الهيئة العامة للرقابة المالية

• This resolution aims to regulate existing business models, enhance consumer protection, and ensure continuous service.
• Newly established companies must obtain a permanent license from the Authority, as mandated by the Unified Insurance Law.
• Temporary license will be revoked if the company fails to regularize its status within one year from now. However, this period may be renewable.
• This resolution is the outcome of extensive public dialogues with all relevant stakeholders, aimed at ensuring and enhancing the legislative impact on the market.
• The company must be a joint-stock entity with fully paid-up issued capital.
• Specialized medical insurance companies must have a minimum issued capital of EGP 10 million when they apply.
• Specialized medical insurance companies must have a minimum in-force portfolio of EGP 100 million when they apply.

FRA Board of Directors, chaired by Dr. Mohamed Farid, has issued resolution No. 90 of 2025. This crucial decree sets out the conditions and procedures for specialized medical insurance companies and healthcare management companies to secure a temporary license. This allows these companies to continue operating provisionally while they work to align their operations with Unified Insurance Law No. 155 of 2024.

This move aims to empower existing companies to keep delivering their vital services without interruption, all while operating within defined regulatory frameworks. It also ensures these companies commit to a clear plan for regularizing their business practices to meet the law’s new requirements. For new companies looking to enter the market, the path remains a direct application to FRA for a permanent license under the Unified Insurance Law.

Companies covered by this resolution must submit an application for a temporary operating license. This temporary status will remain in effect until they fully comply with the Unified Insurance Law and its associated FRA Board resolutions. Importantly, any temporary license will be revoked if a company fails to regularize its status within the timeframes set by the law or by FRA Board resolutions.

In a related and significant development, FRA Board Resolution No. 102 of 2025 has extended the grace period for all entities subject to the Unified Insurance Law, including specialized medical insurance and healthcare management companies. This extension grants them an additional year, effective July 11, 2025, to align with the Law.

FRA conducted several community dialogue sessions with all relevant stakeholders while drafting these new regulations. This extensive engagement reflects FRA’s strategy to ensure and enhance the positive legislative impact on all market participants and to gain practical insights directly from companies operating within the market.

To secure a temporary license, companies must meet several key requirements. First, the company needs to be structured as a joint-stock company with its issued capital fully paid-up, and its equity must not be less than its paid-up capital. For specialized medical insurance companies, there is a minimum capital requirement of 10 million EGP at the time of application. Additionally, these companies must demonstrate that they held contracts extending for at least three years prior to the Unified Insurance Law’s issuance. The regulations also specify that specialized medical insurance companies must have a minimum in-force portfolio size of 100 million EGP when they apply. Both specialized medical insurance companies and healthcare management companies are also mandated to possess the necessary equipment, suitable technological infrastructure and modern information systems for their operations, as determined by FRA.

The resolution further dictates that the company’s management structure must include qualified technical personnel who will serve as the responsible managers. For specialized medical insurance companies, these critical roles include the Managing Director, Underwriting Manager and Claims Manager. In the case of healthcare management companies, the key positions are the Managing Director, Claims Manager and Medical Approvals Manager. All these responsible managers are required to pass specific tests set by  FRA. Furthermore, the auditor for specialized medical insurance companies must be registered in Section One of the Auditors’ Register, as outlined in FRA Board Resolution No. 244 of 2023. For healthcare management companies, their auditor can be registered in Section One or Section Two (A) of the same register.

Companies seeking a temporary operating license from the Authority must submit a comprehensive application package. This package is headlined by a detailed Business Regularization Plan, which needs to include a clear timeline for increasing the company’s capital in line with FRA Board Resolution No. 196 of 2024. This capital increase is crucial and must only occur after any accumulated losses or outstanding loans have been fully addressed. On the other hand, companies are prohibited from distributing any cash dividends to shareholders before they meet these minimum capital requirements, unless they secure prior approval from FRA.

The application also requires a firm Commitment to Data Security and Privacy. This involves pledging to implement all necessary protection and security measures for their operations. This commitment is not just a formality; it is essential for enabling seamless electronic linkage with FRA and for rigorously maintaining the confidentiality and privacy of client data. These robust security measures must be fully in place by the time the company receives its final license.

Applicants also need to provide essential Company Documentation, including an updated copy of their articles of association, a recent commercial register and a copy of their tax card. They must also provide a certificate confirming that no bankruptcy judgments have been issued against the company.

Moreover, statement detailing the shareholder structure is mandatory, along with a pledge to regularize this structure in accordance with relevant FRA resolutions. Furthermore, a statement listing all members of the company’s board of directors must be submitted, accompanied by declarations confirming no criminal convictions or bankruptcy judgments against any of them.

Finally, companies must submit Financial Statements, either annually or quarterly. For specialized medical insurance companies, these statements must be prepared following a comprehensive review and require approval from their designated auditor. The same requirement applies to healthcare management companies. Beyond these core documents, companies must be prepared to submit any additional documentation or data that FRA deems necessary for processing the temporary license application.