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Deal by Design
Welcome to this edition of Law Update, focusing on the evolving M&A landscape across the MENA region. With deal activity and value continuing to grow, the region is seeing increased investor interest alongside a changing regulatory environment.
This edition explores key legal and market developments affecting M&A transactions, including regulatory reforms, foreign investment, governance, due diligence and deal structuring across the region.
The Egyptian Financial Regulatory Authority (FRA) has issued Board Decision No. 55 of 2026, establishing a new regulatory framework governing Managing General Agents (MGAs) operating in the Egyptian insurance market.
Effective from 21 April 2026, the Decision introduces a mandatory registration requirement for overseas MGAs that provide reinsurance-related services to insurance establishments in Egypt. The regime places corresponding obligations on Egyptian insurance establishments, which will be prohibited from dealing with MGAs that are not registered with the FRA.
A Managing General Agent is defined as a juristic person authorized to provide reinsurance-related services, including underwriting and claims settlement on behalf of reinsurance companies registered with the FRA, pursuant to a binding authority agreement, for the benefit of insurance establishments operating in Egypt.
The new framework introduces a mandatory registration requirement for overseas MGAs seeking to provide reinsurance-related services in connection with the Egyptian market.
Importantly, the Decision not only regulates MGAs themselves but also places obligations on Egyptian insurance establishments. Insurers and other insurance market participants will no longer be permitted to engage with MGAs that are not registered with the FRA.
As a result, both MGAs and insurance establishments will need to assess their existing arrangements and ensure compliance with the new regulatory framework.
The FRA has established eligibility criteria that MGAs must satisfy in order to obtain registration. These include requirements relating to regulatory oversight in the MGA’s home jurisdiction, professional experience, arrangements with approved reinsurers, and the maintenance of appropriate professional indemnity coverage.
Applicants will be required to submit supporting documentation to the FRA demonstrating compliance with the registration requirements, including information regarding their corporate structure, copies of binding agreement, authorisation arrangements with reinsurers, financial standing, and proposed business activities in Egypt. One key requirement is to have a locally issued PI policy with minimum limit of EGP 40million.
Once approved, registration will be valid for three years and may be renewed, subject to continued compliance with the applicable requirements.
The Decision empowers the FRA Board to de-register an MGA from the register in certain prescribed circumstances. These include, among others, the loss of any registration condition and the breach of obligations in a manner that is harmful to the Egyptian insurance market.
The new framework sets out a transitional provision requiring both insurance establishments and MGAs to reconcile their positions in accordance with the provisions of the said Decision within six months from 21 April 2026, being the date the Decision comes into force. In addition, insurance establishments that currently deal with MGAs are required to provide the FRA with all relevant data concerning those agents within one month of the effective date.
MGAs currently servicing Egyptian insurance business should assess whether they fall within the scope of the new registration regime and begin preparations for registration where required. Likewise, insurers, reinsurers, TPAs, and other insurance establishments operating in Egypt should review their relationships with MGAs and implement appropriate due diligence procedures to verify that any MGA with which they conduct business is duly registered with the FRA.
Our Insurance team regularly advises insurers, reinsurers, intermediaries, and insurance service providers on regulatory compliance matters in Egypt. We can assist with assessing the applicability of the new MGA regime, advising on registration requirements, reviewing existing arrangements, and engaging with the FRA on compliance-related matters.
For further information on how the new framework may affect your business, please contact our Insurance team.
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