, security measures, and storage.
A licence or permit must be obtained from the PDPC for any cross-border transfers. Transfers are only permitted to countries specified in the licence or permit, which must be updated if additional countries are included. The ER also introduces an adequacy assessment for cross-border transfers. Such adequacy is evaluated on a case-by-case basis and will be included in the licensing decision, not presumed by law.
Personal Data Representative
Controllers based outside Egypt must appoint a representative or agent within the country, via a branch, office, or other authorised means, who will be accredited by the PDPC for the duration of the licence or permit.
Direct Electronic Marketing
While the PDP Law recognised direct electronic marketing as a lawful processing activity, it did not previously provide any guidance or details on how such activities should be conducted. Accordingly, (prior to the issuance of the ER), entities faced uncertainty regarding how to carry out marketing practices in compliance with the PDP Law.
The ER clarify that direct electronic marketing includes social media, emails, SMS, mobile calls, or any other technical means, and may only be carried out with a licence or permit from the PDPC. The ER also set out rules requiring that all marketing communications be conducted only with the prior, explicit, and informed consent of the data subject, with clear identification of the sender and the marketing purpose. It further requires that controllers, processors, and marketing intermediaries must maintain full electronic records of consent, respect withdrawal requests, and ensure personal data is only used for the declared marketing purpose.
In addition, a separate regulatory framework is introduced for granting access to personal data to foreign controllers or processors, also requiring prior licensing by the PDPC and confirmation that equivalent data protection standards apply.
Concerned Entities
The ER apply broadly to any natural or juristic person involved in the collection, processing, storage, or transfer of personal data in Egypt. This includes controllers, processors, marketing intermediaries, consultants, and any stakeholders engaged in activities covered under the PDP Law and ER, such as direct electronic marketing, surveillance in public spaces, or cross-border data transfers. Foreign entities processing or accessing Egyptian personal data are also subject to the regulatory framework and must comply with any licensing requirements imposed by the PDPC.
Sanctions
Non-compliance may expose entities to administrative sanctions, financial penalties, or enforcement actions by the PDPC. Stakeholders are, therefore, encouraged to review the full scope of the ER and implement measures to integrate these obligations into their operations within the grace period.
Grace Period for Compliance
The PDP Law provides for a one (1) year grace period commencing from the issuance of the ER, during which entities are expected to align their operations with the new requirements. On a strict reading, this transitional period would expire on 31 October 2026 based on the Official Gazette publication date. However, it remains unclear whether the competent authorities will calculate the grace period from the formal publication date or from the date which the ER were made publicly accessible, and further clarification on this point is expected.
The contributors to this article are Darah Zakaria, Counsel and Head of TMT; Hana Koptan, Associate; and Junior Associates Habiba Tarek and Marwan Awny.
As part of the implementation of Egypt’s labour law no. 14 of 2025 (the “Labour Law”), the Ministry of Labour continues to issue supplementary decrees to clarify and support its application.
This article outlines the key provisions under the following decrees:
This publication is merely a brief overview of the Labour Law’s supplementary decrees and may not be treated as a legal opinion or relied on in any manner whatsoever. Separate legal advice should be sought where appropriate.
The Foreign Work Permit Decree regulates the licensing and regulation of foreign nationals’ employment in Egypt.
The Foreign Work Permit Decree sets out the rules governing the issuance, renewal, amendment, and cancellation of work permits, the obligations of employers, applicable restrictions and exemptions, related fees, and the Ministry of Labour’s supervisory and enforcement powers, thereby implementing the foreign employment provisions of the Labour Law.
Previously, under the Labour Law, the employment of foreign employees in Egypt was generally governed by Ministerial Decree No. 146 of 2019, which set out the conditions of foreigners work permits; and Ministerial Decree No. 485 of 2010, which regulated the applicable procedures (together, the “Decrees”).
The Foreign Work Permit Decree mainly applies to the employment of foreign nationals in all establishments across the private and public sectors.
It is important to note that, for the purpose of implementing the Foreign Work Permit Decree, the term “work” has been broadly defined, in line with the Labour Law, to include subordinate employment, self-employment, work for one’s own account, professional activities, trades, crafts, and domestic work.
The Foreign Work Permit Decree sets out detailed rules governing the licensing of foreign nationals, beginning with general requirements and extending to exemptions, quotas, fees, monitoring, and enforcement.
