The Egyptian real estate sector is undergoing a potential regulatory shift in the nature of the relationship between real estate developers (the “Developer(s)”) and unit purchasers (the “Purchaser(s)”). As a matter of principle, the sale of real estate units (the “Units”) is treated as a civil matter governed by the Egyptian civil code no. 131 of 1948 (the “Egyptian Civil Code”); however, recently, the regulatory framework governing the relationship between Developers and Purchasers has evolved through the application of the Egyptian consumer protection law no. 181 of 2018 (the “CPL”) to such a relationship instead of relying exclusively on the Egyptian Civil Code.
This legal evolution was triggered by a growing trend of Purchasers submitting complaints against Developers before the Consumer Protection Agency and by the judicial interpretation of products (the “Product(s)”) and consumers (the “Consumer(s)”) by the Egyptian courts under the CPL.
The Egyptian Court of Cassation (the “Court”) has adopted two distinct judicial approaches in this respect. Accordingly, this article will be divided into three sections, which will cover:
The CPL referred to the Units in only a limited number of provisions, namely:
Accordingly, and in light of the absence of an express provision under the CPL classifying the Units as Products and the Purchasers as Consumers, uncertainty has arisen as to whether the Units fall within the scope of the CPL. In this regard, the Court has adopted two distinct judicial approaches through recent judgments issued in 2023, 2024, and 2025, as follows:
In its judgments issued in 2023 and 2024[1], the Court adopted the approach that the sale of the Units is viewed as a purely civil matter that falls outside the scope of the CPL and is subject to the contractual arrangement between the parties. The Court built its rulings on the following grounds:
Conversely, the Court adopted a contradictory approach in its judgments rendered in 2025[2], ruling that real estate sales contracts shall be governed by the provisions of the CPL rather than relying exclusively on the Egyptian Civil Code. The Court grounded its rulings on the following bases:
The application of the CPL to real estate sales contracts would introduce a number of fundamental legal implications, including, without limitation, the following:
The conflicting approaches adopted by the Court have resulted in legal uncertainty regarding the classification of the Units as Products and the Purchasers as Consumers. Consequently, we believe that these divergent precedents could be harmonised to safeguard the stability of the real estate market.
Such harmonisation can be achieved through either of the following mechanisms:
The lack of explicit classification for the Units under the CPL has led to questions regarding its application to real estate sales contracts, resulting in conflicting rulings from the Court. Although the recently issued judgments of the Court are widely followed and cited, they do not constitute legally binding precedent for future cases. Egyptian courts therefore retain discretion to adopt either of the approaches described above. Accordingly, legislative or judicial intervention is recommended, whether by amending the CPL, enacting a dedicated real estate development law, or issuing a unified ruling through the General Assembly of the Court.
The contributors to this article are Dr Mohamed Fathy, Partner – Head of Real Estate, Tourism and Hospitality; Shaimaa Abdelhakim, Senior Associate; Ahmed Yasser, Associate; and Ziad Nasr, Junior Associate.
[1] Court Judgement No. 12220 of 92 JY, Hearing Dated 18/12/2023 and Court Judgment No. 19491 of 92 JY, Hearing Dated 24/04/2024.
[2] Court Judgement No. 9018 of 94 JY, Hearing Dated 02/06/2025 and Court Judgment No. 18424 of 93 JY, Hearing Dated 07/04/2025.
We are pleased to share our latest report highlighting the laws and decrees issued in the first quarter of 2026.
To access the report, click on the attachment below.
If you are interested in acquiring a copy of the legislation and keen on remaining up to date with the most recent laws and decrees, sign up here.
We are pleased to share ADSERO - Ragy Soliman & Partners' contribution to the Q2 edition of the Global Guide Quarterly (GGQ), published by Littler Mendelson. The GGQ is a quarterly newsletter offering concise coverage of key developments in labour and employment law across the Americas, Asia-Pacific, Europe, the Middle East, and Africa.
Our insights are provided by Abdalla Shohdy, Managing Associate, and Seifeldin Hamad, Junior Associate.
View ADSERO's contribution here.
View the full guide on Littler here.
Following the launch of our quarterly publication series, we are pleased to share the second issue of ADSERO’s Egyptian Labour Law Newsletter, providing valuable insights into key regulatory updates relevant to our clients and the broader business community.
Our Q2 2026 issue, authored by Alia Monieb, Partner – Head of Employment, Seif El Kably, Managing Associate, and Hoda Khira, Associate, provides a comprehensive overview of the recent implementing decrees issued pursuant to Labour Law No. 14 of 2025. This edition highlights the latest labour law developments, including the implementation of mandatory remote working arrangements, the establishment of Labour Market Observatories, and the new framework governing the employment of women.
Through this series, we aim to share our team’s expertise and contribute to informed discussions on Egypt’s evolving labour landscape.
