Social insurance arrears in Egypt: surcharges, instalments, disputes

Executive summary

• Each month's contributions fall due on the first day of the following month. Late payment attracts a monthly additional amount until the end of the month of payment, at the average yield on Treasury bills and bonds in the previous month plus 2%, waived if payment is made within fifteen days (article 121 of Law No. 148 of 2019 and article 71 of its executive regulations).
• The National Organization for Social Insurance (NOSI) may allow a debt to be paid in instalments after an administrative seizure or against a bank guarantee, and the additional amounts keep running until payment (article 132 of the Law and article 79 of the regulations).
• Stopping payment of three consecutive instalments entitles NOSI to cancel the arrangement, and all outstanding instalments then fall due at once (article 80 of the regulations).
• The last general waiver of additional amounts we have found, under Law No. 173 of 2020, ended its final phase in February 2021, and we have found none in force since.
• A dispute over a claim goes to the disputes committees for amicable settlement before the courts (article 148), and a referral does not relieve the employer of paying the undisputed amounts on their due dates (NOSI President's Decision No. 7622 of 2025). The penalties chapter of the Social Insurance Law contains no provision for settling its offences by reconciliation.

How the debt arises

The employer pays the contributions for their employees, which "include the share the employer bears and the share the employer must deduct from the insured person's wage" (article 70 of the regulations issued by Prime Ministerial Decree No. 2437 of 2021).

A claim assessed after an inspection on the findings of NOSI's inspectors is covered in Social insurance inspection in Egypt, the late Form 6 amount in Egypt's social insurance Forms 1, 2 and 6, and the insurable wage and the rates in Egypt's insurable wage and Egypt's social insurance contributions.

Additional amounts: rate and period

Article 121 provides that "in the event of delay in paying any of the amounts referred to, the person obliged to pay, including the State's administrative apparatus and public authorities, shall owe a monthly additional amount for the period of delay from the due date until the end of the month of payment". It is computed at the average of Treasury issues of bills and bonds in the month before the month in which payment is due, plus 2%; the regulations specify "the average yield on Treasury issues" (article 71).

• The waiver in the same article: the additional amount is waived "if payment is made within fifteen days of the due date" (article 121).
• The period runs to the end of the month of payment, whatever the day of payment in that month.
• Instalments are covered: the rule applies to "any of the amounts referred to", which include instalments of overdue amounts, so a late instalment attracts an additional amount.
• The rate moves with the yield on Treasury bills and bonds. Neither the Law nor the regulations state a figure or name a body that publishes it, so ask the competent NOSI office for the computation in each claim.

Instalments: conditions and cancellation

The basis is article 132 of the Law: NOSI "may allow the amounts due from the person concerned to be paid in instalments, under the conditions and arrangements set by the executive regulations of this Law". The conditions are in article 79 of the regulations:

• Security: an administrative seizure on the employer's assets sufficient to pay the debt, or a guarantee from an approved bank for the amount, valid for the instalment period and for the outstanding balance. Instalments without seizure or guarantee are allowed only for amounts due in respect of civil servants in the State's administrative apparatus, public authorities, public institutions and their economic units.
• Additional amounts: "the instalment decision does not affect NOSI's right to collect additional amounts ... from their due date until the date of payment". Instalments do not stop the additional amounts.
• Who decides: the authority competent to grant instalments is set by decision of the President of NOSI.
• Period and down payment: neither the Law nor the regulations set a maximum period or a down payment for employers' debts, although article 80 refers to "instalment periods", so ask the competent office for the terms in force. The five years in article 133 of the Law concern insured persons, pensioners and beneficiaries.

NOSI may cancel an instalment decision in four cases (article 80 of the regulations):

1. Bankruptcy, liquidation, emigration or final departure from Egypt. 2. Execution by sale against the employer's assets at the request of another creditor, whether the seizure is administrative or judicial. 3. Stopping payment of three consecutive instalments. 4. Other reasons warranting cancellation.

On cancellation, unpaid instalments and those not yet due become payable at once, and are collected by enforcement or from the bank guarantee; the debt may be rescheduled once the reasons for cancellation cease. The employer may pay in one sum or over a shorter period, and the additional amounts are then recomputed to the date of payment.

