Representative Office Staff in Egypt: Social Insurance, Work Permits

Executive summary

• An employer under Labour Law 14 of 2025 is "any natural or legal person who employs one or more workers for a wage" (article 1), and the law applies to foreign workers "in whatever is not governed by a special provision in individual employment contracts or collective labour agreements" (article 1 of the promulgating articles).
• Private-sector workers subject to the Labour Law are insured where the employment relationship is regular and the insured person is at least eighteen (article 2 of Social Insurance and Pensions Law 148 of 2019); the executive regulations list among employees "foreigners subject to the employment laws or the Labour Law" (article 3, item 5).
• The Companies Law's two Egyptian ratios (90% of staff, 80% of pay) bind branches and what is treated as branches under article 170; article 173 on offices does not refer to them. Decree 279 of 2025 caps foreign workers at 10% of the Egyptian workers "in any establishment" (article 9).
• The General Authority for Investment and Free Zones (GAFI) offers one service recommending a work permit for the office's manager or market-research expert and another for its renewal, each at EGP 1,500 per worker; the permit itself is obtained from the foreign work permits office (GAFI Investor Services Centre guide 2026).
• The office notifies the General Administration for Companies annually of its staff and the Egyptians' share of pay (article 321 of the Companies Law regulations), and sends the competent administrative authority a statement of its workers within thirty days of starting work and then every January (article 36 of the Labour Law).

The difference between a representative office and a branch is covered in Branch or representative office in Egypt, registering and striking off the office in Registering and striking off a foreign representative office in Egypt, and tax on its staff's salaries in Representative office tax in Egypt.

The office is an employer under the Labour Law

The Labour Law defines the employer as "any natural or legal person who employs one or more workers for a wage" (article 1, item 3) and the establishment as "any project or facility owned or managed by a person of private law, whatever its type or affiliation" (article 1, item 33). The two groups that article 1 of the promulgating articles takes out of the law's scope, "save where a special provision applies", are workers in the organs of the state and domestic workers and those treated as such. A representative office is therefore, in our reading, an establishment within that definition, and the foreign company employing its staff is an employer.

This includes foreigners. The law applies "in whatever is not governed by a special provision in individual employment contracts or collective labour agreements, to foreign workers within the Arab Republic of Egypt" (article 1 of the promulgating articles), and article 34 of Minister of Labour Decree 279 of 2025 says the same. The office therefore carries an employer's duties: contracts, a file for each worker, records and statements to the competent administrative authority, set out in Egypt's labour office file and Hiring and leaving notices to Egypt's labour office.

Social insurance for Egyptian and foreign staff

The Social Insurance and Pensions Law, in its text as corrected, applies to:

"workers in the private sector subject to the provisions of the Labour Law, provided that the employment relationship binding the insured person to the employer is regular" (article 2, first category, item 3).

The law requires the insured person in that item to be at least eighteen. The executive regulations (Prime Minister's Decree 2437 of 2021) treat the relationship as regular where the work by its nature falls within the employer's activity or lasts at least six months (article 3, item 4), and list in a separate item "foreigners subject to the employment laws or the Labour Law" (item 5). Read together, the two texts mean in our view that a foreign employee of the office is insured if subject to the Labour Law, on the two conditions the law sets for private-sector workers: a regular relationship and a minimum age of eighteen.

The employer applies to the National Organization for Social Insurance (NOSI) on form 2 within two weeks of the start of activity (article 17 of the regulations); the file is described in Registering a new employer for social insurance in Egypt. Its attachments include "any documents showing that the employer's activity has started, such as the commercial register, the company contract or the decision establishing it, the lease, a work order, a supply order or the licence issued for the activity". The list is illustrative, and in our reading the office's GAFI registration certificate and the lease of its premises serve that purpose. The contribution wage and rates are in Egypt's insurable wage in 2026 and Egypt's social insurance contributions. GAFI's Investor Services Centre guide 2026 requires, to strike off an office, "evidence of payment of the State's dues of salary tax and social insurance".

