Auditors of Egypt's insurance brokers and experts: FRA Decision 172

From 11 September 2026, the auditor of a company carrying on the activities of insurance brokerage, reinsurance brokerage, expertise in risk assessment and in inspecting and assessing damage, and expertise in insurance consultancy, as referred to in the decisions of the Board of the Financial Regulatory Authority (the FRA) that regulate those activities, must be one of those registered in section one, or in branch (A) or (B) of section two, of the FRA's register of auditors. This is the rule of FRA Board Decision No. 172 of 2026, approved by the Board at its session of 5 August 2026 and published in Al-Waqa'i Al-Misriya Issue 199 (continued) (A) on 10 September 2026; it applies from the day after its publication (article 2 of Decision 172). The decision has one substantive article; its second article deals with publication and entry into force.

The rule is a condition the auditor must meet. An auditor registered only in branch (C) of section two does not meet it, nor does an auditor who is not on the FRA register, even if registered on the general register of accountants and auditors. It matters to the company when it appoints or reappoints its auditor, and to the auditor when accepting the engagement.

Companies covered by the decision

Article 1 of Decision 172 defines the companies by the activities they carry on. There are four:

• insurance brokerage;
• reinsurance brokerage;
• expertise in risk assessment and in inspecting and assessing damage;
• expertise in insurance consultancy.

The article limits these activities to those "as referred to in the decisions of the FRA Board regulating those activities" (unofficial translation, as are the other quotations in this article). Alongside the Unified Insurance Law issued by Law No. 155 of 2024, the decision's preamble cites three Board decisions on these activities: Decision No. 69 of 2025 on the professional rules and standards for registering and carrying on insurance brokerage or reinsurance brokerage; Decision No. 25 of 2026 on the conditions, rules and procedures for registering and practising as a consulting insurance expert; and Decision No. 54 of 2026 on the conditions, rules and procedures for registering and practising as an expert in risk assessment and in inspecting and assessing damage in insurance.

Sections of the FRA register of auditors

Decision 172 refers to "the register of auditors organised by FRA Board Decision No. 244 of 2023", the decision reorganising the rules on registration, continued registration and removal in the FRA's register of auditors, published in Al-Waqa'i Al-Misriya Issue 2 (continued) (A) on 2 January 2024. We take its sections from the consolidated copy the FRA publishes, as last amended on 21 May 2025, in which article 2 stands as published in 2024. Decision No. 108 of 2026 (Al-Waqa'i Al-Misriya Issue 152 (continued), 15 July 2026) did not touch that article; it added a paragraph to article 8 only.

Article 2 divides the register into two sections. Auditors in section one audit companies and bodies licensed to carry on non-bank financial activities, "taking section two of this article into account", companies that have offered their securities for public subscription, and companies with securities or financial instruments listed on an Egyptian stock exchange. Only auditors in section one may audit the financial statements of companies in which the companies or bodies listed in that section hold 25% or more of the voting rights, directly or indirectly. Auditors in section two audit private insurance funds, and civil associations and foundations licensed to carry on microfinance, in three branches:

The thresholds in the table relate to the funds and associations each branch audits, not to the companies covered by Decision 172, which names section one and branches (A) and (B) without distinguishing between those companies by size or activity. The registration conditions for each section and branch are in article 3 of Decision 244; some concern the number of joint-stock or capital companies the applicant audited in the years before applying. Articles 4 and 5 set special cases for registration in section one.

The companies required to appoint an auditor, how the auditor is appointed, the bars to appointment, and the general rules of the FRA register are covered in Egypt's statutory audit requirement.

Existing appointments and the rest of Decision 244

Decision 172 has no transitional provision for an auditor appointed before 11 September 2026 who is not registered in section one or in branch (A) or (B), or for the audit of a financial year under way on that date. There are two views, and no express provision settles the point. The first is that the condition applies from the decision's entry into force to every auditor of these companies, even one appointed earlier, so that only an auditor who meets it may report after that date. The second is that an appointment validly made before the decision runs to the end of its term, and the condition applies at the next appointment or reappointment. Until the point is settled, we recommend that the company check its current auditor's registration now and, if the auditor is not so registered, seek the FRA's guidance before the report is issued.

Decision 172 deals only with the sections of the register and does not refer to the other provisions of Decision 244. Those provisions, including annual appointment and the limit of six consecutive years on reappointment (article 8 of Decision 244), apply within the scope set by article 1 of Decision 244, the first category of which is "companies and bodies licensed to carry on non-bank financial activities". In our view, the companies covered by Decision 172 fall within that category, because the Unified Insurance Law allows the FRA to license these activities through companies formed for the purpose (articles 131, 136 and 141 of that Law), so those provisions apply to their auditors. The other view requires nothing of their auditors beyond registration in the sections Decision 172 names.

Before appointing or reappointing the auditor

• Check the company's activity against the four activities in article 1 of Decision 172 and against the decision regulating that activity.
• Check the section or branch in which the current auditor is registered on the FRA register, and do the same for any auditor proposed for appointment or reappointment.
• Choose an auditor from section one if a company or body listed in that section holds 25% or more of the company's voting rights, directly or indirectly, because article 2 of Decision 244 reserves the audit of its financial statements to auditors in that section.
• For an auditor registered only in branch (C): review the conditions for registration in section one or in branch (A) or (B) under Decision 244 before accepting an engagement from these companies.

The firm's Audit & Assurance Department checks whether the decision applies to a company's activity, and in which section of the FRA register a proposed auditor is registered, before the appointment is put forward.

Nehal Saied, Partner
Chartered Accountant, Ministry of Finance, Egypt

Member, Egyptian Tax Society
Member, Egyptian Society for Public Finance and Taxation

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Disclaimer: This bulletin is prepared for general information on the legislation in force at the date of its publication. It does not constitute a professional opinion or tax or legal advice on any particular matter, and it should not be relied upon in place of advice based on an examination of the circumstances of each case. Nassef & Partners International accepts no responsibility for any action taken, or refrained from, in reliance on its contents. The positions stated remain subject to subsequent legislation and decisions.