To read the full update, click here.
Overview
On 21 July 2026, Egypt’s Ministry of Investment and Foreign Trade issued a public reminder to “all companies and establishments” of two (2) recurring, periodic filing obligations owed to the General Authority for Investment and Free Zones (“GAFI”). This publication summarises the obligations, confirms their legal basis, and sets out what they mean in practice for companies operating in Egypt.
What Has Been Announced
The Ministry of Investment and Foreign Trade frames both obligations as supporting accurate, up-to-date economic data to underpin investment decisions, and states that timely, accurate compliance is not merely a legal formality but also contributes to a stronger investment climate and improved government services to investors.
Legal Basis
What This Means for Companies
Suggested Next Steps
ADSERO is available to assist with entity-by-entity applicability assessments, GAFI proxy arrangements, and the design of an internal filing calendar.
The contributors to this publication are Ehab Fedaa, Partner and Head of General Corporate, and Managing Associates Hussien Moustafa and Malak El-Alfi.
Disclaimer: This publication is provided by ADSERO – Ragy Soliman & Partners for general informational purposes only. It does not constitute legal advice and should not be relied upon as such. No attorney-client relationship is created by the circulation or receipt of this publication. The content is limited to Egyptian law as at the date below and does not address tax matters, which should be referred to a licensed tax advisor. Anyone considering a transaction of the kind described should seek specific advice tailored to their circumstances before taking any action.
Overview
Egypt’s Financial Regulatory Authority (the “FRA”) and the Egyptian Exchange (the “EGX”) have, over the past several months, introduced a series of reforms intended to widen the pool of companies able to access the public markets and to sharpen governance standards for those that do. Together with a new tax incentive package for newly listed issuers, these changes are prompting renewed interest from private groups, including those structured through offshore holding vehicles, in evaluating a listing on the EGX.
This article summarises the recent changes, the core listing requirements issuers should be prepared to meet, the particular considerations that arise for groups held through a foreign holding company, and the regulatory framework now available for special purpose acquisition companies (the “SPACs”).
On 10 February 2026, the FRA Board issued Decree No. 26 of 2026, amending the rules governing the listing and delisting of securities on the EGX (the “Listing Rules”). Companies were given three (3) months from issuance to align with the new requirements. Among the more significant changes:
These governance-focused amendments sit alongside a separate package of fiscal incentives announced in the first quarter of 2026. Newly listed companies that maintain their listing and meet annual revenue growth conditions are eligible for a tiered reduction in corporate income tax: 30% (thirty per cent) in the first year following listing, 20% (twenty per cent) in the second, and 10% (ten per cent) in the third. This is in addition to a waiver of capital gains tax on stock transactions, applied retroactively to June 2023 and replaced prospectively by a stamp tax on transactions. Eligibility for the tax measures is conditioned on compliance with the FRA’s listing and disclosure requirements, including quarterly reporting.
Subject to the amendments summarised above and to specific exemptions discussed below, a company seeking a primary listing of its shares on the EGX should generally be prepared to satisfy the following:
The Listing Rules provide targeted exemptions from certain of these requirements, most notably the profitability and track-record criteria, for small and medium-sized Egyptian companies and for companies established by public subscription that have not yet published two (2) years of financial statements. Given the pace of recent amendments, the precise numerical thresholds and exemptions applicable to a given issuer should be verified against the FRA’s and EGX’s current rules at the time of application.
A number of prospective issuers we advise operate their Egyptian business through an offshore holding structure above one (1) or more Egyptian operating companies. The Listing Rules are calibrated to Egyptian juridical persons, and the route available to foreign-incorporated issuers is narrow: secondary listings of foreign securities are permitted only where the issuer is already listed on a recognised foreign exchange, and in practice only a small number of foreign companies have listed on the EGX to date. For a group whose ultimate holding company is offshore and whose primary listing candidate is its Egyptian business, a pre-listing reorganisation will generally be required to interpose or elevate an Egyptian joint stock company (S.A.E.) as the entity to be listed, with the operating subsidiaries held beneath it. That reorganisation typically needs to address, among other matters: the mechanics and sequencing of transferring or contributing the offshore holdco’s interests into the new or existing Egyptian listing vehicle; unwinding or restructuring intercompany financing, guarantees and related-party arrangements between the offshore holdco and the Egyptian operating companies so that the listing entity presents a clean, auditable ownership and financing history for the two (2) years of financial statements required; foreign exchange, capital repatriation and, where relevant, golden share or strategic-sector approval considerations; and the corporate governance changes introduced by the February 2026 amendments described above, including cumulative voting, non-executive committees, and disclosure architecture. Tax structuring implications of any such reorganisation should be considered separately with the client’s tax advisors.
