Employment Compliance in Egypt: Updates on Disability, Intermittent Work, and Holiday Regulations

December 29, 2025

Overview

The Ministry of Labour continues to issue implementing decrees under Egypt’s new labour law no. 14 of 2025 (the “Labour Law”) as the regulatory framework takes shape. This alert focuses on three (3) recently issued implementing decrees, namely:

  • decree no. 271 of 2025 regulating data relating to the employment of persons with disabilities and persons with dwarfism (the “Disability Employment Data Decree”);
  • decree no. 290 of 2025 regulating working hours for employees engaged in intermittent work by nature (the “Intermittent Work Decree”); and
  • decree no. 294 of 2025 regulating official public holidays (the “Public Holidays Decree”).

Key Provisions

1. The Disability Employment Data Decree

This decree regulates the collection, maintenance, and reporting of data relating to the employment of persons with disabilities, including persons with dwarfism. It implements the reporting and monitoring obligations set out under the Law No. 10 of 2018 on the Rights of Persons with Disabilities.

Under the Disability Employment Data Decree, establishments employing persons with disabilities, including persons with dwarfism, are required to maintain a paper or electronic register containing relevant employment data, based on rehabilitation certificates, disability identification cards, or integrated services cards. Such register must be submitted to the competent administrative authority upon request.

Establishments are also required to submit biannual reports to the competent labour directorate in January and July of each year. These reports must include, among other information, the total workforce, the number of employees with disabilities, including persons with dwarfism, the roles they occupy, the nature of such roles, and their wages. Said decree also attaches a standard reporting template to be used for these purposes.

2. The Intermittent Work Decree

The Intermittent Work Decree regulates working hours for employees whose work is intermittent, meaning work that inherently involves periods of waiting, standby, or interruption during the working day. It applies to employees subject to the Labour Law and introduces specific rules governing daily working hours, rest periods, and additional compensation.

As a general rule, actual working hours may not exceed ten (10) hours per day, while an employee’s total daily presence at the workplace may not exceed twelve (12) hours per day. Rest periods are counted as working time where the employee remains present at the workplace. Employees engaged in intermittent work are excluded from the standard organisation of working hours, provided that their total daily presence does not exceed twelve (12) hours.

The decree defines “Intermittent Work” and provides a non-exhaustive list of covered activities, including transport and logistics, certain agricultural and river services, emergency healthcare services, online technical support, data centres and similar activities involving intermittent demand.

Employers may adopt a special organisation of working hours for Intermittent Work, subject to the twelve (12)-hour daily presence limit. Employers must pay additional wages for any hours exceeding the standard daily working hours in accordance with the Labour Law.

Employers are also required to maintain paper or electronic records of working hours, overtime, rest periods, and total daily presence at the establishment.

3. The Public Holidays Decree

The Public Holidays Decree confirms that official public holidays are fully paid leave days and do not count towards annual leave. It specifies a set of official national holidays, including Islamic and Coptic holidays, national memorial days, and Labour Day.

The decree allows employers to require employees to work on holidays where business needs so require. In such cases, employees are entitled to either:

  1. their full daily wage plus double pay for the day worked; or
  2. an alternative paid day off, subject to the employee’s written request.

Further, said decree recognises the right of non-Muslim employees to paid leave for their respective religious holidays.

Conclusion

The recently issued decrees represent a further step in the implementation of the new Labour Law, introducing compliance requirements for employers. It is worth noting that further implementing decrees are expected as the framework continues to develop.

The contributors to this article are Rawan Roshdy, Managing Associate, and Hana Abouelmagd, Junior Associate.

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