New Executive Regulations of the Importers’ Registry Law: Key Regulatory Developments

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Introduction

Following the recent amendments introduced to the Importers’ Registry Law No. 121 of 1982 (the “Importers’ Registry Law”) pursuant to Law No. 4 of 2026 (the “Law Amendment”), published in the Official Gazette on April 2, 2026, and which entered into force on April 3, 2026, the Minister of Investment and Foreign Trade issued the new Executive Regulations of the Importers’ Registry Law pursuant to Ministerial Decree No. 271 of 2026 (the “New Executive Regulations”). The New Executive Regulations was published in the Official Gazette on July 21, 2026, and entered into force on July 22, 2026.

The New Executive Regulations repeal and replace the previous Executive Regulations issued pursuant to Ministerial Decree No. 846 of 2017 and introduce a revised regulatory framework for registration in, and the administration of, the Importers’ Registry.

The New Executive Regulations introduce a number of substantive and procedural changes to the regulatory framework governing the Importers’ Registry. While retaining key elements of the existing regime, the New Executive Regulations seek to modernize and streamline the registration process through greater reliance on digital procedures, and enhancing reporting and compliance requirements applicable to registered importers.

The following sets out the key developments introduced by the New Executive Regulations and its implications for companies engaged in import activities in Egypt.

Key Developments

Express Regulation of Registration of One-Person Companies

While the previous Executive Regulations did not expressly address the registration of one-person companies in the Importers’ Registry, although this corporate form had been introduced under the Companies Law No. 159 of 1981 in 2018. The New Executive Regulations address this regulatory gap by expressly including one-person companies within the scope of the registration framework applicable to companies. In this regard, one-person companies are generally subject to the same registration requirements applicable to partnerships and limited liability companies.

Addressing the Exception to the Egyptian Shareholding Requirement

The Importers’ Registry Law generally requires at least fifty-one percent (51%) of the share capital of a company seeking registration in the Importers’ Registry to be owned by Egyptian nationals (the “Egyptian Shareholding Requirement”).

An exception to the Egyptian Shareholding Requirement was subsequently introduced pursuant to Law No. 173 of 2023, which permits companies whose share capital is wholly or partially owned by non-Egyptians, with Egyptian ownership falling below fifty-one percent (51%), to be registered in the Importers’ Registry. Such registration is subject to a maximum period of ten (10) years. The registration period may be extended for one additional period not exceeding ten (10) years pursuant to a decision of the Cabinet, based on a proposal from the competent Minister.

Against this background, the New Executive Regulations expressly recognize and regulate the registration of companies falling below the Egyptian Shareholding Requirement under the statutory exception.

Transition Towards a Digital Importers’ Registry

The New Executive Regulations introduce several measures aimed at digitalizing and streamlining the administration of the Importers’ Registry. In this respect, the Executive Regulations mandate the General Organization for Export and Import Control (“GOEIC”) to establish, within six (6) months from the date of entry into force of the New Executive Regulations, an electronic platform for registration, renewal, re-registration, and the amendment or updating of importers’ data. Once operational, applications for such procedures shall be submitted through the platform.

In addition, the New Executive Regulations introduce a new requirement for applicants seeking registration in the Importers’ Registry, namely, an undertaking by the company’s legal representative to establish electronic connectivity with the systems designated by GOEIC for the electronic provision of the required information.

The digitalization measures also extend to the corporate information submitted in connection with the registration of one-person companies, limited liability companies, and joint-stock companies. The New Executive Regulations permit reliance on the information available on the website of the General Authority for Investment and Free Zones, subject to verification against the relevant corporate documents submitted by the importer and confirmation of the accuracy of such information.

Collectively, these measures reflect a gradual transition towards a more digitalized and integrated administration of the Importers’ Registry, while maintaining certain documentary and notification requirements pending the full implementation and operationalization of the electronic platform.

Flexibility in Demonstrating Capital Requirements

For the registration of partnerships, limited liability companies, and one-person companies in the Importers’ Registry, a minimum paid-up capital of EGP 2 million is required. Compliance with this requirement may be evidenced by the latest financial statements filed with the Egyptian Tax Authority for the preceding financial year or, where the company has commenced its activities, by a certificate issued by a bank registered with the Central Bank of Egypt confirming the deposit of the company’s paid-up capital.

Importantly, the New Executive Regulations introduce additional means of demonstrating compliance where the minimum capital requirement cannot be evidenced through the foregoing documents. In such cases, companies may rely on the latest paid-up capital recorded in their corporate documents, provided that it corresponds to the capital recorded in the commercial register, or submit their latest audited financial statements accompanied by the auditor’s report confirming compliance with the minimum capital requirement.

Accelerated Processing of Registration Applications/h3>

The New Executive Regulations introduce a defined timeline for processing applications for registration, renewal, and re-registration in the Importers’ Registry. GOEIC is required to decide on a duly completed application within a maximum period of fifteen (15) days from the date of submission of the complete set of required documents. If no decision is issued within the said period, the application shall be deemed rejected.

The decision on registration, renewal, or re-registration shall be issued by GOEIC, published on GOEIC’s website, and reflected in the Importers’ Registry accordingly.

Additional Ongoing Compliance and Reporting Obligations

The New Executive Regulations introduce additional ongoing compliance and reporting obligations for registered importers. In addition to complying with applicable laws and ensuring that imported goods meet the applicable Egyptian standards, importers must include their Importers’ Registry number on relevant contracts, invoices and other business documents.

Importers must also provide GOEIC with detailed information regarding the storage of imported goods, including storage locations, quantities and geographic coordinates, as well as electronic sales invoices and information relating to distributors.

Furthermore, importers are required to submit their annual financial statements, accompanying notes and auditor’s report to GOEIC promptly following their approval and, in all cases, no later than (4) months following the end of the company’s fiscal year. Quarterly financial statements, accompanied by a limited review report issued by the auditor, must be submitted within forty-five (45) days from the end of the relevant reporting period.

Notification of Changes in Legal Form or Tax Registration

The Law Amendment, together with the New Executive Regulations require registered importers to notify GOEIC, using the prescribed form in either paper or electronic format, of any change or amendment to their legal form or tax registration number within sixty (60) days from the date of such change or amendment. The notification must be accompanied by the relevant supporting documents.

Continuity of Import Activity by Heirs

Following the Law Amendment, which allows the heirs of a deceased natural person to re-register in the Importers’ Registry, the New Executive Regulations introduce further conditions and clarifications governing the continuation of the deceased importer’s activity. In particular, the heirs may establish a company to continue the deceased importer’s import activity, provided that the deceased’s import card was valid at the time of death and that the company submits its application for registration within eighteen(18) months from the date of death.

The New Executive Regulations further provide that the newly established company is exempt from the requirements to have been registered in the Commercial Register for at least one year and to submit a tax return evidencing turnover for the preceding year. All other registration requirements remain applicable.

This exception does not apply where the newly established company includes any partners or shareholders other than the deceased’s heirs.