Egypt has had a SPAC framework in place since 2021, refined by FRA Board Decree No. 140 and 148 of 2024, which govern the licensing of SPACs as a form of venture capital company and the listing and trading of their shares on the EGX. The framework offers an alternative route to listing for groups or sponsors seeking to bring a target company to market without a conventional initial public offering (“IPO”). Key features include:
For sponsors and groups exploring a SPAC as a route to listing an Egyptian target, including a target currently held through a foreign holding structure, the restructuring considerations outlined in the preceding section will typically need to be addressed in parallel with the SPAC’s own acquisition timeline and shareholder-approval process.
ADSERO’s Capital Markets team advises issuers, sponsors, underwriters and controlling shareholders on the full range of EGX listing matters, from pre-listing reorganisations and corporate governance readiness through to prospectus drafting and FRA/EGX engagement. We would be glad to discuss how the changes summarised in this article may apply to a specific group structure or listing timetable.
The contributors to this publication are Dr Ziad Bahaa-Eldin, Partner - Head of Financial Regulation and Capital Markets, and Ibrahim ElMessery, Counsel.
Disclaimer: This publication is provided by ADSERO – Ragy Soliman & Partners for general informational purposes only. It does not constitute legal advice and should not be relied upon as such. No attorney-client relationship is created by the circulation or receipt of this publication. The content is limited to Egyptian law as at the date below and does not address tax matters, which should be referred to a licensed tax advisor. Anyone considering a transaction of the kind described should seek specific advice tailored to their circumstances before taking any action.
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 AlBorsa News about why Egypt's new State Ownership Policy Document should be judged on management efficiency rather than the scale of divestments, the case for restructuring and governance ahead of any sale, and why competitive neutrality between state and private enterprise remains the document's most consequential goal.
To read the full article, click here.
المنشور باللغة العربية بالأسفل
The strongest firms are not built in a single moment; they are built by the people who choose to join them.
ADSERO – Ragy Soliman & Partners announces the joining of Dr Ziad Bahaa-Eldin as Senior Partner and Head of Financial Regulatory and Capital Markets Department, a newly configured practice area that brings together ADSERO’s established Capital Markets offering with a new Financial Regulatory capability. He is joined by Mohamed Hossam El Ehwany as Partner and Dr Rana El Kahwagy as Counsel within the same practice, with all three joining the firm on 1 July.
Dr Bahaa-Eldin’s distinguished career has been shaped by the conviction that law and economic policy are inseparable. He has acted on that principle at every level, as the architect of landmark Egyptian legislations, as Executive Chairman of both the Financial Regulatory Authority and the General Authority for Investment and Free Zones, as a member of Parliament, as Deputy Prime Minister for Economic Development, as well as in his private legal practice. He joins ADSERO as the foremost authority on financial regulation and capital markets in Egypt, and one of the most consequential legal minds in the country.
“Since its establishment, ADSERO has distinguished itself in the Egyptian market by a strong institutional structure, a highly regarded professional culture and a modern outlook to both business and people. That is what brought me here, and I believe the timing is right. Egypt’s investment and financial regulatory landscape is evolving at a pace that demands a legal practice able to show agility, adherence to international norms, and a deep understanding of the local market”. — Dr Ziad Bahaa-Eldin, Senior Partner and Head of Financial Regulatory and Capital Markets Department.
Mohamed Hossam El Ehwany joins as Partner with over fifteen years of experience advising on mergers and acquisitions, project finance, joint ventures, and banking matters across Egypt and the wider Middle East. His practice has a particular focus on the energy and infrastructure sectors, spanning oil and gas, petrochemicals, power, and renewables, and he is recognised by both Legal 500 and Asian Legal Business as one of the leading M&A and Energy lawyers in the region.
Dr Rana El Kahwagy joins as Counsel with a practice spanning corporate and commercial law, cross-border M&A, antitrust, and regulatory compliance across the energy, technology, construction, and petrochemical sectors. A Harvard-educated lawyer, Legal 500-recommended practitioner, and Assistant Professor of Law at Alexandria University, she brings a rare combination of front-line transactional depth and academic distinction to the firm.
The formation of Financial Regulatory and Capital Markets, uniting the firm’s established capital markets practice with a newly built regulatory capability, reflects a deliberate strategic choice. Clients operating at the intersection of regulation, capital markets, and investment require specialised, senior-led counsel, and this market, at this moment, is generating that demand at scale. These three additions give ADSERO the depth to meet it.
“ADSERO has always been a firm where the work speaks for itself, but what makes this moment significant is who has chosen to be part of it. Dr Ziad’s joining, alongside Mohamed and Dr Rana, is a statement of confidence in what we are building. This is a firm where exceptional lawyers grow, lead, and leave their mark. The door is open, and the right people are walking through it.” — Ragy Soliman, Managing Partner.
