EGYPT Law and Practice Contributed by: Dina Kamel, Helal El Hossary, Omar Fouda and Kareem Hashem, Zaki Hashem
execution is automated once the order reaches the order book, because execution can still be affected by the market’s trading rules and controls. Key issues include: • price and costs – whether the customer uses mar - ket or limit orders, and whether fees, spreads and slippage mean the customer did not achieve the best available outcome; • speed and reliability – including latency and out - ages; • likelihood of execution and settlement – including partial fills, illiquidity and exchange suspensions; • order handling fairness – including time priority, and ensuring non-discriminatory treatment and avoidance of conflicts in how orders are routed/ managed; and • governance and auditability – maintaining an execution policy, monitoring execution quality and keeping the audit trail and error-handling process consistent with the exchange rule framework. 4. Online Lenders 4.1 Differences in the Business or Regulation of Fiat Currency Loans Provided to Different Entities Egypt’s banking and non-banking financial sector is shifting towards fintech-enabled online lending by both banks and NBFS companies, with the permitted loan products differing by borrower type. CBE Bank lending is governed by the Central Bank and Banking System Law, with separate SME-specif - ic banking lending rules. Article 205 requires CBE approval for digital finance that is bundled with pay - ment and collection services, regardless of the pro - vider’s legal form. Non-banking consumer lending is regulated by the FRA under the Consumer Finance Law and related FRA decisions (including 869/2021 and 81/2023). FRA Microfinance, nano-finance and SME finance compa - nies may finance micro, nano-, and SME businesses
only. Consumer finance companies primarily extend credit to individuals for consumer purchases, and generally may not provide cash loans – except cash loans up to EGP50,000 when pre-approved by the FRA under Decree No 81 of 2023 and Decree No 138 of 2025, subject to a cap whereby cash lending may not exceed 20% of the portfolio. Separately, Decree No 318 of 2025 permits financial leasing, factoring and SME finance companies to offer financing in foreign currencies. 4.2 Underwriting Processes Banks that co-operate with fintech companies under the relevant CBE regulations for a given service typi - cally require those fintech companies, by contract, to comply with the CBE’s KYC and customer due diligence rules. The CBE internet banking rules also require KYC, customer due diligence, and enhanced due diligence for online services, as well as manual verification for certain high-risk or credit operations (Rule s3-4-5). The FRA provides relevant companies with a default monitoring system, including a list of defaulting cus - tomers. In practice, fintech underwriting in Egypt is shaped by industry standards and regulatory require - ments set by the FRA, CBE and other authorities, and commonly includes the following:. • technology-enabled credit scoring using fac - tors such as credit history (including the iScore), income verification (employment details and busi - ness revenue), spending habits (from bank transac - tion or third-party data) and sports club member - ship (including the club’s perceived social status); • AI-based risk assessment models to estimate repayment likelihood based on financial behaviour and other data points, enabling faster decisions; and • electronic KYC (E-KYC), where the FRA requires fintech companies to verify client identity by col - lecting personal information (eg, national ID and proof of address) and conducting checks to sup - port AML compliance. Banks and NBFS compa - nies also manage default risk through insurance policies covering their portfolios, by entering into portfolio default insurance.
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