
Social insurance certificate in Egypt: where required, what blocks it
Where is Egypt's social insurance certificate required, and what stops NOSI issuing it? Law 148 of 2019, the no-debt certificate on a transfer, and liquidation.
By Social Insurance & Labour Department · 14 October 2026 · 9 min read
Executive summary
- The National Organization for Social Insurance (NOSI) must give a private-sector employer a certificate showing that it is up to date with contributions for all its employees, renewed annually and displayed in a visible place at its premises, for a fee of EGP 10 (article 136 of Social Insurance and Pensions Law No. 148 of 2019 and article 306 of its executive regulations).
- All State bodies must suspend dealings with employers until the certificate is produced (article 136); the regulations confine the suspension to the services designated by a high committee formed by NOSI (article 306).
- The regulations expressly tie to the certificate the payment of a contractor's dues, fishing cards and boat licences, and licences for private-sector land-transport drivers and their vehicles (articles 206, 233 and 246), and make dealings with quarry and salt-works operators conditional on evidence that contributions have been paid (article 207).
- When an establishment changes hands, the successor's liability for the previous employers' debts can be avoided only by a NOSI certificate showing that the establishment owes nothing (article 138).
- In a liquidation before the General Authority for Investment and Free Zones (GAFI), the administrative bodies, NOSI among them, state the company's obligations within 120 days of the liquidator's request, and expiry of that period without a statement discharges the company (article 6 of Investment Law No. 72 of 2017).
The certificate in the texts, and who issues it
In practice it is called the "insurance position certificate" (شهادة الموقف التأميني) or "clearance" (براءة الذمة). The Law and its executive regulations, issued by Prime Ministerial Decree No. 2437 of 2021, describe it by what it shows, regular contribution for all employees, and the core text is article 136:
"The Organization shall give private-sector employers, for a fee not exceeding ten pounds, a certificate showing that they are regular in their contributions to the Organization for all their employees; they shall display this certificate in visible places at their premises, and the certificate shall be renewed annually."
Article 122 requires a private-sector employer to display "the certificate showing payment of its contributions to the Organization" and leaves its particulars to the regulations. Article 306 of the regulations sets the fee at EGP 10 and prescribes Form 45 for the certificate, headed "Certificate of payment of social insurance contributions".
The certificate is issued by the competent NOSI office and approved by its manager. It records the employer's NOSI number, allocated when the establishment is registered, the contributions paid and the receipt, the period they cover, and the certificate's period of validity and expiry date, which the form leaves for the office to fill in (Form 45). Neither the Law nor the regulations set a time for issuing it. NOSI's online service catalogue has no page for this certificate (15 October 2026); it does list "View establishment account statement" and "Detailed establishment balance enquiry".
It is a different document from the NOSI letter stating the number of insured Egyptian employees that GAFI asks for in some of its services (GAFI Investor Services Centre guide, 2026).
Where the certificate is required
The general rule is in article 136: "All State bodies shall suspend dealings with employers or insured persons until they produce the certificate showing their participation in the Organization." Article 306 of the regulations sets out how: NOSI forms a high committee to list the services that ministries and public bodies provide to employers and insured persons outside the State administration and the public and public-business sectors, the committee designates the services that may be suspended until the certificate is produced, and NOSI is to link its databases with those bodies through the government digital exchange (G2G) within two years of the regulations taking effect. NOSI has published no list of these services on its website, and we found nothing in its official publications showing whether that link is in place. Neither the Law nor the regulations name business licensing in general among the matters suspended pending the certificate; instead, the regulations name specific cases:
| Case | What the text makes conditional on the certificate | Article |
|---|---|---|
| Contracting works | Payment of each instalment, interim certificate or the final payment under the final account | 144 of the Law, 206 of the regulations |
| Quarries and salt works | Dealings by the leasing, contracting or licensing body with the operator or contractor, on "evidence of payment of social insurance contributions" | 207 of the regulations |
| Fishing | Issue or renewal of fishing cards and boat licences | 233 of the regulations |
| Private-sector land transport | Drivers' licences, vehicle licences and operating permits | 246 of the regulations |
For contracting works, Form 45 names the contract and the commissioning party, and records "the value of the final account ... and the commissioning party may not pay amounts exceeding this value". Notifying NOSI of the contract, computing its contributions and the commissioning party's joint liability are covered in Temporary and contracting workers in Egypt: social insurance rules.
