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Decoding the future of law
This Technology Issue explores how digital transformation is reshaping legal frameworks across the region. From AI and data governance to IP, cybersecurity, and sector-specific innovation, our lawyers examine the fast-evolving regulatory landscape and its impact on businesses today.
Introduced by David Yates, Partner and Head of Technology, this edition offers concise insights to help you navigate an increasingly digital era.
As 2026 progresses, the Middle East continues to see meaningful legal and regulatory evolution. Across the UAE, Saudi Arabia, Qatar and Bahrain, and beyond, governments and regulators are refining frameworks that influence how businesses operate, invest and plan for the future, with increasing focus on consistency, application and regional alignment.
Eyes on 2026 brings together analysis of the developments that matter most, offering practical insight into emerging trends and regulatory priorities. The publication is designed to support organisations as they navigate a changing legal landscape and make informed decisions with clarity and confidence throughout the year ahead.
In furtherance of Egypt’s strategic initiative to expand its hotel room capacity by 2030, the Egyptian Government has introduced a new regulatory framework for holiday homes designed to augment the country’s hospitality infrastructure. This framework presents significant investment opportunities for hotel operators, property owners, and investors seeking to participate in Egypt’s growing tourism sector through the establishment or conversion of properties into licensed holiday home operations, particularly in light of the inauguration of the Grand Egyptian Museum. The inauguration of the Grand Egyptian Museum is expected to drive a significant increase in tourist arrivals, with projections indicating growth of ten to fifteen percent (10-15%), further underscoring the timeliness of this regulatory initiative.
The regulatory framework governing holiday homes in Egypt derives from Law No. 8 of 2022 on Hotels and Tourist Establishments (the “Hotels Law“), Law No. 27 of 2023 on the Establishment of Tourism Chambers, and Prime Ministerial Decision No. 705 of 2023. The principal instruments comprising this framework are as follows:
Pursuant to the Holiday Homes Decree, a “Holiday Home” means any unit comprising one or more rooms, suites or villas—whether stand-alone or within a building—providing such essential services as may be prescribed (including, without limitation, housekeeping) and prepared for the reception of Egyptian and/or foreign guests, situated within a designated tourist area or distinguished residential compound.
The “Third Pattern” is a special subcategory under the Third Pattern Decree. It applies to buildings that contain at least eight residential units (apartments or studios) used exclusively as Holiday Homes. The entire building must be dedicated to Holiday Home use for the duration of the license—mixed-use buildings are not permitted. The Ministry has sole authority to determine whether a location is suitable for this category. Properties operating under the Third Pattern are treated as hotel establishments under the provisions of the Hotels Law.
The Holiday Homes Decree sets out minimum standards that all holiday homes must meet:
(a) Entrance and Signage: There must be a proper entrance with signs in two languages showing the property name and unit number;
(b) Lifts: Buildings with units on upper floors must have a working lift that is regularly maintained;
(c) Kitchen: Each unit must have a kitchen or kitchenette with a refrigerator, stove, microwave, dishes, and laundry facilities;
(d) Rooms: Rooms must meet minimum size requirements and include proper beds, emergency exit maps, door peepholes, good lighting, wardrobes, bins, blackout curtains, internet, TV, minibar, and air conditioning or heating;
(e) Bathrooms: Each bathroom must have a sink with mirror, hot and cold water, toilet with bidet spray, shower or bathtub with splash guard, non-slip floors, and towel rails; and
(f) Reporting and Compliance: Operators must register guests through the Ministry’s online system, pay all required taxes and fees, and follow health and safety rules.
For the Third Pattern, there are additional building-level requirements. These include: a dedicated main entrance; proper exterior finishes; a separate entrance for staff and deliveries; accessibility features for guests with disabilities; a reception area sized for the building’s capacity; optional food and beverage service areas; certified lifts; and such other amenities as may be appropriate.
To obtain a Certificate, applicants must submit documents to the Ministry. The required documents differ depending on whether the applicant is an individual or a company. The Holiday Homes Decree sets out the fees for the initial inspection, license issuance and annual renewal—these fees may change over time. Applicants for the Third Pattern may need to provide additional documents as specified in the Third Pattern Decree.
The improvement fee is a fee imposed by the government pursuant to Law No. 222 of 1955. The Improvement Fees Incentives Decree offers an exemption from the improvement fee for projects that establish or convert properties into hotels or Third Pattern holiday homes.
To qualify for this incentive, the project must: (a) receive approval from the Ministry confirming the location is suitable; (b) obtain approval from the Higher Council for Urban Planning and Development; (c) operate the property only as a rental (not for sale); and (d) not sell the land or buildings before starting operations.
The Improvement Fee Incentives Decree also sets deadlines for when operations must begin, which vary based on the project type and number of units. If these deadlines are missed, the full improvement fee becomes payable, plus interest at the Central Bank of Egypt’s rate.
This incentive presents a significant investment opportunity for domestic landlords, international investors and property owners seeking to acquire and convert existing properties into licensed holiday home operations, thereby establishing diversified real estate portfolios within an emerging market segment.
This regulatory regime relating to Holiday Homes presents a compelling investment opportunity for domestic landlords, international investors and property owners seeking to enter Egypt’s emerging holiday home market through the acquisition and conversion of properties into licensed holiday home operations. Egypt’s tourism sector continues to demonstrate robust growth, with the country’s strategic initiatives aimed at expanding hospitality infrastructure underscoring the sector’s long-term viability and investment potential. Furthermore, the operation of licensed Holiday Homes affords investors the opportunity to generate revenue streams denominated in United States Dollars through the accommodation of foreign guests, thereby providing a hedge against local currency fluctuations and enhancing the overall attractiveness of such investments.