The Financial Regulatory Authority (FRA), under the leadership of Mohamed Farid, has issued Decision No. 90 of 2025, introducing a temporary licensing framework for specialist medical insurance companies and healthcare programme management firms. This initiative is intended to facilitate continued operations by these entities while they align with the provisions of the Unified Insurance Law No. 155 of 2024. According to a statement by the FRA, the new measures aim to support existing service providers within a defined regulatory framework, ensuring continuity while mandating a structured path toward full compliance. Firms newly entering the market must apply directly for permanent licensing under the same law. Under the decision, companies must submit an application for temporary licensing, committing to a detailed plan for achieving full regulatory alignment. If firms fail to meet the requirements within the designated timeframe, their temporary status will be revoked. A grace period for compliance has been granted through FRA Decision No. 102 of 2025, extending the deadline to 11 July 2026. The licensing conditions were developed following multiple rounds of stakeholder consultation, with the FRA emphasizing the importance of practical implementation and alignment with market dynamics. To qualify for a temporary licence, companies must be established as joint-stock entities with fully paid-up capital and shareholder equity at least equal to the paid-in capital. Specialist medical insurance firms are required to have a minimum capital of EGP 10m at the time of application. Additionally, these firms must demonstrate a portfolio of long-term insurance contracts valued at no less than EGP 100m, with contracts in place dating back at least three years before the law's enactment. Applicants must also demonstrate adequate operational infrastructure and up-to-date IT systems appropriate for their business activities. A qualified administrative team is mandatory. For medical insurance firms, this includes a managing director, an underwriting officer, and a claims officer. Healthcare programme administrators must appoint a managing director, a claims officer, and a medical approvals officer. These individuals are subject to FRA-administered competency evaluations. Auditors must be selected from the FRA's approved registry—Section I for insurance companies, and either Section I or II(A) for healthcare administrators. In addition, companies are required to submit a comprehensive compliance plan detailing the timeline and strategy for capital increases in accordance with FRA Decision No. 196 of 2024. No profit distribution to shareholders is permitted until capital requirements are fulfilled, unless explicitly authorised by the FRA. The application process also requires a full set of supporting documents, including an updated company statute, a recent extract from the commercial registry, a valid tax identification number, and legal proof of no prior bankruptcy rulings. Firms must also disclose their shareholder structure and provide board member declarations confirming the absence of criminal or bankruptcy history. Audited financial statements—either annual or quarterly—must be included, and the FRA reserves the right to request additional documentation as needed. Through this decision, the FRA seeks to maintain market integrity while ensuring that firms transition smoothly into compliance with the new insurance framework.