ADSERO enters this next chapter with the talent, the practice depth, and the certitude to deliver it.
المؤسسات لا تبنى في لحظةٍ خاطفة، بل يبنيها من يختارون الانضمام إليها.
يعلن مكتب أدسيرو – راجي سليمان ومشاركوه عن انضمام الدكتور زياد بهاء الدين إليه بصفته شريكاً رئيسياً ومسؤولاً عن مجموعة التنظيم والرقابة المالية وأسواق المال، وهو قسمٌ مُستحدث يجمع بين خبرة المكتب في مجال أسواق المال والقدرات المستحدثة في مجال قوانين التنظيم و الرقابة المالية. ينضم معه الاستاذ محمد حسام الإهواني بصفته شريكاً، والدكتورة رنا القهوجي بصفتها مستشارة، ضمن ذات المجموعة اعتباراً من ١ يوليو ٦٢٠٢.
وقد تبلورت مسيرة الدكتور زياد بهاء الدين الحافلة حول قناعته الراسخة بأن القانون والسياسة الاقتصادية لا ينفصلان. وقد ترجم هذه القناعة إلى مساهماته في مختلف مجالات العمل: في صياغة وإعداد تشريعات بارزة في مصر، ورئيسًا تنفيذيًا لكلٍّ من الهيئة العامة للرقابة المالية والهيئة العامة للاستثمار والمناطق الحرة، وعضواً بمجلس الشعب، ونائباً لرئيس مجلس الوزراء للتنمية الاقتصادية، فضلاً عن ممارسته لمهنة المحاماة، وهو بذلك ينضم إلى أدسيرو بوصفه مرجع في التنظيم المالي وأسواق المال، وأحد أكثر العقول القانونية تأثيراً في البلاد.
«منذ تأسيسه، تميّز مكتب أدسيرو ببنيةٍ مؤسسية متينة، وثقافةٍ مهنية موضع التقدير والاحترام، ونظرةٍ عصرية للمهنة والعاملين فيها على حدٍّ سواء. وهذا ما دفعني للانضمام إليه، وأعتقد أن التوقيت مواتٍ لذلك. إذ أن طبيعة الاستثمار والتنظيم المالي في مصر تتطور بوتيرةٍ تحتاج مرونة في الممارسةً القانونية، والتزاما بالمعايير الدولية، وفهما عميقا للسوق المحلي.» — الدكتور زياد بهاء الدين، شريك رئيسي ورئيس مجموعة التنظيم والرقابة المالية وأسواق المال.
كذلك ينضم لمكتب أدسيرو الأستاذ محمد حسام الإهواني بصفته شريكاً، بخبرةٍ تتجاوز خمسة عشر عاماً في تقديم الاستشارات القانونية في مجالات عمليات الاندماج والاستحواذ، وتمويل المشروعات، والمشروعات المشتركة، والمعاملات المصرفية في مصر والشرق الأوسط. وتتركز خبرته بوجهٍ خاص في قطاعَي الطاقة والبنية التحتية، بما يشمل النفط والغاز، والبتروكيماويات، والكهرباء، والطاقة المتجددة. وقد تم تصنيفه في دليل (005 LAGEL) ودورية (senissuB lageL naisA) ضمن أبرز المحامين في مجالَي الاندماج والاستحواذ والطاقة في المنطقة.
تنضم أيضا الدكتورة رنا القهوجي بصفتها مستشارة، وتمتد ممارستها لتشمل قانون الشركات والقانون التجاري، وعمليات الاندماج والاستحواذ العابرة للحدود، ومكافحة الاحتكار، والامتثال والحوكمة، في قطاعات الطاقة والتكنولوجيا والتشييد والبتروكيماويات. أتمت الدكتورة رنا دراستها العليا في القانون في جامعة هارفارد (dravraH)، وقد سبق تصنيفها في دليل (005 LAGEL)، كما أنها تشغل حالياً درجة مدرس في القانون الدولي العام بكلية الحقوق بجامعة الإسكندرية، وبذلك تضيف إلى مكتب أدسيرو مزيجاً فريدا من الخبرة العملية والتميّز الأكاديمي.
ويأتي استحداث قسم التنظيم والرقابة المالية وأسواق المال، لكي يجمع بين خبرة المكتب في مجال أسواق المال وبين مجال التنظيم والرقابة المالية ويعبر بذلك عن خيارٍ واع ومدروس، يخدم العملاء في مجالات النشاط المالي وأسواق المال والاستثمار، ممن يحتاجون لمشورةٍ متخصصة وعلى مستوي مهني عال، تتزايد الحاجة له، ويملك مكتب أدسيرو في الوقت الحالي القدرة على تلبيته.
