New Regulation Governs the Establishment and Licensing of Insurance and Reinsurance Brokerage Companies in Egypt

Introduction

Within the framework of the development of the non-banking financial sector and promotion of transparency and professionalism in the Egyptian insurance market, the Financial Regulatory Authority (FRA) has issued Decree No. 69 of 2025 regarding the rules and regulations governing the incorporation of insurance or reinsurance brokerage companies.

The purpose of this Decree is to support the efficiency of companies operating in the brokerage activity, protect the rights of clients, and elevate the level of professional practices in this sector.

First: Definition of Insurance and Reinsurance Brokerage Companies

According to the Decree, insurance or reinsurance brokerage companies are entities registered in the designated register and licensed by the FRA to act, in any form, as intermediaries in concluding insurance or reinsurance operations for any insurance or reinsurance company, as the case may be, in return for a fee, commission, or remuneration.

Second: The General Regulations

All insurance or reinsurance brokerage companies must comply with a set of general regulations when establishing and conducting their activities, including the following:

• Prohibition on Combined Activities: Combining insurance brokerage and reinsurance brokerage activities within the same company is prohibited.
• Mandatory Licensing and Registration: Companies are required to obtain necessary licenses and register them in the official register prepared for this purpose by the Financial Regulatory Authority.
• Required Organizational Structure: An organizational structure comprising a minimum of seven departments must be established. Key departments include:
• Brokers’ Department
• Collection Follow-Up Department
• Compensations Follow-Up Department
• The Brokerage Department must include no fewer than two brokers registered in the designated register at the FRA.

Third: Conditions for Establishing Insurance and Reinsurance Brokerage Companies

1. The company must take the form of an Egyptian joint-stock company, whose sole purpose is to engage in insurance or reinsurance brokerage.
2. Its capital at incorporation must not be less than EGP 5 million, whether for insurance or reinsurance brokerage.
3. A financial institution must hold no less than 25% of the company’s capital.
4. Female representation on the board of directors must not be less than 25%.
5. Candidates for executive management positions must be registered in the insurance brokers register.
6. Among the shareholders, there must be individuals with experience in financial or investment activities, especially in insurance or insurance brokerage, and they must meet additional conditions, whether they are natural or legal persons.

Fourth: Key Documents Required for Incorporation Insurance/Reinsurance Brokerage Companies

1. A technical and economic feasibility study & business plan for the company covering the first five years, including necessary arrangements, estimates of commissions and expenses, production costs, and the technical foundations on which they are based, using the FRA’s designated template.
2. A detailed statement of the sectors the company intends to target, their locations, suitable insurance coverages, estimated premiums and commissions expected from each sector, and each sector’s percentage of total revenues.
3. A certificate confirming that the company’s name is not similar to any existing company.
4. A declaration stating that none of the founders or managers of the company are affiliated with insurance or reinsurance companies or are employed by them.
5. A certificate from a bank confirming that the capital has been deposited.
6. Proof of payment of the application review fee amounting to EGP 20,000.

Once the incorporation application is submitted with all required documents, it shall be reviewed, and a response shall be issued within 22 business days. The response may be: (approval, request for additional documents, or a reasoned rejection). The Decree may be appealed before the Grievances Committee within 30 days from the date of issuance or expiration of the review period.

Fifth: Licensing and Registration Procedures

The practice of insurance or reinsurance brokerage may not commence without obtaining the necessary license and registration in the designated register. Among the requirements for obtaining a license from the FRA:

1. Professional Liability Insurance Policy: Submission of a professional liability insurance policy amounting to EGP 5 million per year for five years for insurance brokerage companies, and EGP 20 million per year for five years for reinsurance brokerage companies.
2. Board of Directors Data: Submission of information about board members, specifically: name, address, nationality, qualification, position on the board, previous experience (particularly in insurance), and ownership percentage in the company’s capital.
3. Disclosure of the existence of any second-degree kinship between any board member and other board members, shareholders, or employees of the company, as well as disclosure of the existence of any conflicts of interest.
4. A copy of the company’s tax card.
5. Proof of payment of the registration and licensing fee:

• EGP 40,000 for the head office
• EGP 8,000 for each branch
• EGP 4,000 for each outlet

The registration in the FRA’s register shall be valid for five years, renewable. Renewal must be requested no later than three months prior to expiration.

Sixth: Compliance and Regularization

Insurance brokers must regularize their status within one year from the effective date of this Decree. This includes:

• Maintaining the registers specified in the Decree, whether in paper or electronic format, including:
  1. Register of policies and commissions
  2. Claims register
  3. Brokers register

Reinsurance brokers are also required to regularize their status within one year from the effective date, including:

• Maintaining the specified registers, whether paper or electronic, including:
  1. Register of reinsurance agreements
  2. Register of facultative operations
  3. Claims register

Seventh: Penalties

In case of violation of the provisions of the Decree by insurance or reinsurance brokers, the FRA may impose the following measures:

1. A warning
2. Revocation of approval to open a brokerage office
3. Suspension or deletion of registration as a broker

The FRA may also impose financial penalties ranging between EGP 50,000 and EGP 20 million, depending on the severity of the violation.

Conclusion

Decree No. 69 of 2025 is considered a pivotal regulatory step for governing the insurance brokerage profession in the Egyptian insurance market. It establishes a precise legal framework that ensures transparency, efficiency, and the protection of clients’ rights.

New and existing companies are obliged to fully comply with its provisions within the specified period. Professionalism in managing this specialized activity is paramount.

For a full review of Decree No. 69 of 2025, click here