Egypt media licensing can matter even when a company operates its website and servers outside Egypt. A foreign business should assess the rules before serving the Egyptian market. For international businesses, the first decision is how the service is classified: a foreign website providing media or commercial advertising services may face a different route from a platform covered by the rules for “Social Information Technology Companies”.
The Supreme Council for Media Regulation, or SCMR, administers both routes under its Licensing Regulation, issued by Decision 26 of 2020 and amended by Decision 92 of 2020. Choosing a corporate structure before resolving that classification can leave the business with an office that does not satisfy the applicable requirement.
Operating from abroad does not settle the question
Article 22 addresses qualifying non-Egyptian media outlets and websites that hold a foreign licence or have foreign legal status and wish to conduct activity in Egypt. Article 44 expressly provides an application route for a qualifying company that has no seat in Egypt. Neither provision makes overseas incorporation or overseas hosting a blanket exemption.
Article 22 scope, working translation: the provision covers the specified non-Egyptian websites that “wish to carry on activity within the Arab Republic of Egypt”. The quoted words must be read with the service categories and other conditions in that article.
Start by documenting the actual service. Include its content types, user interaction, advertising, subscriptions, commercial promotion and activity directed at Egypt. Mere worldwide accessibility should not be treated as conclusive on its own. The way the business serves the Egyptian market and the wording of the relevant category need to be considered together.
Two Egypt media licensing routes to assess
The foreign website licence. Article 22 extends beyond news websites. It includes non-Egyptian websites providing electronic commercial advertising services with content promoting works, services, products or persons, within the provision’s other conditions. A commercial directory or promotional platform therefore needs a content-based assessment even if its operator does not supply the advertised goods or services itself. The introductory wording does not make charging users for that content an express condition.
Social Information Technology Company accreditation. The definition introduced by Decision 92 of 2020 concerns companies managing platforms or websites that provide or host news or media services, or broadcast or display artistic works for profit, and enable circulation or sharing of the relevant content between users or with the public on the platform. Article 44 establishes their accreditation procedure. A platform’s precise functions matter; the label “technology company” does not determine the result.
Accreditation is defined as operating without prejudice to other legal procedures and requirements. The regulation does not expressly state that Article 44 replaces an Article 22 licence in every case. Where features engage both provisions, obtain confirmation of the required route or combination of routes before filing or committing to a local structure.
Local representation differs between the routes
For an Article 22 licence, paragraph 3 expressly requires a representation office in Egypt and a legal representative responsible before the SCMR for the applicant and implementation of Council decisions within its competence.
Article 22(3), working translation: “Establishing a representation office within the Arab Republic of Egypt and appointing a legal representative”. The rest of the paragraph makes that representative responsible before the SCMR for the applicant and implementation of its decisions within its competence.
Article 44 takes a different approach to the accreditation file. A company with a seat in Egypt supplies certified incorporation documents, its commercial register and trademark certificate. A company without a seat supplies evidence of authorisation to operate abroad under the applicable foreign law, with Egyptian Ministry of Foreign Affairs authentication. The application is signed by the legal representative or a delegate.
Article 44 itself does not repeat the Article 22 representation-office requirement. That textual distinction is useful, but it is not a universal assurance that a foreign platform needs no Egyptian presence. Other applicable licences, the SCMR’s classification and the company’s separate regulatory obligations remain relevant.
Egypt media licensing fees depend on the category
Article 22(8)(f) specifies EGP 3 million, or its foreign-currency equivalent, for a website containing promotion of goods, products and services. The same amount appears in separate categories for promotion of persons or social networking, and qualifying on-demand content funded through subscriptions or advertising. Other Article 22 categories carry different fees. A licence may cover more than one service subject to satisfying each service’s requirements and paying its prescribed fee.
These are category-specific figures, not a general fee for every foreign website or for Article 44 accreditation. Confirm classification, the applicable current tariff and treatment of multiple services before approving the budget. Article 44 itself does not state an accreditation fee.