«لم يكن أدسيرو يوماً مجرد مكتب محاماة، بل كان دائماً مشروعاً يؤمن بأن مهنة المحاماة في مصر تستحق مستوى أعلى من الفكر، ومؤسسية أكثر رسوخاً، وتأثيراً أوسع في خدمة المجتمع والاقتصاد. وانضمام الدكتور زياد بهاء الدين، والأستاذ محمد، والدكتورة رنا، ليس إلا تأكيداً على أن هذه الرؤية تجد من يؤمن بها ويختار أن يكون جزءاً منها. ولهذا، فإن انضمامهم إلى أدسيرو لا يمثل مجرد إضافة إلى المؤسسة، بل يعكس التقاءً طبيعياً بين كفاءات استثنائية ورؤية مشتركة تؤمن بأن بناء مؤسسة قانونية رائدة هو مشروع طويل الأمد، يقوم على الفكر والالتزام والسعي الدائم إلى إحداث أثر يتجاوز حدود الممارسة القانونية.» — راجي سليمان، الشريك المدير.
يدخل أدسيرو فصله المقبل وهو يملك المواهب، وعمق الممارسة، واليقين بالقدرة على تحقيقه.
We advised the National Service Projects Organization (NSPO) on the signing of a binding principles agreement with EGX-listed TAQA Arabia for the transfer of 172 fuel stations operating under the “Wataniya” brand to a newly established company, Quick Fuel for Trading and Distribution of Petroleum Products S.A.E. (“Quick Fuel”), under which TAQA Arabia will acquire 10% of Quick Fuel, assume management and operation of the network, and hold an option to acquire an additional 15% upon Quick Fuel’s listing on the Egyptian Exchange.
This is a landmark transaction for both NSPO and the Egyptian economy, representing the first transaction by NSPO structured as a partial exit under Egypt’s StateOwnership Policy . ADSERO has advised NSPO throughout this matter for over five years, from the comprehensive reorganisation and restructuring of the Wataniya network, through to structuring, negotiating and documenting this transaction. Our role has spanned the full lifecycle of the deal: preparing the network for its transfer to Quick Fuel, advising on the operational partnership with TAQA Arabia, and structuring a phased ownership transfer with a future EGX listing route.
Commenting on the transaction, Dr Ahmed Abdelgawad, Partner – Co-Head of M&A and Capital Markets at ADSERO, said: “This is a transformative transaction that reflects the State Ownership Policy’s vision for expanding private-sector participation in Egypt’s economic development.”
Our team was led by Dr Ahmed Abdelgawad, Partner – Co-Head of M&A and Capital Markets, assisted by Mohamed Abdelgawad, Partner – Head of General Corporate, Commercial, and Regulatory; Ehab Fedaa, Partner – Head of General Corporate; Ahmed Adib, Partner; Malak Khalil, Partner – Head of EENR; and Soha Hussein, Managing Associate.
The team also included Kamal Shehata, Senior Associate; Mahmoud Attia, Senior Associate; Hussien Moustafa, Managing Associate; Sadeem Abdelsalam, Managing Associate; Malak Abda, Associate, and Omar Shokair, Associate.
Congratulations to our client, NSPO, on this milestone.
Pleased to have worked alongside our colleagues at The Sovereign Fund of Egypt, Noha Khalil, Mohamed Sherien, and General Nader Zaki Moussa, transaction advisors managing the offering; CI Capital Holding, Gamal Olama, Amr Helal, Sherif El Hakim, and Mahmoud El Kouny, exclusive financial advisors to NSPO; TAQA Arabia, Pakinam Kafafi, Peter Mofeed, and Maged Khalaf; SBA – Grant Thornton Egypt, accounting and tax advisors to NSPO; and Zulficar & Partners Law Firm, Ingy Badawy, Anwar Zeidan, and Mohamed Okasha, legal advisors to TAQA Arabia.
For more information, check out The Enterprise Company’s coverage here:
https://enterpriseam.com/egypt/2026/06/14/taqa-arabia-acquires-10-of-172-wataneya-stations/
We advised The Sovereign Fund of Egypt (TSFE) on a landmark development relating to the 580 MW Gabal El Zeit Wind Power Plant in the Red Sea region, a strategic partnership brought together by TSFE alongside the New and Renewable Energy Authority (NREA) and the Egyptian Electricity Transmission Company (EETC), with Alcazar Energy Partners as the private-sector partner and a total investment value of USD 420 million.
The project aligns with Egypt’s National Energy Strategy and State Ownership Policy, bringing world-class private-sector expertise to one of the country’s flagship renewable energy assets.
Our team was led by Hossam Gramon, Partner – Head of Banking and Project Finance; Malak Khalil, Partner – Head of Energy, Environment and Natural Resources; and Radwa ElDerwy, Senior Associate; assisted by Taya Pirinis, Managing Associate; Dina Sharshar, Associate; and Omar Moanes, Associate.
