EGYPT Trends and Developments Contributed by: Dina Kamel, Helal El Hossary, Farida Tawfik and Ahmed Ammar, Zaki Hashem
In parallel, the FRA regulations affirm the enforce - ability of digital contracts and digital signatures in non-bank financial transactions conducted through fintech platforms. By recognising digital contracts as functionally equivalent to traditional written agree - ments, the FRA removes legal uncertainty surround - ing the legal formation, legal validity and enforceability of contracts concluded through electronic channels. This recognition is particularly significant in sectors such as consumer finance, microfinance, insurance, factoring and leasing, where high transaction volumes previously depended on manual documentation and physical execution. The regulatory framework further extends to digital registers and electronic record-keeping, allowing reg - ulated entities to create, maintain and store financial records in electronic form, provided that such records meet specified integrity, confidentiality and accessi - bility standards. Entities are required to ensure the reliability of electronic records through secure infor - mation systems, audit trails and mechanisms that prevent unauthorised alteration or deletion. This not only enhances regulatory oversight and compliance monitoring but also facilitates more efficient internal governance and reporting. These measures represent a structural transformation from paper-based regulatory and operational mod - els towards a fully digitised financial services envi - ronment. By enabling end-to-end digital customer journeys from onboarding and contracting to record maintenance, the FRA regulations significantly reduce operational costs, processing times and administra - tive burdens for financial service providers. At the same time, these measures make non-banking finan - cial services easier to access, especially for individu - als and small businesses in under-served or remote areas, by reducing the need for physical presence to finalise all required paperwork and procedures. They also support the Fintech Law’s main goal of promoting financial inclusion and accelerating digital transforma - tion. FRA Decree No 125 of 2025 introduces a new approach to regulating digital investment in real estate in Egypt. It establishes a framework for licensed digital platforms for real estate investment funds, enabling
fractional ownership. It sets clear requirements for licensing, investor protection and operational govern - ance of these platforms. A recent protective measure undertaken by the FRA to ensure that only licensed companies are operating and offering NBFS, the FRA has announced a list of blacklisted entities that are operating as NBFS with - out licences, as well as unlicensed entities that offer services including availing cash illegally to consumers in return for the credit obtained from NBFS. The most recent regulations for banking services The CBE introduced several rounds of the regulatory sandbox, which offers a life testing environment for fintech entrepreneurs who wish to develop new busi - ness models. Cohort 3 of the Regulatory Sandbox was launched in 2023 for lending-based crowdfund - ing platforms. As part of the regulatory sandbox initiative, the CBE is regulating the transformation of the traditional rotat - ing savings and credit association (ROSCA) into digi - tal experiences for the public, testing such services within its regulatory sandbox. Pursuant to Article 184 of the CBE Law, the CBE has issued the licensing and registration rules for pay - ment system operators (PSOs) and payment service providers (PSPs) (the “PSP/PSO Rules”). The PSP/ PSO Rules ensure all entities that engage in activities involving payment services operating within Egypt, whether locally established or operating offshore for Egyptian residents, are licensed directly from the CBE. The CBE has laid out a set of requirements, which include the legal form of company, capital require - ments, shareholding, governance structure, techni - cal requirements and financial collateral – as well as supporting documents – to be able to obtain a PSP or PSO licence. However, banks may engage in PSP and PSO activities, provided that approval is obtained from the CBE – and without a licence from the latter. The grace period for PSPs and PSOs has been 12 months since the issuance of the Rules, but this ends on 31 May 2026. Digital banks are the newest trend in traditional bank - ing services, offering banking services via digital
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