As labor markets evolve and reliance on recruitment intermediaries grows, we need stronger regulatory frameworks to govern this activity and protect market integrity, and curb unlawful practices. This requirement was prompted by the rise in labour exploitation, particularly in overseas recruitment. In addition, the widespread use of online job platforms created a new reality that calls for flexible and effective legal regulation.

Within this framework, Ministerial Decree No. 272 of 2025 (the “Decree”) institutionalizes the State's strategy to reform the recruitment ecosystem by implementing strict licensing and oversight regimes for both traditional and digital agencies. By fostering operational transparency and safeguarding worker rights, the Decree reflects a modern legislative trajectory that embraces digital transformation while balancing economic freedom with robust social protections.

The Decree raises pivotal questions about whether this new framework can effectively monitor the market, solve practical challenges, and dismantle informal recruitment networks. This article provides a comprehensive analysis of the decree's legal structure, its core mechanisms, and its overarching effect on local and global labor markets.

Private Recruitment Agencies are companies that specialise in selecting and placing workers with third parties in accordance with the provisions of the Labour Law.
Online Recruitment Agencies are private agencies that place Egyptians in jobs, at domestic and international levels, via websites, web pages, online platforms, or mobile apps.
A labor supply contractor is any entity or individual that supplies workers or job seekers to employers without obtaining a license to do so from the Ministry of Labor.

Scope of Application of the Decree:

This Decree governs all domestic and international recruitment entities, subject to alignment with relevant international labor conventions. Authorized recruitment activities may be conducted by the following entities:

1. Ministries and public agencies, with respect to their employees.

2. Egyptian public-sector, public-business-sector, and private-sector companies, with respect to their employees, in connection with contracts they enter into with foreign entities within the scope of operations and the nature of activities.

3. Private recruitment agencies organized as joint-stock companies (JSCs), limited partnerships, limited liability companies (LLCs), or sole proprietorships licensed by the Ministry.

4. Online recruitment agencies licensed by the Ministry of Labor.

Regulation of Private Recruitment Agencies Pursuant to the Decree

In order to obtain a license to conduct recruitment operations, at domestic and international levels, private recruitment agencies must be organized as JSCs, limited partnerships, LLCs, or sole proprietorships.

If a business wants to operate in Egypt, its issued or paid-up capital must be at least EGP 250,000, and it must be wholly owned by Egyptians.

If a business wishes to conduct recruitment, whether at domestic and/or international levels, its capital must not be less than EGP 500,000. The absolute majority of the founders and members of the board of directors must be Egyptian nationals who collectively own at least 51% of the company’s capital.

Legal Requirements for Private Recruitment Agencies to Obtain a Licence for Domestic and/or International Recruitment:

Legal representatives of recruitment agencies must submit an application for a licence to carry out recruitment operations, at domestic and international levels, to the competent authority (the Department of Labor Recruitment Agencies “DLRA”), using the form provided for this purpose, accompanied by the following documents:

The company's memorandum and articles of association.

2. An official statement of the names and nationalities of the founders, members of the board of directors, and relevant managers.

3. Criminal records of founders, members of the board of directors, and relevant managers.

4. A copy of the company’s tax ID card and an official extract from the company’s commercial registry.

5. Six photocopies of the national ID cards of the company’s board members and relevant managers.

6. A registered lease agreement, or a deed of ownership registered with the Real Estate Registry for the company’s headquarters.

7. A power of attorney for the applicant, accompanied by a copy of the applicant’s national ID number.

8. With regard to maritime recruitment, the following documents shall be attached:

- A certificate of scientific and practical expertise in the field of maritime activities for the managers and staff of the company engaged in the recruitment of seafarers, issued by a body specialising in maritime transport.

- Technical approval of the Maritime Transport and Logistics Sector of the Ministry of Transportation.

The application is recorded by the competent authority (the “DLRA”) in a paper or electronic registry. The application is reviewed to ensure that all required documents are included. The authority is required to notify the applicant of the acceptance or rejection of the application, with the reasons for rejection, within five business days via a registered letter with return receipt. Otherwise, failure to provide notification after the period expiration shall be deemed implicit approval of the application.
The agency has the right to file an appeal with the Ministry of Labor if the application is denied, within 60 days of being notified of the dismissal.

The agency’s legal obligations upon approval of an application for a license to conduct recruitment operations at domestic and/or international levels are as follows:

Once the license application has been approved, the applicant company shall provide a security deposit of not less than EGP 1 million, either in cash or in the form of an unconditional and irrevocable letter of guarantee issued by a bank registered with the Central Bank. The letter of guarantee must be made out in the company’s name and payable to the Ministry, and must remain valid for the term of the license.

The company shall make up the difference in the security by the amount deducted for fines, compensation, or sums collected without legal justification, in accordance with the provisions of the Law, within 15 days of the date it is notified by registered letter to make up this security.

License Validity and Renewal:

The license is issued for a renewable one-year period, effective from the date of issuance, upon payment of a license fee of EGP 5,000.
The license shall be renewed upon an application by the agency’s legal representative, at least two months before the expiration of the license. The application shall be accompanied by a statement of the agency’s operations during the license period. Renewal shall be granted upon payment of a fee of EGP 5,000 and full payment of the prescribed security.
If the license expires without renewal, it shall be deemed null and void. No renewal application shall be accepted after the license has expired unless there is a valid reason accepted by the competent authority. The renewal fee shall be increased by EGP 2000 for each month following the license expiration date, up to a maximum of EGP 10000.
If the delay exceeds one year after the license expires, the license shall be deemed null and void and may not be renewed under any circumstances.
The relevant department shall establish simplified procedures for annual renewal, provided that the documents are reviewed and updated at least every five years.

