Introduction

On 24 November 2025, the Egyptian Ministry of Finance (the “MoF”) issued Circular No. 94 of 2025 (the “Circular”), introducing a new mechanism governing dealings with the Unified Procurement Authority (the “UPA”).

Effective 1 July 2025, (the “Effective Date”), all pharmaceuticals and/or medical supplies procurement for the public sector (“Procurement”) must be conducted through a tripartite arrangement involving the UPA, the requesting public entity, and the relevant supplier.

Under this model, the UPA will also maintain supervisory oversight to ensure proper implementation and compliance.

The Circular applies to all entities addressed by Law No. 151 of 2019 (the “Entities”).

Key Provisions

1. Existing Procurements’ Status
   Procurement arrangements executed with the UPA until 30 June 2025 will not be governed by the Circular. These arrangements will remain subject to the provisions of MoF Circular No. 154 of 2021.
   
2. Tripartite Contracting Model Adoption
   As of the Effective Date, all Procurements with the UPA must be executed through a tripartite agreement between:
   • the UPA;
   • the requesting public entity (“Requestor”); and
   • the relevant supplier (“Supplier”).
     
3. Tripartite Contracting Model Process
   • Requestors will submit their Procurement requests to the UPA.
   • The UPA will take the necessary measures and issue purchase orders in favour of the Requestors, notifying them accordingly.
   • Suppliers will take the necessary measures to fulfil and deliver the Procurement requests to the relevant Requestors.
   • Requestors will pay for the products actually supplied, in accordance with the MoF’s relevant instructions, including, without limitation, settling the UPA fees and providing the UPA with copies of payment orders made to Suppliers.
     
4. Compliance
   Both the UPA and the Entities must adhere to the above process. Additionally, any competent governmental authority shall consider applying the same model.

The Decree applies to all insurance and reinsurance companies governed by the Unified Insurance Law No. 155 of 2024 and operating under the supervision of the FRA.

Disclaimer

This document is for informational purposes only and does not constitute legal advice.

The contributors to this article are Fadila Abdelaziz, Counsel, Fagr Moheb, Senior Associate, and Alaa’ El-Mekhashen.