Waivers of additional amounts

Law No. 148 of 2019 and its regulations contain no general waiver of additional amounts for employers other than payment within fifteen days of the due date. The last general waiver we have found was granted by law and has ended:

Counting the periods from the Law's entry into force on 17 August 2020 (articles 1 and 4), the phases ran from 17 August to 15 October 2020, from 16 October to 14 December 2020, and from 15 December 2020 to 12 February 2021. At the date of this review we have found no law or decision in force granting a general waiver since then; a waiver cannot be assumed.

Disputes and amicable settlement

NOSI has "committees to examine disputes arising from the application of this Law", formed, with their rules of procedure, by decision of the President of NOSI after approval by its board. Before going to court, employers must ask NOSI "to refer the dispute to those committees for amicable settlement" (article 148).

NOSI President's Decision No. 7622 of 2025 (Al-Waqa'i al-Misriya No. 6, 8 January 2026) formed a disputes committee in each NOSI region. The request for referral goes to the competent region or office on the form attached to NOSI's guide to insurance services, against a receipt or by registered letter with acknowledgment of receipt, with the documents supporting the dispute, and the committee must complete its review within thirty days of receiving it (articles 3 and 5). Decision No. 7621 of 2025, published in the same issue, formed committees to examine employers' objections to claims assessed on NOSI's findings.

For a claim assessed on NOSI's findings, the committee stage is preceded by an objection within thirty days of the notice; referral to the committee is requested within thirty days of notice of rejection, and the committee's decision may be challenged in court within thirty days of its issue; the details are in the inspection bulletin referred to above. NOSI notifies the employer of the committee's decision and adjusts the amounts accordingly (article 120 of the Law and article 65 of the regulations).

• Effect on payment: the account becomes final and the amounts payable once these deadlines pass (article 120). Neither the objection nor the request for referral relieves the employer of paying the amounts due on their due dates, other than the disputed amounts (article 3 of each of Decisions No. 7621 and 7622 of 2025). We found no provision suspending the additional amounts during a dispute: they run from the due date until payment (article 121).
• Correction after the account is final: finality does not prevent NOSI from adjusting the amounts if it finds it has overstated them, by a reduction decision of the President of NOSI or the competent deputy (article 65 of the regulations).
• Reconciliation in offences: the penalties chapter (articles 164 to 170) contains no reconciliation provision. Its offences include intentionally failing to pay amounts due to NOSI by giving incorrect data or concealing data, with a fine of EGP 20,000 to 50,000 (article 166), and failing to insure an employee, or insuring them for other than their actual periods and wage, with a fine of EGP 20,000 to 100,000 on the person actually managing the employer, doubled for a repeat offence (article 168).

Collection and the employer's exposure

• Privilege and administrative seizure: amounts due to NOSI "carry a privilege over all the debtor's assets, movable and immovable, and are paid before judicial costs", and NOSI may collect them by administrative seizure (article 132).
• Interrupting limitation: NOSI's rights are time-barred after fifteen years (article 147), and the period is interrupted by any act showing that NOSI is pursuing its dues, in particular a demand to the debtor by registered letter with acknowledgment of receipt, or an administrative seizure.
• Transfer of the business: the establishment, with all its tangible and intangible elements, secures NOSI's dues in whoever's hands it is; the successor is jointly liable with the previous employers, up to the value of what passed to them where only one element is transferred (article 138).

The social insurance certificate, and what prevents its issue, is covered in The social insurance certificate in Egypt.

What this requires

• Pay each month's contributions within the first fifteen days of the following month; nothing else avoids the additional amount.
• For any claim: ask for a breakdown of principal, additional amounts and their periods, and check it against the wage register and payment receipts before the objection deadline.
• Pay the undisputed part on its due date without waiting for the dispute to end: an objection or referral does not suspend it, and the additional amounts run on it until payment.
• Before applying for instalments: arrange a bank guarantee valid for the whole period, or accept an administrative seizure on assets sufficient to cover the debt.
• Pay instalments with current contributions every month; stopping three consecutive instalments allows NOSI to cancel the arrangement.
• When buying a business: obtain NOSI's certificate of no debt before signing, since the successor is liable for its debts.

The firm's Social Insurance & Labour Department reviews NOSI claims and their additional amounts, and prepares objections, committee referrals and instalment applications, 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.