ESG Reporting in Egypt: What FRA Decrees 107 and 108 Require

Sustainability reporting in Egypt stopped being optional for a large part of the market in 2021. That year the Financial Regulatory Authority (FRA) issued Decrees No. 107 and 108 of 2021, which brought environmental, social and governance (ESG) disclosure, and for larger firms climate-related disclosure, into annual reporting.

This guide summarises what the two decrees require, who they apply to and how companies can prepare. It is general information, not legal advice: always confirm your obligations with your advisers and the FRA.

Who must report

• Non-bank financial institutions (Decree 107): companies with issued capital or net equity of EGP 100 million or more must include ESG disclosures in their annual reports. Those with EGP 500 million or more must also report in line with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD).
• Companies listed on the Egyptian Exchange (Decree 108): must disclose ESG information and the financial impacts of climate change in their annual reports and financial statements.

Disclosures have been due with annual reporting from 2023 onwards.

What an ESG disclosure covers

The required topics follow the familiar three pillars:

• Environmental: energy use, greenhouse gas emissions, water and waste.
• Social: workforce make-up, labour practices, health and safety, and community impact.
• Governance: board structure and oversight, policies, and anti-corruption measures.

For companies in the TCFD group, the report also needs the four TCFD elements: governance of climate issues, strategy (including scenario analysis), risk management, and metrics and targets, such as Scope 1 and Scope 2 emissions.

What comes next: IFRS S1 and S2

In January 2025 the FRA said it is developing a framework aligned with the International Sustainability Standards Board's IFRS S1 (general sustainability-related financial disclosures) and IFRS S2 (climate-related disclosures). IFRS S2 builds directly on TCFD, so companies already reporting under TCFD have a head start. Companies that only report ESG data today should expect to be asked for more financial context: how sustainability risks affect cash flows, financing and strategy.

A practical checklist

1. Map your obligation: check your listing status and your issued capital or net equity against the EGP 100 million and EGP 500 million thresholds.
2. Name an owner: one person, ideally reporting to the CFO or the board, should own the data and the timeline.
3. Build the data trail: energy bills, fuel use, water meters, waste contracts and HR records are the raw material. Collect them monthly, not at year end.
4. Measure Scope 1 and 2 emissions with a recognised method, such as the GHG Protocol.
5. Bring it to the board: TCFD and IFRS S2 both expect visible board oversight of climate risk.
6. Get it checked: internal audit or a limited external review builds trust with investors and lenders.

Where to learn more

The FRA's own statements are the primary source: see its January 2025 remarks on sustainability reporting. For a legal overview, the Chambers ESG 2025 guide on Egypt is a useful starting point.

ESG reporting is a recurring theme at the Egypt CSR & Sustainability Forum. Its 16th edition ran hands-on workshops on implementing an ESG reporting framework and on sustainability assurance under ISSA 5000. Companies that want tailored support can talk to CSR Arabia, Athar Network's training arm.