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

• Companies must submit direct investment data to GAFI within forty-five (45) days of the end of each calendar quarter.
• Companies must submit their financial statements to GAFI in accordance with Article 156 (bis) of the Companies Law No. 159 of 1981 (the “Companies Law”), as amended.

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

• Direct investment data reporting derives from the Investment Law No. 72 of 2017 (the “Investment Law”) and Prime Minister Decree No. 2732 of 2019, which require all companies incorporated in Egypt, regardless of legal form, to report data enabling GAFI to calculate direct and indirect foreign investment. This includes (i) event-driven reports within thirty (30) days of incorporation or any change in capital, purpose, shareholding structure or board composition; (ii) quarterly reports within forty-five (45) days of quarter-end; and (iii) annual reports within three (3) months of financial year-end.
• Quarterly financial statement filing derives from Article 156 (bis) of the Companies Law, recently amended as part of the broader governance and transparency reforms to Articles 39, 60 and 156 (bis). This amendment obliges companies to send quarterly financial data to GAFI to ensure periodic monitoring, with exemption thresholds carved out for small and micro enterprises.

What This Means for Companies

• Scope is broad: the obligations apply to companies generally, not solely to those with foreign shareholders, although the underlying legal bases differ. Investment Law/FDI Decree governs direct investment data, while Article 156 (bis) of the Companies Law governs financial statement filings. Applicability, and any small or micro-enterprise exemption, should be assessed on a case-by-case basis by reference to each company’s size, capital and shareholding structure.
• Recurring, calendar-driven deadlines: filings are due four times a year, forty-five (45) days after each quarter-end. The relevant dates are 31 March, 30 June, 30 September, and 31 December. This is a standing compliance obligation, not a one-off filing.
• Designated delegate required: companies must authorise a representative to create or use an account on GAFI’s e-portal, or may instead delegate a law firm to submit filings on their behalf via proxy.
• Financial and reputational exposure for non-compliance: Article 91 of the Investment Law imposes a fine of up to EGP 50,000 (fifty thousand Egyptian pounds) on companies that fail to submit the required data. Persistent non-compliance may also affect a company’s standing with GAFI in future dealings, including licensing, incentives, and approvals.
• Governance implication: because the financial statement obligation is now anchored directly in Article 156 (bis) of the Companies Law, it should be treated as a board- and finance-function-level compliance item, integrated into the company’s normal financial reporting calendar rather than left as an ad hoc regulatory task.
• Group-wide relevance: multi-entity groups should confirm that each Egyptian entity in the structure has a clear owner for these filings, rather than only the flagship operating company, given the per-entity nature of the obligation.

Suggested Next Steps

• Confirm which entities in your structure are in scope and whether any qualify for the small or micro enterprise exemption under the amended Article 156 (bis).
• Identify or appoint an internal owner (or authorise ADSERO as delegate) for GAFI e-portal filings.
• Align internal financial reporting timelines to the forty-five (45)-day post-quarter-end deadline to avoid last-minute filings.
• Review historical compliance to confirm no gaps exist for prior quarters, given the fine exposure under Article 91 of the Investment Law.

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.