Introduction

Egypt’s fintech sector has become a key driver of financial inclusion, offering accessible and innovative financial services to a wide range of users. Leading players such as Fawry–a pioneer in digital payments–and Paymob–a provider of payment processing solutions–have played a central role in modernising traditional banking and payment systems, accelerating Egypt’s digital evolution.

According to FINTECH Global, fintech investments in Egypt reached USD 259 million (two hundred and fifty-nine million United States dollars) in 2022, reflecting a 12.6% (twelve point six per cent) increase from the previous year. This aligns with broader efforts to enhance financial accessibility, evidenced by a 147% (one hundred and forty-seven per cent) rise in financial inclusion rates between 2016 and 2022, as reported by the Central Bank of Egypt (the “CBE”).

More recently, in February 2025, Entlaq–together with the Embassy of the Netherlands in Egypt–launched the Egypt FinTech Landscape Report, highlighting that the sector has expanded 5.5 (five point five) times since 2020, reaching 177 (one hundred and seventy-seven) startups and ranking 10^th among emerging markets.

With this rapid growth, the need for robust regulatory frameworks becomes increasingly pressing to ensure fair competition. In this regard, the CBE, through its Competition Protection Unit (the “Unit”), alongside the Financial Regulatory Authority (the “FRA”), plays a crucial role.

The Central Bank and Banking System Law No. 194 of2020 (The “CBE Law”), the Egyptian Competition Law No. 3 of 2005 (the“EC Law”), and its Executive Regulations No. 1316 of 2005 (the “EC Law ER”) form the foundation for overseeing business practices in the fintech industry.

This article examines how these regulations influence fintech operations, ensuring market fairness while supporting sustainable growth.

Violations to Look Out for:

While the growth of the fintech market signifies progress, rapid expansion also attracts regulatory scrutiny. Market participants should be especially mindful of the following practices, which are commonly flagged as anti-competitive:

1. Price Fixing: Defined under Article 11 of the EC Law ER, price fixing occurs when competitors collude to set prices, eliminating market-driven competition. The Egyptian Competition Authority (the “ECA”) recently initiated criminal proceedings against 162 (one hundred and sixty-two) companies for engaging in horizontal agreements to fix daily selling prices of chicks, exchanging sensitive commercial information on market availability, execution prices, raw materials, feed, and demand. This resulted in artificially high prices and excessive profit margins at the expense of Egyptian consumers, increasing their financial burden.
2. Market Segmentation: When competitors coordinate to divide the market—whether by geographic region, customer base, or product offering—they significantly undermine competition. Such segmentation can lead to monopolistic-like conditions in certain areas, depriving consumers of genuine choice and fair pricing.
3. Exclusivity: Competition concerns may arise when competitors engage in exclusive supply agreements. These arrangements, whether explicit or implicit, can restrict market access for other players by limiting their ability to procure essential inputs or services.
4. Bid Rigging: Under Egypt’s Public Procurement Law No. 182 of 2018, competitive bidding is required for many public projects. Any agreement among companies to manipulate or rig the bidding process often leads to inflated prices and reduce service quality for the public sector.
5. Abuse of Dominant Position: Regulated by Article 13 of the EC Law ER, this provision prohibits certain behaviours by entities holding a dominant market. A recent case involved a telecommunications company bundling fixed services as a condition for obtaining landline services. The ECA found this to be an abuse of dominance in the landline service market.  - It is worth noting that, pursuant to Article 31 of the EC Law ER, anyone is eligible to file a request for an investigation into a potential violation.
6. Cross-Border Oversight:  Oversight is not limited to Egypt’s national territory. According to Article 21 of the COMESA Competition Regulations, any person may request an investigation where they have reason to believe an activity by an undertaking in a Member State is likely to restrict competition in the Common Market. Accordingly, investigations may be triggered both domestically and abroad. 

Regulatory Framework for Market Competition

The CBE Law established the Unit within the CBE to regulate competition in the financial sector. This Unit enforces regulations issued by the CBE’s Board of Directors (the “BoD”), aiming to enhance market efficiency, consumer choice, service quality, and pricing.

The CBE Law empowers the BoD to investigate and penalise anti-competitive practices. The Unit also monitors mergers and acquisitions and promotes compliance and awareness within the industry.

Complementing this, the EC Law offers a broader framework covering all sectors, including fintech. Together, these laws enable regulators to address anti-competitive agreements, abuse of dominance, and market transparency—balancing innovation with competitive fairness.

In parallel, the Personal Data Protection Law No. 151 of 2020 (the “PDP Law”) plays a crucial indirect role in shaping fintech competition. Since fintech firms rely heavily on user data, the monopolisation of this data can create barriers that hinder smaller enterprises from competing effectively. The PDP Law helps prevent such imbalances by promoting secure, transparent access to data.

Advancing Innovation: FRA’s Vision for Egyptian Fintech

The FRA has made notable progress in building a fintech-friendly regulatory environment. The introduction of the Fintech Law No.5 of 2022 and subsequent decrees in 2023 are important steps toward encouraging innovation and lowering entry barriers. By supporting technologies like blockchain and smart contracts, the FRA is sending a clear message: Egypt is open for fintech business.

These decrees grant recognition to entities seeking licences to offer Non-Banking Financial Services using fintech tools, expanding market participation.

To regulate outsourcing, the FRA has introduced criteria for service providers covering experience, capital, and technical capacity. These measures ensure fair competition while maintaining service quality and ecosystem integrity.

In a move that promotes consumer-centric innovation, the FRA has also legitimised the use of digital contracts and e-signatures, enabling broader access to services and enhancing user satisfaction.

Further, recent amendments to the executive regulations of the E-Signature Law No. 15 of 2004 strengthens legal clarity around electronic transactions. The new framework grants electronic documents, digital seals, and trusted services (e.g., time stamps and registered email) the same legal status as traditional documents. These reforms reduce administrative burdens, improve reliability of digital transactions, and support the growing fintech ecosystem.

Conclusion

So, where do we stand? Egypt’s fintech sector depends on maintaining a balance. On one side lies the promise of innovation, inclusion, and economic opportunity. On the other looms the risk of monopolistic practices, stifled competition, and ineffective regulation. The CBE and FRA have laid the groundwork for a resilient and competitive fintech ecosystem–but much work remains.

The stakes are high–but so is the potential. If regulators succeed in navigating these complexities, Egypt has the potential to emerge as a regional fintech powerhouse, setting a benchmark for innovation and financial inclusion. Conversely, if regulatory missteps occur, the sector’s momentum may stall. The path ahead is clear, and the decisions made today will shape the trajectory of Egypt’s fintech landscape for years to come.

Authored by our team Darah Zakaria, Counsel, Farida Banany, Senior Associate, and Junior Associates Habiba Tarek, and Youssef Abdelmaksoud, this piece reflects our continued commitment to providing thoughtful insights on emerging legal and business developments.

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 for general information purposes only and is not intended to be and should not be taken as legal advice. Readers should consult with a qualified attorney for specific legal guidance. ADSERO does not guarantee or warrant the accuracy, completeness, or adequacy of the information presented and assumes no liability or responsibility for any errors or omissions in the content.