Congratulations to TSFE, the NREA and EETC on this milestone.
Pleased to have worked alongside our colleagues at Alcazar Energy Partners.
For more information, check out Al Mal Newspaper’s coverage here: https://almalnews.com/2118119/
Introduction
Depression, anxiety, and stress related disorders now rank among the most pressing public health challenges of our time, with prevalence rising sharply across the globe. As mental health has gained greater recognition, the demand for psychotherapy (the “Therapy”) rapidly increased.
Following COVID-19, the shift towards virtual services accelerated, offering greater convenience and accessibility regardless of location. As a result, online therapy (the “Virtual Therapy”) has experienced rapid expansion. However, this growth brings critical questions regarding credibility, safety, and regulatory oversight (the “Concerns”).
We therefore set out below the existing governance framework for Virtual Therapy in Egypt, alongside the associated Concerns.
Background
Therapy is legally defined as a “treatment provided by a psychiatrist or a psychotherapist, under the supervision of a psychiatrist, to assess and cure a human’s maladaptive or dysfunctional responses in emotion, thought, or behaviour; through cognitive, behavioural, humanistic, and other types of therapies”.
Virtual Therapy involves delivering the above treatment remotely via electronic platforms (the “E-Platform/s”).
Virtual Therapy is mainly present in Egypt through the following models:
Perspective
Egyptian healthcare legislation was drafted prior to the digital era. Accordingly, Virtual Therapy operates in a regulatory grey area. The lack of explicit legal frameworks creates potential Concerns, including, but not limited to, the licensing status of psychiatrists or psychotherapists involved (the “Practitioners”) and the sensitive personal health data of relevant patients (the “Data”).
In light of the foregoing, the primary Concerns regarding E-Platforms within the prevailing Egyptian regulatory framework are as follows:
Therapy must be exclusively provided by Ministry of Health-licensed Practitioners. However, because E-Platforms currently lack official regulatory supervision, compliance cannot be guaranteed, except in the case of Licensed E-Platforms. Without official governance, there is no guarantee that unvetted E-Platforms verify Practitioners’ credentials, qualifications, authorisations, or adherence to ethical standards.
Furthermore, only psychiatrists are authorised to diagnose mental health conditions, prescribe medication, and authorise hospitalisation. Consequently, in unregulated E-Platform environments, other than Licensed E-Platforms, there is a severe risk of psychotherapists overstepping their statutory roles, for example, by attempting to make medical diagnoses or suggest medications.
Moreover, beyond standard licensing, psychotherapists must practise under the supervision of a psychiatrist. Consequently, in unregulated E-Platforms, other than Licensed E-Platforms, the risk of unsupervised practice is elevated.
The provision of Virtual Therapy services involves the handling of Data. Any collection, use, retention, or disclosure of such Data must be carried out in full compliance with the applicable personal data protection regulations in Egypt.
Relying on E-Platforms’ compliance in the absence of proper regulatory oversight, other than in the case of Licensed E-Platforms, presents serious vulnerabilities that may compromise patient privacy.
Relevant key compliance risks include, but are not limited to:
Operating E-Platforms naturally involves the commercial promotion of medical services and of the Practitioners providing them. By law, advertising of medical services must be pre-approved by a legally designated committee.
Additionally, strict ethical guidelines prohibit psychiatrists from publicly endorsing treatments and self-advertising on any platform.
In practice, without strict oversight, E-Platforms, other than the Licensed E-Platforms, may not always adhere to the above requirements.
Notwithstanding the Concerns, no E-Platform-related instances of harm or legal proceedings have been announced to date.
Post-pandemic demand has driven a significant surge in mental health services, leading to widespread adoption of E-Platforms in Egypt. As an illustration of this trend, the Egyptian Ministry of Health launched a free, Licensed E-Platform in 2022, in partnership with the World Health Organization and the University of British Columbia, Canada.
Most importantly, previous ministerial statements have signalled the state’s intention to formulate a specialised legal framework for virtual medical treatment.
E-Platforms represent the inevitable integration of technology and healthcare. Despite being unobjectionable in principle, the regulatory deficit identified above necessitates careful oversight to safeguard public health.
While individual Practitioners in traditional settings may commit violations of the kind described above, the likelihood is significantly amplified on E-Platforms that currently lack adequate oversight, other than Licensed E-Platforms.
The aim is not to reject technology that makes life easier; rather, the objective is to achieve robust governance to ensure that such convenience never compromises human safety. Such governance may take the form of new legislation targeting Virtual Therapy, or the modernisation of existing laws to adapt to the digital age. Egypt is likely to see this shift soon, driven by the relevant authorities’ proactive approach to digitalising the healthcare sector.