Article 206 of the regulations also requires the commissioning party's notice to NOSI of each contract to attach the contractor's declaration that it will insure all workers on the contract, "under article (23) of Law No. 182 of 2018 regulating contracts concluded by public bodies". Article 23 of that Law requires the administrative body to obtain from the bidder a declaration, placed in its technical envelope, "showing its commitment to insure the workforce under the prevailing social insurance laws, where the nature of the operation so requires". At bid stage, then, the text asks for a declaration of commitment, not the certificate; any further documents a tender requires are set by its own tender conditions.
The no-debt certificate on a transfer
An establishment, with all its elements and in whosever hands, guarantees all amounts due to NOSI. The successor is jointly liable with the previous employers, whether they owned or rented the premises, and, where one element of the establishment passes to it by sale, merger, inheritance or otherwise, up to the value of what it received. Article 138 then provides:
"Liability under the foregoing may be avoided only by the person to whom the establishment or the premises passed producing a certificate issued by the Organization on a date before the dealing in the establishment, showing that the establishment had no debt on the date on which the establishment or the premises passed to that person."
Article 312 of the regulations requires an employer dealing in an establishment or business premises to check with NOSI whether it carries debts of previous employers, and refers to a certificate issued "on the date of the dealing". In a purchase, acquisition or merger, the safer course is to obtain the certificate before signing and to have it cover the date the establishment passes.
What stops the certificate being issued
Neither article 136 nor article 306 lists grounds for refusal, so they follow from what the certificate attests: regular contributions for all employees, and payment of the contributions due for a stated period.
- Unpaid contributions: Form 45 records that the employer "has paid the contribution due to the Organization" by a receipt and for a specific period, so the certificate cannot cover an unpaid period.
- Uninsured employees: the certificate shows regularity "for all their employees", which cannot be said while any employee is not insured, and that is what an inspection uncovers. The form deadlines are in Egypt's social insurance Forms 1, 2 and 6.
- Late notice of end of service: for each month of delay in notifying NOSI that an insured employee has left, a private-sector employer owes an additional amount of 20% of the last month's contribution (article 142 of the Law and article 20 of the regulations), which is an amount due to NOSI.
- An open inspection claim: a NOSI claim computed on its own investigations becomes final and payable once the time to ask for the disputes committee, or to challenge its decision in court, has passed (article 120). The text does not say what effect a pending objection has on a request for the certificate.
- Missed instalments: NOSI may cancel an instalment arrangement if three consecutive instalments are missed, or on bankruptcy or liquidation, and every instalment then becomes payable at once (article 80 of the regulations). No text settles whether an employer who keeps up its instalments gets the certificate. Instalment rules are covered in Social insurance arrears in Egypt: surcharges, instalments, disputes.
The penalties chapter of the Law imposes no fine for failing to display the certificate; the consequence of not having it is practical: a suspended service or a payment withheld.
Liquidation, strike-off and closing the NOSI file
In a liquidation before GAFI, the competent administrative bodies must notify GAFI and the company in liquidation of its obligations within 120 days of the liquidator's request, and "expiry of this period without a statement of those obligations" discharges the company (article 6 of the Investment Law). At the close of the liquidation, GAFI's Investor Services Centre guide (2026) asks for the letters sent to the tax authority, NOSI and customs, with 120 days having passed or a reply received, and the liquidator's declaration that no obligations were notified; for partnerships, the notices must have been delivered at least 120 days before the date of the minutes. To strike off a representative office, the guide asks for "evidence of payment of the State's dues of salary tax and social insurance". The liquidation steps are in Voluntary liquidation and strike-off of an Egyptian company.
Closing the establishment's file with NOSI is a separate step. Under NOSI's published procedure for "ending an establishment's subscription", the employer applies with evidence that the activity has ended, such as the liquidation decision or the deletion from the commercial register; the office's inspection section makes field enquiries; a committee decides whether the activity has ended; and, where it ended earlier, the establishment's account is adjusted.
What this requires
- Reconcile the establishment's NOSI account statement with actual payments well before the certificate is needed, and settle any differences.
- Check that Form 1 has been filed for every employee and Form 6 for every leaver; a late Form 6 costs 20% of the last month's contribution for each month.
- Resolve any claim based on NOSI's investigations, by objecting in time or by paying, before the contract or payment date.
- On contracting works: have the certificate issued on the correct final-account value, and ask for one at the new value if the final account increases.
- Before buying or merging with an establishment, or taking over premises used for a business: obtain a no-debt certificate dated before the dealing and covering the transfer date.
- On liquidation: notify NOSI, with the tax authority and customs, as soon as the liquidation is entered in the commercial register, diarise the 120 days, then apply to end the establishment's subscription.
The firm's Social Insurance & Labour Department reviews an establishment's social insurance position, clears what stands in the way of the certificate, and checks an establishment's debts to NOSI before it is bought or merged, 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.
