A foreign engineer’s arrival date is not necessarily the date on which the engineer may lawfully start commissioning a production line. The company needs to identify the work, the employing entity, the applicable permit or exemption, and the immigration permission before committing to mobilisation.
This guide addresses HR, legal, finance and plant management under Labour Law No. 14 of 2025 and Ministerial Decision No. 279 of 2025. It focuses on corporate work assignments and their continuing controls. The English quotations are working translations from the Arabic provisions; they are not official translations.
1. A work permit and permission to enter and reside for work are separate requirements
Labour Law Article 71, first paragraph:
“A foreign national may not work within the country until obtaining a licence from the competent Ministry and being authorised to enter and reside in the country for the purpose of work. Employers may not employ foreign nationals until that licence has been obtained.”
Article 69 defines work broadly, including subordinate employment, independent work, self-employment and work in a profession, trade or craft. Article 70 subjects foreign employment in the specified establishments and public bodies to the chapter, subject to reciprocity, and allows ministerial exemptions from reciprocity. Decision 279, Article 3, repeats the prior-permit requirement and identifies the Ministry, its labour directorates and its designated offices, including offices at other authorities, as licensing channels.
A business visa, overseas group contract, application receipt or internal approval is not itself the required work authorisation. Equally, ordinary non-working visits should not be automatically classified as employment: assess what the visitor will actually do. An installation or maintenance assignment requires a work-authorisation analysis even if described internally as a short visit.
2. Distinguish exemption from a permit, exemption from recruitment conditions and exemption from fees
Decision 279, Article 4, identifies permit exemptions for specified categories: persons expressly exempt under applicable international agreements within their limits; qualifying embassy, consulate and regional/international organisation administrative staff sent by their national authorities; foreign correspondents; unpaid foreign religious personnel; foreign workers on Egyptian vessels on the high seas outside territorial waters; personnel of the Commonwealth war-graves body; members and experts of the specified architectural and ancient-Egyptian antiquities research institutions and missions; and a foreign investor holding investor residence to conduct the activity under the governing law.
An expatriate employee should not be treated as an exempt investor merely because the employing company has foreign shareholders. Document the individual category and its conditions. Even for a permit-exempt person, Article 71’s final paragraph and Decision Article 5 require notification to the competent labour directorate within seven days of commencing work and upon the end of service. Exemption from a fee under Article 19 is a different issue and does not by itself remove the permit requirement.
3. Prepare the application and satisfy the operating conditions
Decision Article 6 requires the establishment’s application to include evidence of formation, the nature of its work, its activity licence, the foreign national’s documents and a work contract specifying the work, location, wage, benefits, allowances, start and end dates and renewal if extended. Article 6 contains a limited exception from submitting a work contract for foreigners assigned specific work “for a period of six months and not exceeding one year”, and experts working under an international agreement. This concerns submission of that document; it is not a general exemption from work authorisation.
Under Article 7, the conditions include experience appropriate to the licensed profession of at least three years, certified and authenticated by the competent authorities; any professional licence required by Egyptian law; no displacement of national labour; the country’s economic needs and the establishment’s actual need for the expertise.
Article 7(5) — knowledge transfer:
“Establishments authorised to employ foreign experts or technicians shall appoint two Egyptian assistants whose qualifications correspond to the foreign national’s expertise, train them in the foreign national’s work, and prepare periodic reports on their progress.”
The Minister, as the competent authority, may exempt all or some Article 7 conditions on a submission from the competent administration supported by reasons and documents. Until a relevant exemption exists, assigning assistants in name only does not meet the training and progress-report requirements. Retain the appointment, qualification match, training record and periodic reports. The source does not prescribe one universal reporting interval; a company’s monthly training review is an internal control, not a statutory monthly deadline.
Article 8 also restricts specified occupations: tourist guiding and export/customs-clearance work, with the stated Palestinian exception for the latter. Check the actual role rather than assuming every professional activity can be licensed.
4. Calculate the workforce ratio using the correct denominator
Decision Article 9 — the general ceiling:
“The number of foreign workers in any establishment, even where it has multiple branches, may not exceed ten per cent of the total number of Egyptian workers in it.”
The denominator is Egyptian workers, not the combined Egyptian and foreign workforce. For example, 100 Egyptian workers ordinarily support a ceiling of 10 foreign workers under this general rule; 100 total workers do not produce the same calculation. Aggregate the establishment’s branches as the text requires.