Plan the application timetable accurately
Under Article 44, the General Secretariat refers the application to the competent committee; review includes the opinion of the National Telecommunications Regulatory Authority and approval of the relevant authorities. The Council’s decision period is 30 days from receipt of a file complete with all data and documents. This is not a promise of approval 30 days after an initial submission.
If the application is incomplete, the Council must notify the applicant within 15 days from presentation of the committee’s report. Accreditation lasts five years, with renewal requested six months before expiry. The Article 22 licence also lasts five years and is renewable under the same procedures and conditions; the six-month accreditation renewal rule should not be automatically transferred to that separate route.
Build the operating controls alongside the filing
An accredited operator must provide a transparent complaints process, document complaints and inform the parties of decisions. Article 45 requires a report every six months, in Arabic and English, on handling harmful-content complaints. It also requires notification of changes to accreditation application data within 30 days.
The Article 45 removal rule runs from notification: harmful content must be removed within 24 hours, subject to its express provision for establishing within that period that the facts relied on are incorrect. Where the Council refers the complaint to a competent authority and a violation is established, removal must be immediate. Content ordered deleted or removed must be retained for four months as evidence. The business needs an escalation process and controlled evidence retention, not simply a delete button.
Article 22 separately requires a mechanism to block the specified harmful or infringing content. Article 22(7) sets the period as “within twenty-four hours from the date of notification of blocking” (working translation). Its licence-data changes must be notified within 30 days by registered letter with acknowledgment of receipt. Article 23 also requires the licensed service to become available within three months of licence effectiveness, alongside the other applicable authorisations. Assign each route’s obligations to named legal, operations and content teams.
What happens if licensing requirements are breached
The consequence depends on the provision breached. Article 2 of the decision issuing the Licensing Regulation treats a breach of that Regulation or the sanctions regulation identified there as a material breach of licence conditions. That provision does not itself set a single fine for every breach.
Law 180 of 2018 provides separate statutory consequences. Article 6 addresses establishing or managing websites in Egypt and managing Egyptian offices or branches of websites operating from abroad without the required SCMR licence. For a breach of that article, the Council may take the prescribed measures, including licence cancellation, suspension of website activity or blocking where there is no valid licence. The article provides for challenge before the Administrative Court.
Article 105: a violation of Article 6, or the other articles expressly listed in Article 105, carries a fine of EGP 1 million to EGP 3 million. The court must also order closure and confiscation of the equipment, devices and components used to commit the offence. In a repeat offence, both the minimum and maximum penalty are doubled.
Article 106: where a newspaper, media institution or website is proven to have breached the nature of its licensed activity, the fine is EGP 1 million to EGP 2 million. The court must also order licence cancellation or website blocking.
These provisions should not be presented as an automatic penalty for every foreign platform or every breach of Article 44 accreditation. The facts, the legal classification and the particular offence must match. The classification review should identify the exposure before launch, and again when the service or its revenue model changes.
Prepare a clear decision file before launch
- Describe each service, who creates content, how it is shared and how the business earns revenue.
- Map those functions against Article 22 and the Article 1 definition underlying Article 44.
- Obtain written clarification of classification, local representation, supporting documents and fees where the application is uncertain.
- Prepare corporate, trademark, authority and authentication documents for the confirmed route.
- Test complaint handling, notified-content response, evidence retention and reporting responsibilities before the service operates.
A generic example illustrates the distinction: adding public user-to-user media sharing to a previously static promotional directory may change the classification analysis. The legal review should follow the product’s functions as they develop, rather than relying indefinitely on its original description.
SCMR licensing does not resolve data protection, tax, telecommunications or other sector-specific requirements. Consortio can help an international business assess its platform, coordinate regulatory clarification and select a suitable Egyptian compliance structure. Contact Consortio to discuss the service and its planned activity in Egypt.
Legal references
Law 180 of 2018: Articles 6, 105 and 106. SCMR Decision 26 of 2020: issuing Article 2 and Licensing Regulation Articles 1, 22 and 23. Decision 92 of 2020: additional definitions and Articles 44–46. References are to the Arabic provisions; English descriptions are explanatory. The sanction provisions discussed above remain subject to their specific statutory conditions. The full schedule of administrative measures in Decision 16 of 2019 is not reproduced here.
