Draft Amendments to the Importers’ Register Law

Amendments to the Importers’ Register Law

On April 2, 2026, Law No. 4 of 2026, amending certain provisions of the Importers’ Register Law No. 121 of 1982 (the “Importers’ Register Law”) was published in the Official Gazette (the “Amendments”).

The Amendments seek to address practical challenges encountered in the implementation and enforcement of the Importers’ Register Law, and to establish a mechanism for the settlement of certain violations thereunder. These Amendments are expected to contribute to a reduction in the number of criminal cases and to alleviate pressure on the Egyptian judiciary.

Principal Provisions of the Amendments

1. Explicit Recognition of Capital and other Amounts Paid in Foreign Currency

The Amendments introduce a new provision to the Importers’ Register Law expressly permitting companies applying for registration in the Importers’ Register to satisfy the applicable statutory capital requirements using the equivalent value in freely convertible foreign currencies, as approved by the Central Bank of Egypt (“CBE”).

This amendment aligns the law with prevailing practice. While the previous statutory text referred exclusively to capital denominated in Egyptian pounds; however, the General Organization for Export and Import Control (“GOEIC”) has, in practice, permitted the registration of companies with capital denominated in foreign currency, provided that such capital, upon conversion into Egyptian pounds, satisfies the prescribed minimum statutory thresholds.

2. Streamlined Re-registration Following Corporate Modifications

Pursuant to the Amendments, the competent authority affiliated with the Ministry of Investment and Foreign Trade is empowered to re-register companies already recorded in the Importers’ Register. This applies upon notification that such companies have undergone changes to their legal form or tax registration number.

For the purposes of the foregoing, such re-registration shall be treated as a mere amendment to the company’s existing registration data, rather than requiring a deletion and re-registration, which constitutes a significant procedural simplification.

3. Continuity of Import Activity by Heirs

The Amendments introduce a mechanism whereby the heirs of a natural person registered in the Importers’ Register shall be entitled to continue the import activities of the deceased.

In particular, where such heirs, whether jointly or individually, establish a company to carry on the same activity, they are entitled to apply for re-registration within a grace period of one (1) year and six (6) months from the date of death, provided that the competent authority is duly notified within the prescribed timeframe.

4. Introduction of a Settlement Mechanism for Violations

A key feature of the Amendments is the introduction of a settlement mechanism applicable to criminal offences under the Importers’ Register Law, including offences subject to custodial penalties. Such offences include, without limitation:

• Conducting import activities without prior registration in the Importers’ Register; and
• Submitting or utilizing false or misleading information in connection with registration or import-related documentation.

The Amendments permit settlement at different stages of the criminal proceedings, with the applicable settlement amount varying depending on the procedural stage at which the settlement is concluded, as follows:

• Prior to the initiation of criminal proceedings;
• Following the initiation of proceedings, but prior to the issuance of a final judgment; and
• Following the issuance of a final judgment.

Any settlement duly concluded in accordance with the above foregoing provisions shall result in the extinguishment of the criminal case and all related legal consequences. In circumstances where a settlement is reached during the enforcement stage, the Public Prosecution is mandated to order the suspension of the execution of the penalty upon full payment of the applicable settlement amount.