Article 9 expressly distinguishes three exceptions:
- Free-zone establishments subject to Investment Law No. 72 of 2017, for which the joint committee at GAFI sets the relevant weightings and controls.
- Small establishments, identified as shops and restaurants, where the competent authority sets a maximum in light of Ministry initiatives following the administration’s submission.
- Cases approved by the exceptions committee and endorsed by the competent authority. Under Article 17, committee recommendations are not effective before that endorsement.
These are not automatic exemptions for every foreign-owned company or every small workforce. Article 73 preserves the Investment Law framework; a special economic-zone operation also needs its own applicable rules considered. This article does not assume that the Suez Canal Economic Zone is the same as an Investment Law free zone.
5. A short technical assignment still needs written approval
Decision Article 20 — a specific task of up to fourteen days:
“An establishment wishing to employ a foreign national to perform a specified task requiring only one day or a few days, up to a maximum of fourteen days, shall submit an application to the competent administration after paying a fee of ten per cent of the remuneration for those works, with a minimum of fifteen thousand Egyptian pounds and a maximum of one hundred thousand pounds. This applies to foreign nationals of all nationalities; the fee is multiplied by the number of tasks performed. The foreign national may not commence the work before obtaining written approval from the Ministry.”
The second paragraph allows the competent authority to waive that fee following a reasoned, documented submission from the administration. A fee waiver is not the same as dispensing with the written approval.
Example: A supplier sends an engineer for one qualifying ten-day commissioning task paying EGP 80,000. Ten per cent is EGP 8,000, so the Article 20 minimum produces a fee of EGP 15,000, absent an approved waiver. Payment or filing alone is insufficient: obtain the written approval before work begins. For an assignment exceeding fourteen days, do not assume that this short-task procedure applies or that splitting the description creates a lawful exception.
6. Budget the licence fee and start renewal early enough
Article 18 normally provides a licence for one year or less and treats part of a year as a full year for the fee. Its ordinary schedule is:
| Year of licensing | Article 18 fee |
|---|---|
| Years 1–3 | EGP 6,000 for year 1; add EGP 1,500 for each following year through year 3. |
| Years 4–6 | EGP 12,000 for year 4; add EGP 1,000 for each following year through year 6. |
| Years 7–10 | EGP 17,000 for year 7; add EGP 1,000 for each following year through year 10. |
| Year 11 onward | EGP 23,000 for year 11; add EGP 2,000 for each following year, capped at EGP 100,000. |
Article 18 separately states EGP 10,000 for the first year in an approved workforce-ratio exception, increasing by EGP 3,000 each following year to a maximum of EGP 100,000. Do not treat an unapproved exception as purchasable merely by paying this amount. The article also permits the competent authority to reduce the fee or extend a licence beyond one year in justified cases on a reasoned, documented submission.
Article 19 makes fee relief subject to reciprocity and identifies Sudanese and Lebanese nationals, Palestinians holding temporary residence for a non-tourist purpose, Italians resident continuously for at least five years, Greek nationals, and persons expressly covered by a treaty fee exemption. For Tunisian nationals it states that the treaty minimum applies, plus the licence-card fee. These conditions must be checked for the individual; nationality alone should not be converted into a universal permit exemption. Article 22 provides EGP 300 for the licence card and EGP 500 for a replacement lost or damaged card, subject to its treaty/reciprocity reservation. The applicable category and any exemption should therefore be established before presenting a total cost quotation.
Article 24 — renewal:
“The foreign national shall submit an application to renew the licence at least two months before its expiry.”
The application goes on the prescribed form to the competent directorate or Ministry office. Renewal for a fourth year and subsequent years goes to the Ministry’s competent administration with reasons for renewal. A reminder three months before expiry is a sensible internal buffer; the legal filing deadline remains at least two months before expiry.