A license to conduct domestic and/or international recruitment activities may be revoked by decision of the Ministry of Labor under the following circumstances:

1. The company no longer meets one of the licensing requirements.

2. The company obtained or renewed its license based on fraudulent or falsified information.

3. The company is found to be operating outside its licensed premises or without prior written authorization.

4. Recruiting a worker without an executed written employment agreement—or its regional equivalent—or failing to secure agreement approval from the competent administrative authority.

5. Failure to maintain records of employment data or to record the amounts collected from employees.

6. The company posts fake job listings or exceeds the terms of employment agreements.

7. The company collects any fees from the employee for recruitment, in violation of the provisions of the law.

- If any of these circumstances arise, the competent authority may temporarily suspend the company’s operations until a determination is made regarding the validity of such circumstances or until the violations are resolved. Such suspension shall not affect the progress of license renewal procedures by the renewal date.

- License revocation in such cases shall not preclude criminal, civil, or disciplinary liability.

- The competent authority shall, within 5 business days, notify the company of the revocation of its license or the temporary suspension of its operations at the company’s address listed on the license.

Obligations of the Company licensed to conduct domestic and/or international recruitment are as follows:

1. Compliance with the Ministry of Labor’s regulations and circulars governing recruitment activities.

2. Monitoring changes in wages and employment conditions and including them in periodic reports.

3. Entering into formal contracts with employers, which are notarised and submitted to the relevant administrative authority, and which include details of the workers, wages, and terms of employment.

4. Maintaining confidentiality of employee and employer data and information.

5. Compliance with the laws in force in the countries of employment and with labor migration agreements.

6. Observance of fundamental labour rights, including: Freedom of association, non-discrimination, prohibition of forced labour, occupational safety, and legal recruitment age.

7. Ensuring that the actual working conditions correspond to the conditions agreed upon before the worker’s departure or the start of employment.

8. The company undertakes to maintain paper or electronic records of job seekers, employers’ requests, and a register of comments relating solely to workers whose employment has been terminated and any feedback received from them.

9. Private recruitment agencies may charge a fee not exceeding 1% of the worker’s annual salary for the first year only, as administrative expenses. Such agencies shall not deduct any portion of the worker’s salary for recruitment. They shall not collect any other amounts from the worker, whatsoever, either directly or indirectly.

10. The agency is prohibited from collecting administrative fees until the worker has actually been placed by the agency with a third party, whether at the domestic or international level.

11. The competent Labour Directorate must be notified of job vacancies that reflect the establishment’s actual needs. A monthly hiring statement must also be provided, in accordance with the forms provided for that purpose.

Regulation of the Operations of Online Recruitment Agencies under the Decree

The recruitment of Egyptians, whether at the domestic or international level, may not be conducted electronically—through websites, web pages, or online platforms—unless a license has been obtained from the competent authority. Private recruitment agencies are exempt from this requirement.
The above legal requirements governing private recruitment agencies also apply to online recruitment agencies with the online placement of Egyptians at the domestic or international level, provided that this does not conflict with the nature of their activities.

Mandatory Requirements for Online Recruitment Platforms Are as Follows:

1. Compatibility with all devices and browsers.

2. A user-friendly interface that reflects the company's identity.

3. Inclusion of company details and licence number.

4. The Arabic language should be available, along with other languages.

5. Ensuring accessibility for all users.

6. Providing communication channels, technical support, and an FAQ section.

- While committing to updating and ensuring the accuracy of the content regularly.

Companies that process the enrollment of Egyptians, whether at the domestic or international level, via electronic means, must bring their affairs into compliance within a period of no more than one year from the effective date of the Decree.

Recruitment companies’ Obligation to Provide Pre-departure Orientation to Workers and Mechanisms for Receiving Complaints in Light of the Decree:

The Decree regulates the obligations of recruitment agencies regarding the training of workers before departure, requiring them to enroll workers in orientation programs before departure to familiarize them with the nature of work in the host country, their rights and duties, travel procedures, and how to communicate with official authorities abroad.

Additionally, the decree establishes a dedicated Ministry of Labour unit to investigate worker complaints and mandates competent authorities to publish guidelines optimizing communication with overseas labour offices and consulates.

In conclusion, the Decree establishes a comprehensive legal framework for regulating domestic and international employment, based on strict oversight, enhanced transparency, and the protection of workers’ rights. This is particularly important in light of the expansion of digital employment and the growing opportunities for cross-border work. Rather than merely establishing formal regulations, the Decree also includes effective enforcement and oversight mechanisms, reflecting a modern legislative approach that seeks to balance between regulatory requirements and safeguards.

Crucially, specialized legal consultancies—led by Sadany & Partners Law Firm—actively support this initiative by aligning corporate operations with the decree, building legal awareness, and driving regulatory compliance.

Consequently, the success of this regulation depends on effective enforcement and cross-agency collaboration to foster a fair operational environment and elevate the Egyptian labor market's global standing.