EGYPT Law and Practice Contributed by: Dina Kamel, Helal El Hossary, Omar Fouda and Kareem Hashem, Zaki Hashem
kerage and digital policy issuance. • Consumer finance: Law No 18 of 2020 (the “Con - sumer Finance Law”) and FRA decrees shape the product and conduct layer, including model contract templates, affordability and instalment-to- income constraints and rules on cash advances. It is worth noting that in 2024, the FRA issued Board Decision No 184 of 2024, deciding to suspend the incorporation and licensing of consumer finance com - panies that intend to engage in consumer finance activity non-digitally for a renewable period of one year, and in 2025 the FRA renewed the suspension (via Board Decision No 237 of 2025) for an additional one-year period starting on 11 October 2025. This exempts companies and entities wishing to engage in consumer finance activities via financial technol - ogy (fintech), in accordance with the provisions of the Law Regulating and Developing the Use of Finan - cial Technology in Non‑Banking Financial Activities, as part of the FRA’s approach to promoting digital transformation in financial activities and supporting financial innovation. However, on 24 February 2026, the FRA issued Decree No 43, suspending the acceptance of new applica - tions for the incorporation and licensing of consumer finance companies under the FinTech Law for a period of one year, effective from 25 February 2026. Alongside FRA Decree No 184 of 2024, this measure suspends all new applications for consumer finance companies, whether operating through traditional channels or financial technology platforms. The decree was issued to strengthen the FRA’s oversight of consumer finance activities and ensure compliance with anti-money laundering and counter- terrorism financing regulations, following the recent issuance of multiple licences over the past two years, bringing the total number of licensed consumer finance companies (whether traditional or FinTech) to 28. The firm views this decision as a proactive measure by the FRA to preserve the economic and strategic value of consumer finance in Egypt, particularly in light of the current market landscape, which is increasingly
saturated with licensed consumer finance providers. By temporarily pausing the issuance of new licences, the FRA is likely seeking to maintain market stabil - ity, prevent excessive competition, and ensure that the existing institutions can operate sustainably while safeguarding the quality and accessibility of consumer financing services. Typically, factoring is FRA-supervised as an NBFS activity, and where digitised, it also falls within the FinTech Law category covering digital onboarding, contracting and outsourcing controls. Insurance is FRA-supervised, with a distinct digital rulebook for digital issuance and digital brokerage activities that sits alongside general insurance regulation. 2.3 Compensation Models Law 194/2020 empowers the CBE to set disclosure and transparency requirements and supervise cus - tomer protection for entities within its perimeter; the general consumer protection statute does not apply to CBE-regulated entities (Article 216). The CBE can set rules for service pricing disclosure and quality stand - ards (pricing rules can be issued per Article 186, and service quality/continuity obligations per Article 198). The CBE licensing rules reference public registry transparency and oversight; they do not enumerate fee caps for PSPs/PSOs in the provided excerpts. Banks retain authority to set returns and service pric - es subject to disclosure rules and competition safe - guards in Law 194/2020 (Article 89). FRA-regulated non-banking financial entities may be compensated via monthly and annual fees for provid - ing finance to clients, in addition to administrative fees and any other fees that may apply. The FRA have issued standardised contract models. NBFS companies are obliged to comply with the pro - visions stated in these models as a minimum require - ment. As an example, a consumer finance contract shall include clear fee and pricing disclosure, includ - ing: • the finance amount; • the fees and annual interest rate; • administrative and any other expenses; and
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