Authored by Fagr Muheb, Senior Associate and Alaa Mohamed, Junior Associate.
Disclaimer: The views and opinions expressed in this article are those of the author and do not necessarily reflect the official policy or position of ADSERO. This article is intended for general information purposes only and should not be considered or relied on as legal advice. Readers are encouraged to consult with a qualified attorney for specific legal guidance. ADSERO does not guarantee or warrant the accuracy, completeness, or adequacy of the information provided and accepts no liability or responsibility for any errors or omissions in the content.
On 6 May 2026, Prime Ministerial Decree No. 1440 of 2026 was published in the Official Gazette, amending several provisions of the executive regulations of the mineral resources law no. 198 of 2014 (the “Mining Law”) issued by prime ministerial decree no. 108 of 2020 (the “Old ER”). The amendments became effective on the day following their publication, i.e., 7 May 2026 (the “New ER”).
The amendments introduce a broad set of regulatory, financial, and operational changes affecting mining, quarrying and saltworks activities in Egypt. The changes mainly address licensing procedures, rental values, royalty rates, competent authority approvals, laboratory licensing, and additional operational areas required for mining-related activities.
The amended Article 1 clarifies that the New ER apply not only to exploration and exploitation licences for mines, quarries and saltworks, but also to licences for laboratories conducting analysis of rocks and minerals, quarry and saltworks materials, which implement the Mining Law’s existing framework.
The amended Article 1 also confirms that rentals and royalties relating to mines, quarries and saltworks shall accrue to the State Treasury.
The Old ER already required Ministry of Defence approval before licences were issued. Under Article 8, the New ER adds a requirement to complete the necessary coordination for the approval of the Armed Forces Operations Authority, to review the impact on State defence, formalising a requirement previously observed in practice.. It also expands the list of restricted areas requiring approvals for licence issuance to include public properties connected to water resources and irrigation, areas near nuclear installations, and areas known to potentially contain radioactive materials.
Importantly, the relevant authorities must respond to approval or coordination requests within thirty (30) days from the submission of all required documents.
The amended Article 11 permits the Mineral Resources and Mining Industries Authority (the “MRMIA”) to establish or participate in specialised companies conducting exploration, exploitation and mining activities for mines, quarries and saltworks inside or outside Egypt.
Public capital participation in such companies must not be less than 10% (ten per cent), without prejudice to concession agreements issued by law, while under the Old ER, public capital participation in companies established or participated in by the MRMIA for mining activities could not be less than 25% (twenty-five per cent).
The amended Article 14 introduces the Egypt Mining Portal as an electronic platform for submitting exploration licence applications, while maintaining manual submission as an available option.
This supports the broader digitalisation of mining licensing procedures, although the substantive document and approval requirements remain in place.
The amendments under Article 19 revise the renewal mechanics for exploration licences. While the Old ER required the licensee to submit the renewal application at least six (6) months before the expiry of the licence, the amended Article 19 requires only that the renewal application be submitted before the licence expires, without the prior six-month advance requirement.
The amendments also increase the minimum annual exploration expenditure from four (4) times to ten (10) times the applicable annual rental value, while allowing excess expenditure incurred in one (1) exploration period to be credited against the minimum expenditure required in subsequent exploration periods, subject to satisfying the relevant technical obligations.
The Old ER applied flat annual advance rental values per km² for each exploration period. The New ER replaces this with a tiered structure based on the size of the exploration area for each exploration period: one (1) km² to sixteen (16) km², seventeen (17) km² to one hundred and seventy-five (175) km², and areas exceeding one hundred and seventy-five (175) km².
For areas from one (1) km² to sixteen (16) km², annual advance rentals range from EGP 4,300 (four thousand three hundred Egyptian pounds) per km² in the first exploration period to EGP 17,200 (seventeen thousand two hundred Egyptian pounds) per km² in the fourth exploration period.
For areas from seventeen (17) km² to one hundred and seventy-five (175) km², annual advance rentals range from EGP 2,580 (two thousand five hundred and eighty Egyptian pounds) per km² to EGP 12,900 (twelve thousand nine hundred Egyptian pounds) per km².
For areas exceeding one hundred and seventy-five (175) km², annual advance rentals range from EGP 1,720 (one thousand seven hundred and twenty Egyptian pounds) per km² to EGP 11,180 (eleven thousand one hundred and eighty Egyptian pounds) per km².
In general, the new rental values are lower than the previous flat rates, particularly for larger areas. However, these should be considered alongside the increased minimum expenditure obligation, as lower rental values do not necessarily result in a lower overall exploration commitment.
Under the Old ER, the ability to add minerals to an exploration or exploitation licence was mainly linked to cases where the new mineral was mixed with the licensed mineral and could not be extracted separately. The New ER is broader under Articles 20 and 30, whereby a licensee may add any ores or mineral materials to the relevant licence, subject to the MRMIA’s Board approval.