7. Maintain the file after issue: reporting, absence and departure
| Trigger | Required action and timing | Evidence |
|---|---|---|
| Employment continues — Article 31 | Keep the foreign-worker register with identity, passport, profession, qualifications, work, wage, entry and permit details and the two assistants’ names. Supply the Ministry administration with updated detailed foreign-workforce information and its ratio to Egyptian labour. | Current register, updates and submission receipts. |
| First week of January and July — Article 31 | Send the competent directorate the foreign-worker list with nationality, profession, permit number/dates/expiry and assistants where applicable; also the Egyptian-worker numbers/professions supported by social-insurance Form 2 or another official insurance document showing insured Egyptian headcount. | Two lists, insurance evidence and dated filing receipt. |
| Five consecutive working days of unexcused absence — Article 26 | Notify the worker at the residence recorded in the service file. If the employer verifies the worker is not there, make an administrative report at the competent police station and notify the labour directorate. | Attendance record, notice/service evidence, verification and report. |
| Fifteen consecutive days without lawful justification — Law Article 72 and Decision Article 25 | Report to the competent labour directorate and authorities within seven actual working days after that fifteen-day period expires. | Absence calculation and dated notifications. |
| Contract ends or worker leaves — Article 32 | Notify the competent directorate or office within one week and deliver the work licence to its issuing authority. | Departure record, notification and licence handover receipt. |
The five-day trigger uses working days; the fifteen-day trigger uses consecutive days; the subsequent reporting window uses actual working days. Combining these into one “absence deadline” loses an important distinction.
Article 30 includes cancellation grounds such as false application data, use for another profession or employer and administrative verification of fifteen days’ unjustified absence. Article 27 separately describes verification, temporary suspension and cancellation if absence continues for a further fifteen days. HR should not infer from Article 27 that it can ignore the first fifteen-day reporting trigger or promise that cancellation can occur only after thirty days.
On termination of the relationship, Law Article 74 requires return to the country of recruitment at the employer’s expense unless the employment contract provides otherwise. Decision Article 36 prohibits retaining the worker’s passport or personal/identity documents and restricting freedom of movement, and addresses salary deductions and discriminatory treatment. Keep immigration and employment administration separate from coercive retention of documents.
8. The penalty is distinct from a permit fee or regularisation payment
Labour Law Article 293:
“Anyone who contravenes Articles 70, 71, 72 or 74 of this Law and the ministerial decisions implementing them shall be punished by a fine of not less than twenty thousand pounds and not more than one hundred thousand pounds. The fine shall be multiplied by the number of workers in respect of whom the offence occurred and doubled in the event of recurrence.”
Example: If the competent court finds the covered offence occurred in respect of three workers, the undoubled statutory range, applying that multiplication, is EGP 60,000–300,000. That is an illustration of the text, not an automatic assessment against every foreign visitor or a prediction of a court’s findings.
Under Article 298, the person responsible for the company’s actual management faces the relevant penalty where knowledge is proved and breach of managerial duties contributed to the offence. The company is jointly liable for financial penalties and compensation. Article 280 preserves more severe penalties under another applicable law.
Decision Article 23 permits a foreign national who worked without a licence to apply to regularise their position; on approval, it specifies an EGP 15,000 recruitment-condition exemption fee, with a reasoned reduction/waiver mechanism. That provision does not itself say that payment extinguishes Article 293 liability or authorises continued work before approval. Any separate Ministry initiative under Article 35 must be assessed on its actual terms.
What the company should have ready before mobilisation
As recommended internal controls, assign HR ownership of the individual register and deadlines, legal ownership of classification and exemptions, operations ownership of the work description and assistant-training evidence, and finance ownership of the applicable fee calculation. Record the permit or written short-task approval, work-purpose residence position, ratio calculation, exemptions, application and renewal receipts, and the person who authorised commencement. These suggested responsibilities support execution; they are not job titles prescribed by the legislation.
Contact Consortio Law Firm to review the authorisations, ratio position and continuing compliance controls for your foreign assignments.
Sources: Labour Law No. 14 of 2025, Articles 69–74, 280, 293 and 298; Ministerial Decision No. 279 of 2025, particularly Articles 3–9, 17–27, 30–32 and 35–36, from the Arabic copy in the firm’s law library. The Decision was published in Al-Waqa’i al-Misriyya, No. 290 supplement B, on 24 December 2025 and applies from the following day under Article 40. The Law’s operative text was corroborated with the Official Gazette copy hosted by the Egyptian Tax Authority, printed pages 36–37 and 110–111.
Related resource: English translation of Egyptian Labour Law No. 14 of 2025.
General legal information, not advice on an individual application. The controlling Arabic texts, applicable treaty or special regime, and the assignment’s actual facts must be assessed together.