The Egyptian share and the cap on foreigners

Article 174 of Companies Law 159 of 1981 requires that the Egyptians working in Egypt among the staff of "the companies subject to this law" be at least 90% of all their staff, and that their pay be at least 80% of the total pay the company disburses; article 170 binds "branches of foreign companies and what is treated as such" by articles 174, 175 and 176. Article 173 on offices does not refer to them, and in GAFI's consolidated copy of the law it sits under a separate heading, "Representative offices and what is treated as such". Article 321 of the regulations asks only for an annual notice that includes "the percentage of Egyptians' pay". Reading these texts together, in our view no text binds the office to the two ratios of article 174, but it discloses the Egyptians' share of its pay every year.

On the labour side, the minister sets "the maximum proportion for employing foreigners" in establishments (article 70), and Decree 279 does so:

"The number of foreign workers in any establishment, even if it has several branches, may not exceed (10%) of the total number of its Egyptian workers" (article 9).

The office is an establishment as the law defines it, so in our reading it falls within the general terms of this rule. Where one foreigner works there with fewer than ten Egyptians, the foreigners exceed the cap on a literal count, and the exceptions in article 9 should then be explored, among them cases approved by the exceptions committee and endorsed by the minister. They are set out in Foreign work permits in Egypt.

Work permits for the manager and the market-research expert

A foreigner may not work, or be employed, without a permit (article 71 of the Labour Law); its conditions, fees and renewal deadlines are in the article just cited. Under article 3 of Decree 279 the permit is issued "by the competent ministry, or by the labour directorates affiliated to it, or by the offices the ministry establishes for this purpose in other bodies, such as the General Authority for Investment and the General Petroleum Corporation and others".

The guide gives the office two services: "recommendation to issue a work permit for the manager / market-research expert of a representative office", and "recommendation to renew" that permit. The application goes to the Investment Services Sector with the foreigner's details, job and qualification, and with the passport, a power of attorney to deal with government bodies or an authorisation from the manager, a recent statement of the office's staff, their nationalities and jobs, certified by the manager, a copy of the registration certificate, a timetable of the studies, and the work the office has done for the parent company with evidence that it was sent and the parent's opinion of it. For a first permit the parent company's decision appointing the foreigner, notarised, legalised and translated, is added, or the manager's decision where the manager is authorised to appoint staff, and an application for a market-research expert must bear the stamp of the Central Security Administration confirming receipt of the expert's security forms; for a renewal, a copy of the previous permit.

GAFI recommends; the foreign work permits office issues and renews the permit and is, in our reading, one of the offices the ministry establishes in other bodies under article 3. The guide's fee is due to GAFI for its service; the permit fee is set by Decree 279 (article 18).

Periodic staff statements

Article 36 requires the administrative authority to send NOSI a copy of the January data, so the same figures reach both. The guide also asks for a staff statement with the Egyptians' share of pay with every request for a certificate from GAFI. All of these statements should therefore come from a single staff register kept by the office. The next January statements fall due in January 2027.

What this requires

• Opening a file with NOSI within two weeks of the start of activity, with the registration certificate and the lease among the evidence of activity, and contributions for every Egyptian or foreign employee who meets the conditions.
• The workers' statement to the labour directorate within thirty days of work starting at the office, then every January.
• Before hiring any foreigner: whether a permit is needed, whether foreigners would exceed 10% of the Egyptian staff, and an exception sought where needed.
• GAFI's recommendation and then the permit before the foreigner starts work, with a schedule of expiry dates that leaves time for the renewal recommendation and then the renewal on time.
• One register of staff, jobs, nationalities, pay and the Egyptians' share of pay, from which the GAFI, labour and NOSI statements are drawn and which is reconciled with the contribution schedules.
• Keeping proof that contributions were paid, which the guide requires when the office is struck off.

The firm's Social Insurance & Labour Department registers representative offices with NOSI and the labour office, prepares the permit files of their foreign staff with GAFI's recommendations and renewals, and their periodic staff statements, 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.