Mandatory employment records in Egypt: what to keep and for how long

Executive summary

• Every employee must have a paper or electronic file, kept for at least five years after the employment ends, and until a final judgment if there is a court dispute (article 92 of Labour Law No. 14 of 2025). This is the only retention period the law sets.
• Wage records (article 105), the register of financial penalties (article 153), the overtime register (Minister of Labour Decree 291 of 2025) and the register of daily workplace inspections (article 269) must be kept, on paper or electronically, as must the injury-statistics registers of establishments that file the statistic (Ministerial Decree 126 of 2003, kept in force by article 11 of the issuing articles).
• There is no separate leave register: leave is recorded in the employee's file, and the leave balance must be settled at least once every three years (articles 92 and 125).
• Failing to produce documents to inspectors carries a fine of EGP 5,000 to 20,000 (article 297); breaching the safety provisions that contain the safety registers carries EGP 5,000 to 100,000 (article 296).

The legal framework

Labour Law No. 14 of 2025 (Official Gazette No. 18 (continued), 3 May 2025) has applied since 1 September 2025. What employers call "the labour office" is, in the law, the "competent administrative authority": the ministry responsible for labour, with its directorates and departments (article 1(38)). What is sent to that authority, together with the register of employees with disabilities and persons of short stature, is covered in The labour office establishment file.

Article 11 of the issuing articles provides that, until the new implementing decrees are issued, "the decrees in force on the matter continue to apply insofar as they do not conflict with" the law (our translation). Ministerial decrees made under the repealed Law 12 of 2003 therefore remain in force where nothing has replaced them.

The employee file

The employer opens a file for each employee containing their particulars, wage and any changes, penalties and leave, together with a copy of the contract, any investigation records, supervisors' reports, the pre-employment medical examination and proof of social insurance registration (article 92); the insurance forms themselves are covered in Social insurance Forms 1, 2 and 6. The rule that matters most is retention:

"The employer shall keep the employee's file, on paper or electronically, for at least five years from the date on which the employment relationship ends, and in all cases the file must be kept where there is a court dispute until the case is decided by a final judgment" (article 92, our translation).

For employers of ten or more, the work regulation sets the department responsible for the file, its form and contents, the rules for keeping and handling it, its retention period "without prejudice to the legal provisions in force", and who may see it (article 23 of Minister of Labour Decree 162 of 2026). Reading the two texts together, we take the period in the regulation to be no shorter than five years. The regulation itself is covered in Work regulation and disciplinary penalties.

Wages, leave and working hours

The deadlines for registering a worker and returning the registration certificate, whose number goes in the register of employees, are in Hiring and leaving notices to Egypt's labour office.

The employer is discharged from paying wages only if the employee signs for receipt in the register kept for the purpose or on the payroll sheets, or if the wage is transferred to the employee's bank account; the employer must also give each employee a statement of the components of their pay (article 115).

The law has no separate leave register: a statement of the leave taken is part of the employee's file (article 92). The employer still needs an accurate record of the balance. The leave balance, or pay in lieu, must be settled at least once every three years; an employee whose employment ends before the balance is used is entitled to pay for it; and the right to pay for leave is lost if the employee refuses in writing to take it on the dates notified (article 125).

Occupational safety and work injuries

The law requires two paper or electronic registers: one for the daily inspection, in every shift, of workplaces, especially hazardous ones (article 269(1)), and one listing the hazardous chemicals in use with their data, together with a record of the workplace pollutants employees are exposed to and of hazardous materials and waste (article 249(4)).

Establishments with thirty or more employees must send a half-yearly statistic of ordinary and chronic illnesses, serious accidents and injuries within the first half of July and of January (article 260). We have not found a new decree setting its forms, so Minister of Manpower and Emigration Decree 126 of 2003 remains in force insofar as it is consistent with the law. It requires the establishment "to create specific registers for the data required for each statistic and to record the data as it arises", allows computers to be used, and requires a third copy of each statistic to be kept (article 4). That article concerns establishments with fifty or more employees, and no text links it to the law's threshold of thirty. Reading the two texts together, we take any establishment that must file the statistic to need its registers. Notification deadlines for injuries are in Work injuries and social insurance.

What must be posted, and paper or electronic

The table of the weekly rest day, working hours and rest periods is posted at the main entrances or in a visible place (article 122); the work regulation in a visible place at the establishment, its branches and work sites, for employers of ten or more (article 137); and the rules on employing women in the workplace or where employees gather, if one or more women are employed (article 59).

The text expressly allows electronic form in articles 92, 105, 153, 249 and 269 and in Decrees 290 and 291 of 2025. The employee file may be seen only by those authorised by law, and is produced to the administrative authority or the labour court on request (article 92). Officers with judicial police status may "examine the books and papers relating thereto, and request the necessary documents and data" (article 276), and the employer must provide them (article 277).

Penalties

Every one of these fines doubles for a repeat offence, and under articles 286, 288 and 290 it is multiplied by the number of employees concerned. No penalty article names article 105 (article 287 covers articles 104 and 108, and article 288 covers article 115), nor Decree 291 (article 288 covers article 121 itself). Reading the texts together, we take Decree 290 to be, by its subject, the decree to which article 119 refers, so its register falls under article 288, which penalises breaches of article 119 "and the ministerial decrees implementing it"; and we take a refusal to produce any register to an inspector to fall under article 277, penalised by article 297. Where the employer is a legal entity, the person in actual charge of its management incurs the same penalty if they knew of the breach and their failure in the duties of that management contributed to it (article 298).

What this requires

• A file for every employee, kept for at least five years after employment ends and until a final judgment in any dispute.
• Wage records proving receipt by signature or bank transfer, and a pay statement for each employee.
• Leave recorded in the employee file, the balance settled at least once every three years, and any written refusal kept.
• An overtime register whenever overtime is worked, and a record of presence hours for intermittent work.
• The daily inspection register, a hazardous-chemicals register where chemicals are handled, and statistics registers for those who must file the statistic.
• The working-hours table posted at the establishment, the work regulation at the establishment, its branches and work sites, and any electronic system able to produce any register during an inspection.

The firm's Social Insurance & Labour Department reviews employee files and wage, leave and safety records before an inspection and completes what is missing, as part of its social insurance and labour compliance services.

Mahmoud Nassef, Founder Partner
Chartered Accountant, Ministry of Finance, Egypt

Member, Egyptian Society of Accountants & Auditors
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.