Certain key provisions under the Decrees have been retained, while others have been amended or newly introduced. The retained provisions include, among others:
The Foreign Work Permit Decree sets out the procedures, conditions, and applicable fees for applying for and renewing work permits for foreign nationals, including the following:
Employers are required to notify the competent authority of, among others:
In addition, establishments employing foreign nationals are required to:
Even though the Foreign Work Permit Decree maintains the Legal Percentage, it sets out specific, new, and clear exceptions to this cap. These include small establishments, such as shops and restaurants, which are subject to a separate maximum limit for foreign labour, to be determined by the competent authority, taking into account incentive initiatives launched by the Ministry of Labour following submission by the competent administration.
The Foreign Work Permit Decree continues to subject short-term and task-based work to a special fee regime; however, it now expressly defines and limits such engagements to a maximum duration of fourteen (14) days, whether completed in a single day or over several days. This clarification effectively resolves the previous ambiguity surrounding the meaning of “few days” under Article 4 of Decree No. 146 of 2019 and confirms that the exemption regime is limited to assignments of up to fourteen (14) days only.
Where an establishment seeks to engage a foreign national for such work, it is required to submit a request to the competent authority and pay a fee calculated at 10% (ten per cent) of the foreign national’s remuneration for the relevant work, subject to a minimum fee of EGP 15,000 (fifteen thousand Egyptian pounds) and a maximum fee of EGP 100,000 (one hundred thousand Egyptian pounds), applicable to foreign nationals of all nationalities. The applicable fee is payable separately for each task performed by the foreign national.
The Foreign Work Permit Decree expressly prohibits the foreign national from commencing such work prior to obtaining written approval from the Ministry of Labour.
The Collective Labour Disputes Decree regulates in detail the conciliation of collective labour disputes under the Labour Law, setting out its rules and procedures.
Collective Labour Dispute is defined as “any dispute that arises between an employer or a group of employers or their organisations, and all the employees of the establishment or a group of them or their relevant trade union organisations, concerning the terms of work, its conditions, or employment.”
Applications for conciliation may be submitted by either the employee or employer. Said decree specifies the information that must be included in the conciliation application, as well as the supporting documents required, including copies of minutes reflecting the negotiation sessions that took place, reflecting discussions, claims, and defences of each party.
The collective dispute resolution unit within the Labour Directorate (the “Unit”) is empowered to actively manage negotiations, propose compromises, and prevent escalation. The parties to the dispute are restricted from adopting any decision or procedure related to the subject-matter of the dispute during the conciliation phase, except in emergencies and provided that the same is temporary.
The Collective Labour Disputes Decree places particular emphasis on maintaining the confidentiality of the conciliation process, protecting the interests of employees, the trade union, and their representatives.
Conciliation requests should be submitted following the lapse of at least one (1) month from the date the collective negotiations have started without any agreement between the parties.
The parties to the dispute must submit any requested documents, whether by the Unit or the other party.
The results of conciliation may be either:
The Workforce Reduction Decree sets out the rules governing employee selection in cases of partial closure or workforce downsizing due to economic, technical, or organisational reasons stated under the Labour Law.
In the absence of a collective agreement determining objective selection criteria, employers are required to engage in consultations with the competent trade union, if any, for a minimum of seven (7) working days after issuing the establishment’s decision and before its implementation.
When selecting employees, employers must apply transparent, objective, and non-discriminatory principles, balancing business needs with employees’ social and family circumstances.
Additionally, key selection criteria include giving priority to employees, taking into account:
Employers must, as part of the workforce reduction process:
The Ministry of Labour issued the Skill Measurement and License Decree, establishing a national framework for issuing both a certificate measuring skill levels and a permit licensing the practice of professions and crafts across Egypt. Said decree sets out the procedures for skill assessment, issuing permits, and workplace compliance, with implications for both individuals and employers.
In general, individuals practicing the listed professions, trades, or crafts included under the decree must submit a request to obtain a skill measurement certificate and, subsequently, a practice license issued by the competent Labour Directorate, subject to defined tests, fees, and timelines (“License”). The Skill Measurement and License Decree provides for few partial or full exceptions that may apply.
Skill levels are classified across five (5) grades, ranging from assistant employee to specialised technician or trainer.
Employers are subject to enhanced workplace compliance obligations, including:
It is worth noting that employers may engage employees without obtaining the License, provided that their status is reconciled with the applicable legal requirements and the License is obtained within a period not exceeding three (3) years from the date of issuance of the Skill Measurement and License Decree.
In all cases, employees who have been employed by the employer for a period exceeding one year prior to the issuance of the Labour Law shall be exempt from the requirement to obtain such License.
The contributors to this article are Alia Monieb, Partner - Head of Employment; Rawan Roshdy, Managing Associate; Hana Abouelmagd and Seifeldin Hamad, Junior Associates.
