Start with the law now in force
Egypt’s Unified Insurance Law No. 155 of 2024 is the starting point for a new insurance-market project. Its issuing provisions apply to insurance, reinsurance and connected insurance services and professions, and assign establishment, licensing, supervision and oversight of those activities to the Financial Regulatory Authority (FRA). They also repeal the former insurance supervision law No. 10 of 1981 and other listed statutes. A market-entry memo that simply copies the old law’s licensing checklist is therefore unsafe. The legal form, activity and implementation decisions must be checked against the current regime before a company signs distribution or reinsurance agreements.
Define the activity before planning the structure
“Entering insurance” can mean different things: underwriting, reinsurance, acting as an intermediary, administering claims, or purchasing group cover for an operating business. The first two involve the risk carrier; others involve a service provider or policyholder. Do not treat one license or registration as permission for every role. Write down who accepts risk, who signs the policy, who collects premiums, who deals with the insured and who handles claims. Ask Egypt-qualified counsel to match each entity and activity to the FRA’s current licensing or registration requirements, including decisions issued after the 2024 law.
Before negotiations, map ownership, funding, governance, data flows, outsourced tasks and any cross-border service arrangements. Ask whether the proposed company needs to hold the risk on its own balance sheet or instead works under a risk carrier’s policy; the distinction changes the licensing question, contracts, capital planning and how it deals with customers. Document the proposed business lines and geographic reach separately. A plan that says only “insurance services” is too broad to check against a precise license. Keep a dated list of the regulatory decisions and guidance actually reviewed, and recheck it before signing the final contracts.
For a group policy, separately identify each insured entity, territory, exclusions and claim-notice route. An attractive premium is not enough if the named insured, covered operations or available evidence do not match the business’s real exposure. A useful comparison table puts the stated coverage trigger beside real operating events: damage at a subcontractor site, a loss discovered after renewal or a claim made against an affiliate. Those are questions for the particular wording, not promises that any of those events are covered. Set out who in the organization can submit notices, how they are archived and how the insurer’s acknowledgment is tracked.
Review the contract as an operating process
Collect the proposed policy wording, schedule, endorsements and claims procedure in one folder. Compare their definitions, exclusions, sub-limits, deductibles and notification conditions with the actual risk. Identify which version prevails if a proposal, a quotation and an issued policy differ. For a claim, record the date of the event, discovery, notification, insurer response and all loss evidence. Do not assume that a broker’s summary amends the insurer’s issued wording. If a proposed endorsement is essential, obtain its final text and confirm its place in the issued set before relying on it. Compare limits per claim and in aggregate, and note any waiting periods or prior-event wording if present.
If a claim notice has to travel through a broker or administrator, record the date and recipient at every handoff. A missing step is harder to reconstruct after the underlying documents have been dispersed.
For an intermediary or service arrangement, allocate responsibility for client communications, complaints, record retention and handover if the relationship ends. Check whether a proposed provider’s FRA status covers the precise service, not merely its trading name. Keep a dated record of the license or register check and the regulatory decision relied on; a change after signing may require a revised operational plan.
Assign a named team member to maintain that record; it should link each corporate entity to its role, the relevant regulatory status, the permitted activities and the contracts through which it operates. On renewal or a product change, repeat the check instead of assuming the earlier status covers the new activity.
The decision gate before launch
- Role: write a one-line description of every entity’s insurance activity.
- Authority: confirm the current FRA license or registration for that role and the applicable post-2024 decisions.
- Document set: compare issued policy terms, distribution agreements and claims process with the actual business.
- Escalation: decide who will preserve notices and resolve a disputed coverage interpretation before a deadline passes.
For related work, see our insurance practice and corporate and commercial practice.