Egypt PDPL · Law No. 151 of 2020
Personal Data Protection & GDPR Compliance
PDPC licensing, the data protection officer, penalties and deadlines, explained clearly by a practising lawyer.
Does your company need a licence from the PDPC?
Yes, if it is a legal entity that collects or electronically processes personal data of customers, employees or others. The size of the company does not matter. Natural persons obtain a permit for a specific purpose, valid for no more than one year. Legal entities obtain a licence valid for 3 years and renewable; a renewal request is filed at least three months before expiry (Article 40 of the Regulations).
Types of licence
- Core licence: controller and processor, controller only, or processor only.
- Supplementary licences, issued only alongside a valid core licence: cross-border data transfer (including reliance on servers or cloud services outside Egypt), direct electronic marketing, and visual surveillance in public places.
The data protection officer is a condition of the licence
Article 21 of the Regulations requires a legal entity applying for a licence to submit the contract with its DPO, showing that the DPO accepts the responsibilities and is given the independence needed to perform them. Article 35 requires the DPO to be identified in the application. The DPO is entered in a register kept by the Centre and receives an identification code (Article 9). Article 8 of the Law requires a legal entity to appoint within its own structure a specialist employee responsible for data protection, registered with the Centre, and one DPO may serve more than one entity with the consent of those entities and the Centre (Article 11 of the Regulations). The DPO’s duties include monitoring the application of security policies, submitting an annual report to the Centre, and following up data subject requests and complaints (Article 12). The Centre must be notified at least 15 days before the DPO’s engagement ends (Article 10).
Need a data protection officer or a review of the DPO contract?
We review the Article 21 requirements with you and prepare an appointment contract that meets the Centre’s conditions.
Licence fees
Annual fees for a legal entity depend on the number of records (each record relates to one data subject), under the table in Article 19 of the Regulations:
- No fee for 1 to 100,000 records.
- EGP 200 a year for 101,000 to 200,000 records, rising by EGP 100 for each further 100,000 records up to EGP 1,000 for entities holding up to one million records, with higher bands after that.
- The ceiling is EGP 666,666 a year (EGP 2 million over three years) for more than 5 million records.
- A controller-only or processor-only licence costs half. The cross-border transfer licence costs 50% of the licence fee, and electronic marketing costs 10% (own marketing) or 25% (marketing for others).
How to apply
The application is filed electronically through the PDPC portal (pdpc.gov.eg) with the required documents, including the commercial register, the organisational structure, the nature and volume of personal data and which of it is sensitive, retention periods, security and transfer measures, the mechanism for erasing and amending data, the mechanism for obtaining consent, the DPO, and technical certificates for the infrastructure (Article 35). The Centre decides within 90 working days of receiving the complete documents, and silence counts as refusal (Article 36).
Deadline to regularise your position
Article 6 of the Law’s issuing articles requires those covered to regularise their position within one year of the date the Executive Regulations were issued. The Regulations were published in the Egyptian Gazette on 1 November 2025, so on that basis the period ends around the end of October or the beginning of November 2026. We advise against waiting for the last day, and recommend following the PDPC portal and announcements for practical implementation details and any clarifications.
Know where your company stands before the deadline
A quick initial review of your position and the licences you need.
Penalties under the Personal Data Protection Law
| Violation | Article | Penalty |
|---|---|---|
| Breaching licence, permit or accreditation provisions | 45 | Fine of EGP 500,000 to 5 million |
| Breaching controller or processor duties | 38 | Fine of EGP 300,000 to 3 million |
| Processing sensitive data without consent | 41 | Imprisonment of at least 3 months and a fine of EGP 500,000 to 5 million, or either |
| Breaching cross-border transfer rules | 42 | Imprisonment of at least 3 months and a fine of EGP 500,000 to 5 million, or either |
| Breaching electronic marketing rules | 43 | Fine of EGP 200,000 to 2 million |
| Collecting, processing or disclosing data electronically outside permitted cases | 36 | Fine of EGP 100,000 to 1 million, with heavier penalties where the aim is gain or exposing the data subject to danger |
| DPO failing in the duties of the role | 40 | Fine of EGP 200,000 to 2 million |
| Repeat offence | 48 | Minimum and maximum penalties are doubled |
The person responsible for the actual management of a legal entity is punished with the same penalties if knowledge is proven, and the entity is jointly liable for compensation (Article 47). The Centre may also impose administrative sanctions, starting with a warning and then suspension or withdrawal of the licence in whole or in part (Article 30). Settlement is possible for some offences under Article 49.
What your company can do now
- Map the personal data you hold and the number of records, and decide whether you act as controller, processor or both.
- Choose a DPO and prepare the appointment contract so that it meets Article 21 of the Regulations.
- Prepare a record of processing activities, a privacy policy, consent mechanisms and a process for data subject requests.
- Review supplier and cloud contracts and identify which activities need a supplementary cross-border licence.
- Put a breach response plan in place: notify the Centre within 72 hours and the data subjects within 3 working days of notifying the Centre (Article 7 of the Law).
- Foreign entities processing data of people in Egypt should appoint a legal representative in Egypt.
We handle the implementation end to end
From data mapping to the licence file, policies and contracts.
Frequently asked questions
Does a small company need a licence?
Yes. The duty falls on every legal entity that controls or processes personal data. Fees are tiered by number of records, and entities with up to 100,000 records pay no fee.
Do I need a data protection officer?
Yes. The Regulations require a legal entity applying for a licence to have a contracted DPO who is registered with the Centre.
Does using a cloud service outside Egypt need a permit?
Transferring, storing or processing personal data outside Egypt requires a cross-border transfer licence or permit, which is issued only alongside a valid core licence.
What is the difference between a licence and a permit?
A licence is for legal entities and lasts 3 years. A permit is for natural persons, for a specific purpose and for no more than one year.
How does the Egyptian law relate to GDPR?
They are separate laws with similar principles of consent, transparency and data subject rights. Companies active in Europe often have to comply with both.
Is your company compliant with the Personal Data Protection Law?
Contact us now for a quick initial consultation, and we will set out the compliance steps that fit your business.
