News Middle East25 Aug 2025

Egypt:Regulator spells out conditions for registering non-resident foreign reinsurance brokers

| 25 Aug 2025

The Financial Regulatory Authority (FRA) has issued a decision regarding the terms and criteria for registering non-resident foreign reinsurance brokers.

Insurance and reinsurance companies may not deal with reinsurance brokers that are not on the registration list.

The decision (No. 158 of 2025) says that:

To be registered on the list, a non-resident foreign reinsurance broker must be a legal entity whose head office is located outside Egypt, and must be licensed to carry out reinsurance brokerage activities by a regulatory body that exercises similar powers to the FRA in the field of insurance. No measures must have been taken against the broker by the regulatory body to which he is subject during the three years preceding the application for registration on the list.

In addition, the equity of this broker shall not be less than its issued and paid-up capital according to the latest financial statements. The broker shall have previous experience in the field of reinsurance brokerage, and it shall have a business history with a foreign reinsurance company whose rating is not less than ‘A’ and operating in a country whose international credit rating is not less than ‘BBB’ ??or equivalent. It shall have a work team with experience and competence in the field of reinsurance and reinsurance brokerage.

According to the decision, for an intermediary to be registered, none of its founders, major shareholders, ultimate beneficiaries, or members of its board of directors must be included on negative lists related to local or international sanctions.

A fee of EGP25,000 ($517), or its equivalent in a foreign currency approved by the Central Bank of Egypt, must be paid for the services of examining and studying the registration application or renewal.

Registration application procedures

The procedures for applying for registration on the list include submitting an application form, along with documents demonstrating that the conditions stipulated in the decision have been met, in addition to submitting a model reinsurance brokerage services contract concluded/to be concluded between the broker and the establishments operating in the Egyptian insurance market for treaty reinsurance operations.

A technical feasibility study related to the broker's activity in the Egyptian insurance market is also required, including, at a minimum, the broker's business plan, targeted operational plan, and the extent of their contribution to the transfer of technical expertise. The Authority may request the broker to prepare a comprehensive presentation detailing the contents of the feasibility study. The Authority also requires a professional liability insurance policy from an insurance company operating in Egypt with a liability limit of EGP20m upon initial registration. Upon renewal, the policy value shall be determined based on the broker's average business in Egypt over the previous three years.

This should also include a statement of the transactions the broker has brokered for Egyptian insurance and reinsurance facilities during the three years before the registration application. This statement should include the companies it has dealt with, the value of the balances collected from Egyptian insurance and reinsurance facilities, and the compensation balances due to them. This clause excludes brokers wishing to operate for the first time.

It also requires submitting a certified statement that includes the broker's ownership structure, the names of its board members and executive directors, and their contact information, enabling the Authority to identify the ultimate beneficiary. The broker also pledges to notify the Authority immediately if any of this information is amended.

The broker's most recent financial statements, in Arabic or English, must also be submitted, along with a statement from the reinsurance companies with which the broker deals, authorising the broker to collect premiums and pay compensation on their behalf. This is in addition to any other information or documents that the Authority deems necessary to submit to decide on the application.

The registration period on the list is three years, and the registration may be renewed for similar periods.

Reinsurance brokers' obligations

A reinsurance broker registered with the FRA is committed to complying with the legislation issued related to its activity, as well as those related to combating money laundering and terrorist financing, and not to assign any reinsurance operations in accordance with the provisions of this decision except to reinsurers registered with the Authority.

The reinsurance broker is to avoid conflict of interest and maintain the confidentiality of data and the privacy of information related to contracting with insurance and reinsurance facilities.

It is to provide advice and consultation to insurance and reinsurance facilities regarding reinsurance programmes available in the insurance and reinsurance markets, whether local or foreign, while clarifying the reasons for choosing these programmes and explaining the conditions and exceptions they include, and providing a comparison between the coverage and prices included in them and other alternative programmes, when requested to do so.

The broker is also obligated to disclose to insurance and reinsurance establishments the names of the reinsurance companies (branches of companies) that have subscribed to the risk, along with a statement of the subscription percentage for each of them, and any commissions, discounts, or privileges for each reinsurance company (branch) separately, immediately upon completion of the risk distribution, and to submit documents proving their acceptance of the risk.

The broker is also obligated to assist in distributing the risk among the various reinsurance markets, as well as to contribute to negotiations related to the settlement of claims and disputes between insurance or reinsurance establishments and reinsurance companies (branches of companies), in addition to notifying insurance and reinsurance establishments immediately of any reasons that may affect the obligations of reinsurers to compensate for the risks assigned to them.

The broker has to notify the FRA in the event of any change in the conditions or documents required for registration with the Authority or its renewal, as well as to provide the Authority with any data or documents it requests within the period it specifies.

The Authority also requires insurance and reinsurance companies, when dealing with reinsurance brokers, to provide the Authority with a copy of the contractual reinsurance brokerage services agreement concluded with the broker, and to immediately notify the Authority of any violations committed by the broker, including violations of any of the legislation governing the activity, in addition to notifying the Authority immediately upon termination of its contract with the broker, regardless of the reason.

Administrative measures

If a broker is proven to have violated or breached any of their obligations or pledges submitted to the Authority, or to have lost one of the conditions for registration on the list, a warning will be issued regarding the violations attributed to them, and a time period will be specified to eliminate the causes. This will be in addition to a temporary suspension from accepting new transactions for a period not exceeding three years, in addition to deletion from the list, with re-registration not permitted until after a period of no less than six months and no more than five years has passed, in addition to final deletion from the list.

The broker may also be delisted if they fail to mediate in reinsurance transactions for Egyptian insurance or reinsurance facilities for three consecutive years, without a justification acceptable to the Authority.

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