Introduction
The Importers Register is a regulatory register maintained by the General Organization for Export and Import Control (GOEIC), in which all persons and entities wishing to import goods into Egypt must be registered. Registration in the Importers Register is a key legal requirement for carrying out import activities and is subject to specific eligibility criteria and ongoing compliance obligations under Egyptian law. The framework governing the Importers Register is set out under Law No. 121 of 1982 (the “Importers Register Law”), which regulates the conditions, procedures, and requirements for registration and continued listing.
Law No. 4 of 2026 (the “2026 Amendment”) introduces some substantive amendments to the regulatory framework under the Importers Register Law, which governs registration and compliance requirements in the Importers Register.
The following provides a summary of the key amendments introduced under the 2026 Amendment.
Recognition of Foreign Currency Equivalents for Financial Thresholds
Before the issuance of the 2026 Amendment, t the Importers Register Law used to require the applicants, individuals or legal entities, to meet certain financial thresholds as a condition for registration. In particular, an Individual was required to demonstrate a minimum business volume of no less than EGP 2 million, as evidenced by the tax return submitted to the Egyptian Tax Authority, while a legal entity was required to demonstrate a minimum business volume of no less than EGP 5 million.
In this regard, the 2026 Amendment introduced a key change allowing the amounts stipulated under the Importers Register Law to be satisfied by their equivalent value in freely convertible foreign currencies accepted by the Central Bank of Egypt. The 2026 Amendments offers greater flexibility in the application of the financial thresholds, facilitate compliance for foreign investors and entities operating in foreign currencies, allowing applicants to meet the minimum capital and turnover requirements using foreign currency equivalents, rather than being strictly limited to Egyptian Pounds.
Amendment of Registered Data
The Importers Register Law requires importers to notify the GOEIC of any changes or amendments to the data recorded in the importers register within 60 days from the date such changes occur.
In this context, the 2026 Amendment aims to facilitate the update of registered data without requiring the undertaking of a new registration process. Accordingly, where a company registered in the Importers Register changes its legal form or its tax registration number, GOEIC may record such a change, provided it is notified within the prescribed 60-day period.
Such registration of the change shall be treated as an amendment to the existing registration, rather than a new registration, in accordance with the applicable procedures. This approach ensures the uninterrupted continuity of the importer’s registration, streamlines the administrative Process, and confirms that such changes do not create a new legal status, but rather constitute an update of the registered data.
Facilitated Re-Registration for Heirs to Ensure Continuity of Import Activities
The Importers Registration Law provides that an importer’s registration shall be struck off if any of the conditions required for registration are no longer met, including in cases of the death of a natural person or the dissolution of a legal entity licensed to import.
In this context, the recent amendment introduces an exception whereby the heirs of a deceased natural person may establish a company to carry out the same business activity of the deceased within 18 months from the date of death and apply for re-registration in the Importers Register.
In such case, the newly established company shall be exempted from the requirements set out under the Importers Register Law, namely: (i) that the company must have been registered in the commercial register for at least 1 year, and (ii) that its minimum business volume, as evidenced by the tax return submitted to the Egyptian Tax Authority, shall not be less than EGP 5 million.
The 2026 Amendment, therefore, facilitates business continuity, reduces entry barriers for heirs, and allows the continuation of the deceased importer’s activity without being subject to the standard qualification requirements applicable to newly established companies.
Settlement of Offence's
The Importers Register Law provides for the publication of final criminal convictions issued in relation to the offences stipulated therein, at the expense of the convicted party. These offences include importing goods for trading purposes without registration in the Importers Register, submitting false data in relation to registration or its renewal, and obstructing the competent authority from exercising its inspection powers.
The 2026 Amendment establishes a settlement mechanism for such offences. It allows the GOEIC to settle such offences at different stages of the criminal proceedings, subject to payment of specified amounts, as follows:
i. before the initiation of criminal proceedings, against payment of an amount not less than the minimum prescribed fine and not exceeding one-third of its maximum.
ii. after the initiation of criminal proceedings and before a final judgment is rendered, against payment of an amount not less than 3 times the minimum prescribed fine and not exceeding two-thirds of its maximum.
iii. after a final judgment has been issued, against payment of an amount not less than the maximum prescribed fine and not exceeding double its maximum.
Such a settlement would result in the extinguishment of the criminal case and all related legal consequences, as applicable. In addition, where a settlement is reached during the enforcement stage, or even after a final judgment has been rendered, the Public Prosecution shall order the suspension of the execution of the penalty.
Accordingly, this amendment introduces a flexible enforcement mechanism that allows for the resolution of certain offences through financial settlement, reduces litigation burdens, and provides incentives for early compliance while preserving the authority’s regulatory oversight.
Amendment of the Executive Regulations
The 2026 Amendment entered into force on 3 April 2026 and requires the amendment of the current executive regulations by 3 May 2026, in order to give a full legal effect to the new provisions.
Is your import registration ready for the importers Register Law No. 4 of 2026?
Whether you need to update your registered data, assess your eligibility under the commercial register law 2026, explore foreign currency thresholds, or navigate a settlement process,
Shehata & Partners is ready to deliver the sharp, tailored counsel your business requires. Contact us through our email: info@shehatalaw.com or our website: http://www.shehatalaw.com today for a confidential consultation and let us ensure your import registration is fully compliant, commercially resilient, and ready for the road ahead.
