What the 2026 Executive Regulation of the Importers Register Law No. 121 of 1982 Means for Your Business

Egypt’s new Importers Register framework introduces important changes for businesses operating in the import sector. The reforms open the door to greater foreign ownership, introduce a more digital registration process, and set clearer timelines, while also bringing additional ongoing compliance requirements for registered importers.

The Minister of Investment and Foreign Trade issued Ministerial Decree No. 271 of 2026, promulgating a new Executive Regulation to the Importers Register Law No. 121 of 1982 (the “New Executive Regulation”). The New Executive Regulation replaces the previous Executive Regulation issued under Ministerial Decree No. 846 of 2017 (the “Previous Executive Regulation”) and gives effect to the amendments introduced by Law No. 4 of 2026, which required the Minister of Foreign Trade to amend the Executive Regulation within 30 days from the date the Law came into force

Against this background, this article highlights the main changes introduced by the New Executive Regulation and how they differ from the position under the Previous Executive Regulation.

1. Digital Transformation of the Importers Register

One of the changes introduced by the New Executive Regulation is the move towards a more digital registration process. Under the Previous Executive Regulation, registration procedures were handled manually, with no framework for electronic filing or verification.

The New Executive Regulation changes this approach by requiring the competent authority to establish an electronic platform for submitting registration applications within six months from the date it enters into force. It also provides for the electronic integration of company incorporation data with the General Authority for Investment and Free Zones (“GAFI”), allowing the relevant authorities to exchange information electronically and reducing the need for physical documentation.

2. Reduction of Foreign Ownership Restrictions

The New Executive Regulation introduces an important change for foreign investors seeking to carry out import activities in Egypt. Under the Previous Executive Regulation, companies were generally required to be at least 51% Egyptian-owned in order to register in the Importers Register, with financial leasing companies being the main exception.

The New Executive Regulation provides greater flexibility for foreign-owned companies. Companies with less than 51% Egyptian ownership, including wholly foreign-owned companies, may now register in the Importers Register for a period of up to 10 years. This period may be renewed once for an additional 10 years by a decree of the Council of Ministers.

This gives foreign investors greater flexibility when structuring their presence in Egypt, as majority or full foreign ownership no longer prevents their company from accessing the Importers Register, subject to the requirements and time limits set out under the New Executive Regulation.

3. Recognition of Single-Person Companies

The New Executive Regulation also expands the types of companies that may register in the Importers Register. While the Previous Executive Regulation did not recognize single-person companies as a separate category eligible for registration, the New Executive Regulation expressly allows them to register.

This change gives investors greater flexibility in choosing the corporate structure through which they carry out import activities in Egypt, particularly for businesses owned by a single individual that may not be structured as a traditional multi-shareholder LLC or JSC.

4. Business Continuity Following the Death of a Sole Trader

The New Executive Regulation introduces a mechanism that allows the heirs of a deceased sole trader, or some of them, to continue the same import activity through a newly incorporated company. This is available where the deceased’s import registration was valid at the time of death and an application for re-registration is submitted to the General Organization for Export and Import Control (“GOEIC”) within one and a half years from the date of death.

To facilitate the continuation of the business, the newly incorporated company is exempt from the requirement to have been registered in the commercial register for at least one year and from the requirement to submit a tax return showing its business volume for the previous year.

5. Mandatory Timeframe for Registration Decisions

The New Executive Regulation introduces a specific timeframe for deciding applications for registration in the Importers Register. Unlike the Previous Executive Regulation, which did not set a deadline for the General Organization for Export and Import Control to decide on an application. However, the New Executive Regulation requires a decision to be issued within 15 days.

If no decision is issued within this period, the application will be deemed rejected. The New Executive Regulation also requires registration decisions to be published on GOEIC’s official website

This gives the applicants a clearer timeline for the registration process and allows businesses to plan their import activities with greater visibility as to when a decision on their application should be expected.

6. Greater Flexibility in Supporting Documentation

The New Executive Regulation gives the applicants more options when it comes to the documents used to demonstrate their capital or business volume. Under the Previous Executive Regulation, the applicants were required to rely on a limited set of documents, mainly tax returns and commercial register extracts, with no alternative where these documents were unavailable.

The New Executive Regulation takes a broader approach by allowing other forms of supporting evidence to be submitted, including the latest financial statements, bank deposit certificates, or audited financial statements accompanied by the auditor’s report.

The applicants therefore have more options for demonstrating their financial position and meeting the supporting documentation requirements for registration.

7. Expanded Ongoing Compliance Obligations

Ongoing compliance requirements for registered importers were relatively limited under the Previous Executive Regulation, focusing primarily on the requirement to include the Importers Register number on business documents.

The New Executive Regulation introduces a wider set of obligations. Registered importers are now required to provide the GPS coordinates of their warehouses, use electronic invoices, issue distribution invoices that identify the relevant distributor, submit quarterly reviewed financial statements, and provide audited annual financial statements.

Importers will therefore need to ensure that these requirements are incorporated into their day-to-day operations and financial reporting processes to maintain compliance following registration.

8. Significant Increase in Administrative Fees

The New Executive Regulation introduces higher administrative fees across the Importers Register process: (i) the fee for first-time registration or re-registration is now EGP 5,000; (ii) the renewal fee is EGP 2,000; and (iii) a separate fee of EGP 1,000 applies for each commodity group.

Other administrative fees include: (i) EGP 500 for amendments or recording changes to registered information, except for the addition or modification of commodity groups; (ii) EGP 500 for the publication of a registration, renewal, or amendment; and (iii) EGP 100 for obtaining a copy of the importers register record or a negative certificate.

These fees represent a considerable increase compared to the Previous Executive Regulation, where registration or re-registration cost EGP 500, renewal EGP 200, each commodity group EGP 100, amendments EGP 10, publication EGP 10, and official extracts EGP 5.

9. What Should Businesses Do Now?

Businesses considering incorporating a company in Egypt to carry out import activities, as well as existing importers approaching the renewal of their registration, should take the New Executive Regulation into account when planning their next steps.

For new market entrants, the changes to foreign ownership requirements and the recognition of single-person companies provide more options when deciding how to structure an importing entity in Egypt. Businesses should consider the structure that best fits their operations and confirm that the applicable registration requirements can be met before proceeding with the application.

Existing importers should review their current arrangements ahead of renewal, particularly in light of the additional ongoing compliance requirements, revised supporting documentation, and increased administrative fees introduced by the New Executive Regulation.

With the registration process also moving towards electronic filing and a defined 15-day timeframe for decisions, preparing a complete and consistent application from the outset will be increasingly important for both new registrations and renewals.

10. How Shehata and Partners Can Help?

Shehata and Partners Law Firm can assist businesses looking to incorporate or expand their import activities in Egypt, from choosing the appropriate corporate structure and assessing registration requirements to preparing and submitting Importers Register applications.

We also support existing importers with renewals, amendments, and ongoing compliance requirements, helping businesses navigate the new framework and address the practical steps required for their operations in Egypt.

Law Update

Authors

Author

Hesham Kamel

Author

Omar Selim

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