For exploitation licences, the licensee must pay the applicable royalty on the annual production of the added mineral, but no additional rent is payable for the added mineral.
The amended Article 31 increases the annual rent for exploitation licences from EGP 25,000 (twenty-five thousand Egyptian pounds) per km² to EGP 35,000 (thirty-five thousand Egyptian pounds) per km². The rent for white sand remains EGP 9 (nine Egyptian pounds) per square metre, and the New ER introduces a specific annual rent of EGP 1 (one Egyptian pound) per square metre for kaolinitic sand or sandy kaolin.
The amended Article 32 provides that any unlisted ore or mineral is subject to a 6% (six per cent) royalty.
The New ER also provides that local market prices for royalty calculation are determined by a committee formed by the MRMIA’s Chairman, rather than by a committee formed by the competent minister under the Old ER.
The amended Article 85 revises the rental values for areas leased outside the exploration or exploitation area for facilities, buildings, storage, industrial purposes, utilities, or related operational needs.
The annual rental is:
The amendments also reduce the portion of the rental value allocated to the relevant governorate from 25% (twenty-five per cent) to 15% (fifteen per cent).
Consistent with the Mining Law, which provides that laboratories analysing rocks and minerals, quarry and saltworks materials must be licensed by the MRMIA, the New ER introduces the detailed licensing framework for such laboratories.
Article 107 of the New ER regulates the application process and sets operational standards for licensed laboratories, including:
On oversight and inspection, the MRMIA may carry out periodic or surprise inspections to verify compliance, withdraw samples to check the accuracy of results, and issue written notices requiring violations to be remedied within a period determined by the MRMIA. In cases of serious violations, result manipulation, or breach of data confidentiality, the MRMIA may withdraw the licence.
The licence is valid for three (3) years and renewable following a comprehensive review. Issuance fees are EGP 1,000,000 (one million Egyptian pounds) for sample preparation laboratories and EGP 3,000,000 (three million Egyptian pounds) for full analytical laboratories. Renewal fees are EGP 500,000 (five hundred thousand Egyptian pounds) and EGP 1,000,000 (one million Egyptian pounds), respectively.
Laboratories may not advertise their services or commence activities before obtaining the licence.
The New ER amends the existing mining framework to deliver a combination of investment facilitation and tighter fiscal and compliance controls. In practical terms, the amendments make the licensing process more structured, introduce clearer financial obligations for exploration and exploitation activities, and expand the MRMIA’s oversight role, particularly in relation to added minerals, laboratory licensing, and ancillary operational areas.
On the investment side, the reduction of the minimum public capital participation threshold to 10% (ten per cent) opens new structuring options for joint ventures with the MRMIA, the broadened mineral add-on rights provide greater project flexibility, and the Egypt Mining Portal digitalises the application process.
While some changes are procedural, such as the introduction of the Egypt Mining Portal and updated approval mechanics, others may directly affect project costs, including the tenfold increase in minimum exploration expenditure, higher exploitation rent, increased ancillary area rentals and the expanded scope of the MRMIA’s oversight, including a new laboratory licensing regime, all of which raise the bar for operational compliance.
Clients with active or planned mining projects should assess how the revised expenditure commitments, royalty mechanics and ancillary area ratios interact with their project economics and licence structures.
The contributors to this article are Malak Khalil, Partner – Head of EENR, Sadeem Abdelsalam, Managing Associate, and Zeina Jowett, Associate.
We are pleased to share our latest report highlighting the laws and decrees issued in the first quarter of 2026.
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We are pleased to launch our new quarterly publication series, ADSERO's Egyptian Labour Law Newsletter, which aims to provide valuable insights into key regulatory updates relevant to our clients and the broader business community.
Our inaugural Q1 2026 issue, authored by Alia Monieb, Partner – Head of Employment, Abdalla Shohdy, Managing Associate, Hana Abouelmagd, Junior Associate, and Seifeldin Hamad, Junior Associate, provides a comprehensive overview of the recent implementing decrees issued pursuant to Labour Law No. 14 of 2025. This edition highlights noticeable shifts in employment structuring, working hours, employees welfare, and expanded employer obligations.
Through this series, we aim to share our team’s expertise and contribute to informed discussions on Egypt's evolving labour landscape.
To read the full update, click here.
Check out our latest interview where Ragy Soliman, Managing Partner, Co-Head of M&A and Capital Markets at ADSERO, speaks to Alyaa Stouhy from Capital Call Magazine by EPEA on why investment continues to hold firm in Egypt despite regional tensions, the sectors attracting the strongest investor demand, and the structural reforms needed to unlock Egypt's full potential as an FDI destination.
To read the full article, click here.
