Registering a new employer for social insurance in Egypt
When must a new business open its NOSI file, and with which forms? The two-week deadline, enrolling each employee, the first payment and the penalties.
Executive summary
- An employer is any natural or legal person who employs one or more workers covered by the Law as employees (article 1 of Social Insurance and Pensions Law No. 148 of 2019), so the obligation starts with the first employee.
- The employer applies to the National Organization for Social Insurance (NOSI) for the establishment's enrolment on Form 2 within two weeks of the start of activity, with a signature form, evidence that the activity has started and a notification for each employee (article 17 of the executive regulations).
- Each employee who joins afterwards is notified within two weeks of joining (article 19 of the regulations).
- Each month's contributions fall due on the first day of the following month, and no additional amount is charged if they are paid within fifteen days of that date (article 121).
- Failing to insure employees, or insuring them on other than their actual periods or wages, is punishable by a fine of EGP 20,000 to 100,000 on the person actually responsible for management, doubled for a repeat offence (article 168).
Who is bound, and when
The Law defines an employer as "any natural or legal person who employs one or more workers subject to item (i) of article (2)" (article 1(2)), which covers private-sector workers subject to the Labour Law where the employment relationship is regular and the worker is at least eighteen (article 2). A new business therefore enters the social insurance system with its first employee, not at any particular size.
The deadline runs from the start of activity: "the employer must apply to the Organization for enrolment within two weeks of the date on which activity starts" (article 17 of the executive regulations issued by Prime Ministerial Decree No. 2437 of 2021).
An employer with branches is subject to a special rule: a branch located within a different police district or administrative unit is treated as a separate employer in its dealings with NOSI, and the employer may apply on Form 10 to unify the branches, subject to conditions including that staff move between branches and that the business is up to date with its payments (article 16 of the regulations).
The establishment file: forms and documents
The application is made on Form 2 in three copies, together with (article 17 of the regulations):
| Document | Detail |
|---|---|
| Signature form (Form 11) | Signatures of the employer or of those responsible for correspondence and forms, approved and stamped, or an electronic signature |
| Evidence that activity has started | "such as the commercial register, the company contract or its establishment decision, the lease, an operating order, a supply order or the licence issued for the activity", and evidence of the employer's capacity for businesses other than sole proprietorships |
| Notification of each employee (Form 1) | With the birth document or a copy certified against the original |
Data and forms may be submitted electronically under an electronic signature (article 12 of the regulations). NOSI is to set a timetable for requiring employers to file electronically, by a decision of its President with the approval of its board (article 13), and article 18 makes the provision of wage and contribution data monthly on an electronic file subject to that same decision. We have not found that decision issued as at the date of this review.
A new employee
Once the file is open, the employer submits each employee's data, wage and contributions on NOSI's forms, with the birth document and a copy of the employment contract if there is one, within two weeks of the employee joining (article 19 of the regulations). The same deadline applies to trainees, apprentices, students on summer employment schemes and workers under eighteen, who are covered by work-injury insurance (article 45 of the Law). An employee with a previous contribution record files a statement of it on Form 4 (article 15 of the regulations).
Contributions run from the first full month: "no contributions are due for the month in which employment starts unless it is a full month" (article 70 of the regulations), and a private-sector employee's contributions are computed on the wage for the month he joined until the following January, then on each January's wage.
The first payment and the recurring dates
The employer pays each month's contributions, its own share and the employee's share deducted from pay (article 70 of the regulations), "on the first day of the month following the month in which they fall due"; late payment attracts a monthly additional amount at a rate equal to the average of Treasury bill and bond issues in the preceding month plus 2%, waived if payment is made within fifteen days of the due date (article 121 of the Law). In 2026 the general private-sector rates on the insurable wage are 18.75% for the employer and 11% for the employee (articles 19, 36, 46, 70 and 86 of the Law).
Three dates then recur: Form 2 each January with the changes in employees' data and wages (article 18 of the regulations), Form 6 within a week of any employee leaving (article 20), and the monthly payment. The two periodic dates, January and the monthly payment, are also in the Egypt tax and social insurance compliance calendar.
The consequences of delay and omission
- "Contributions are computed on the basis of the data in these forms" (article 120); where the employer does not submit them, contributions are computed on the last statement filed and then on the findings of NOSI's inspectors (article 64 of the regulations).
- Failing to submit data on employees' names, wages and contributions: a fine of EGP 20,000 to 50,000 on the person actually responsible for management, doubled for a repeat offence (article 167).
- Failing to insure any employee, or insuring him on other than his actual periods or wages: a fine of EGP 20,000 to 100,000, which also applies to charging employees any share of insurance costs not provided for by the Law, with repayment of what they bore; the fine is doubled for a repeat offence (article 168).
What this requires of the employer
- Open the establishment file within two weeks of starting activity, even with a single employee, with Form 2, Form 11, the start-of-activity documents and Form 1 for each employee.
- Notify each new employee within two weeks of joining, including trainees and workers under eighteen.
- Insure the actual wage from the first full month, and pay each month's contributions within the first fifteen days of the following month.
- Keep a separate file for each branch in a different administrative area, unless NOSI approves a request to unify them.
- File Form 2 in January, and Form 6 within a week of any employee leaving.
The firm's Social Insurance & Labour Department opens new employers' files with NOSI, prepares their forms and tracks their monthly contributions, as part of its payroll and social insurance services.
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.