New Regulatory Requirement Effective February 2026
On January 28, 2026, the Board of Directors of the Egyptian Financial Regulatory Authority (FRA) issued Decree No. 35 of 2026, introducing a mandatory Directors and Officers (D&O) liability insurance requirement for licensed non-banking financial companies operating in Egypt.
Who Is Affected?
The Decree applies to all companies licensed by the FRA to engage in non-banking financial activities where the company’s issued and paid-up capital exceeds EGP 50 million. Maintaining valid D&O insurance coverage is now a condition for the continuation of the company’s operating license.
Key Requirements
Coverage Scope: Affected companies must enter into an annual insurance policy with an insurance company operating in Egypt to cover the liability risks of their boards of directors and executive managers.
Minimum Coverage Limits: The policy’s liability limits must be proportionate to the company’s business volume and degree of risk, and must be no less than 5% of the company’s average revenues over the three fiscal years preceding the policy issuance date.
Ongoing Obligations: Companies must renew the policy annually and immediately disclose any amendments or cancellations during the policy’s validity period.
Compliance Timeline
Existing companies that meet the capital threshold must regularize their status and submit a copy of the insurance policy to the FRA within six months from the effective date of the Decree. The Decree takes effect the day following its publication in the Egyptian Official Gazette.
Takeaway
This Decree represents a significant governance enhancement for Egypt’s non-banking financial sector, aligning with international best practices on corporate liability protection. Affected companies should promptly assess their D&O insurance arrangements and engage with insurers to ensure compliance within the prescribed timeline.
