On 18 February 2026, the Financial Regulatory Authority (“FRA”) Board of Directors decision no. 35 of 2026 (the “Decision”) entered into force. The transitional period it granted has now expired, making compliance an immediate consideration for affected non-banking financial institutions in Egypt.

The Decision requires FRA licensed companies carrying out non-banking financial activities whose issued and paid-up capital exceedsEGP 50,000,000 (fifty million Egyptian pounds) to maintain an annual insurance policy covering the liability risks of their board members and executive management.

Crucially, maintaining this insurance coverage is expressly treated as a condition for the continuation of the company’s license to conduct its regulated activity.

Defining the Scope of the New FRA D&O Insurance Mandate

Affected companies must maintain an annual insurance policy with an insurance company operating in Egypt covering the liability risks of:

• members of the board of directors; and
• executives responsible for the company’s executive management.

The liability limit under the policy must be proportionate to the company’s scale of operations and risk profile and, in all cases, must not be less than 5%(five per cent)of the company’s average revenues during the three (3) financial years preceding the issuance of the policy.

Companies are also required to renew the policy annually and to immediately disclose any amendment or cancellation occurring during its term.

FRA Grace Period Expires for Mandatory D&O Insurance

Existing companies falling within its scope were given six (6) months to regularise their position and provide the FRA with a copy of the relevant insurance policy. That period therefore expired in August 2026.

Affected FRA regulated companies should therefore ensure that the required policy is now in place, that its coverage limits satisfy the requirements of the Decision, and that the relevant regulatory filings have been completed.

The Decision forms part of the FRA’s broader focus on corporate governance, management accountability and risk allocation across Egypt’s non-banking financial sector.

ADSERO – Ragy Soliman & Partners advises financial institutions and other FRA-regulated entities on regulatory compliance, corporate governance and the implementation of requirements affecting boards and senior management.

The contributors to this article are Dr. Ziad Bahaa-Eldin, Senior Partner - Head of Financial Regulatory and Capital Markets​ and, Ibrahim El Messery, Counsel.