• Expedite the issuance of the micro, small, and medium-sized enterprises (MSMEs) law, which was reviewed by FEI, to encourage formalization of informal enterprises.

• On July 13, 2020, the President ratified the Micro, Small, and Medium-sized Enterprises Development Law (No. 152 of 2020), which includes 109 Articles, organized into 9 chapters. Articles 105 and 106 of the law prescribe a penalty of a deprivation of liberty; additionally, several issues remain ill specified and should be more adequately addressed in the executive regulations.

For example, executive regulations should clearly specify the following issues:

• The types of violations that will render the closing of a business legal, as well as the controls that should govern the exercise of the powers by the competent authorities (Article 56).
• The procedures to be taken and the sectors to be targeted for formalization; the latter should be consistent with the priorities set in Egypt’s Sustainable Development Strategy (Article 91). 

• Reduce delays in court proceedings to enhance the timely delivery of justice; and build the capacity of judges in economic courts, with a focus on increasing their knowledge of economics principles and issues.

• On August 7, 2018, the President ratified the amendments to the Economic Courts Law (No. 120 of 2008), which were approved by the House of Representatives. The new Law No. 146 of 2019 will help accelerate litigation involving lawsuits falling under the jurisdiction of the laws governing trade, investment, and financial transactions.

• Do not impose a real estate tax in free zones, and consider exempting factories from such tax: In May 2018, the General Assembly of the Legal Opinion and Legislation Departments of the State Council issued a legal opinion confirming that business enterprises located in free zones are exempt from the taxes prescribed in Real Estate Tax Law No. 196 of 2008. This exemption is to take effect from the date on which the Investment Law No. 72 of 2017 entered into force. Article 41 of the Investment Law stipulated that free zone business enterprises shall not be subject to the provisions of the applicable laws on taxes and duties in Egypt, which includes the real estate tax.  Accordingly, it is not legally possible to require these enterprises to pay real estate tax starting June 6, 2017, the day the Investment Law entered into force. Compliance with the legal opinion of the State Council, and establishing a mechanism to ensure its implementation is yet to be seen. 

• Review the sanctions-related provisions in all business-relevant laws and draft laws, and eliminate sanctions that entail deprivation of liberty, thereby making them consistent with the Investment Law. The latter expressly states that no penalties that entail deprivation of liberty shall be imposed on investors in any economic activity and that penalties shall be limited to fines.  Indeed, several of recently issued laws, including the NGO Law, the Social Insurance Law, and the Trade Unions Law did away with all penalties involving jail time. However, there remain other laws and draft laws that include sanctions that entail deprivation of liberty (e.g., the regulations pertaining to cheques under “the Cheques Law”).

Consider amending the Comprehensive Health Insurance Law (No. 2 of 2018) to address several shortcomings. The amendments should address the following points:

• The amount of Takafulia contribution  that a business is required to make under the law should be calculated based on its net annual income instead of its gross annual revenue. Additionally, a contribution ceiling and floor should be specified.
• Establish contribution brackets—ranges of net annual incomes, each subject to a certain contribution rate; the contribution rate should be progressive, in other words, lower brackets pay lower rates and higher brackets pay higher ones.
• Affix a label “finished product” to imported goods to avoid imposing the Takafulia contribution on production inputs, and thus increasing costs. This will prevent duplication, as the contribution is already imposed on the gross annual revenues.
• Since the required contribution constitutes a business expense, it should be tax-deductible under all circumstances.
• Funding the new comprehensive health insurance scheme, should not be limited to this contribution. Other sources of funding include supplementary taxes on cigarettes and alcohol, as well as contributions from employees and employers, which add up to 5% of the employee’s salary.
• The contribution brackets should be structured such that the highest rate, 0.0025, be assigned to the highest bracket of net annual income, and gradually decrease to 0.0015 and then 0.001, as the net annual income decreases.
• Money-losing businesses should be subjected to the same contribution payment terms. That said, the contribution should not be charged to the profit and loss statement, but rather the shareholders' equity account. By doing so, the payment may be tax-deductible in the future, under certain circumstances, as it will be considered a loss carried forward.

• Reconsider Articles 115 through 119 of the Penal Code—The Chapter on Public Funds— to counter the prevailing modus operandi of the government, which is characterized by irresolution and hesitancy. In this regard, attention should be given to enacting a specific and clear law holding ministers and public officials politically accountable for their policies and action, rather than limiting their accountability to the legal realm—accountability for criminal conduct. Attention should also be given to providing support to public officials and building their confidence in making decisions that serve the public interest and respond to national development objectives, as long as these decisions are well-studied, and were subject to broad-based and meaningful community dialogue. 

• End the freeze placed on the investment incentives scheme (both the tax and non-tax incentives), which are stipulated in Law No. 72 of 2017. This will contribute to boosting investment attraction efforts and achieving the goals behind these incentives. Additionally, activate the new set of tax incentives included in the amended Investment Law to encourage businesses to reinvest their excess profits, thereby increasing the rate of investment in Egypt.

The draft law places excessive financial burdens on business owners, for example:

• It calls for the creation of multiple funds such as the Penalties Fund, the Vocational Training Fund, the Irregular Employment Fund, which represents significant financial burdens for industries.  
• It is overly permissive regarding vacation leave—the number and types of leave entitlements are way exaggerated; time-off can reach over 190 days a year, including the weekly day of rest.
• It obligates bankrupt employers to compensate workers in case of a total or partial shutdown, in addition to obligating employers to pay bonuses to workers if a fixed-term employment contract is not renewed on expiry. 

• Ensure that the foundational goal of the draft law is the fair balancing of employer and worker interests. In other words, the law should serve the interest of workers, however, without causing material damage to business owners. An efficient and profitable business ultimately benefits workers as it ensures employment security and increased incomes associated with higher productivity. 
• The law should align with the National Development Plan, namely the objective of increasing the productivity of Egyptian labor, which is essential for enhancing competitiveness; it should also give adequate considerations to the rights and responsibilities of workers. 
• A worker should not be entitled to bonus compensation if the employment contract is not renewed. 

• The Manpower Committee of the House of Representatives approved the draft new labor law.

• The absence of a fair mechanism to regulate the right to strike.

• The right to strike should be regulated in a manner that does not undermine the interests of the business enterprise, and at the same time, be in line with international labor standards. The power of the authorized labor representative to organize strikes must be well-defined. 

• Business associations are not represented on the Board of Directors of the workers training fund, although employers are the primary suppliers of the fund’s resources, and they are the main beneficiaries of the fund’s services represented in training their employees to raise their level and its reflection on increasing productivity and profitability and thus expanding their investments and the positive impact on the development of the national economy and raising competitiveness.
• Not to carry over the surplus funds of the training fund from year to year.
• Non-participation of sectoral employers’ associations (Federation of Industries, Federation of Chambers of Commerce, Federation of Chambers of Tourism, Federation of Construction and Building) in determining the rules and conditions of the total exemption.
• Lack of dialogue with employers and workers before issuing legislation affecting them.
• The draft law confused casual and seasonal employment with irregular employment.
• The requirement to notify the competent administrative authority every time vacancies are advertised represents a large administrative burden on the employer, especially employers who have thousands of workers; this condition is considered an unjustified control by the Ministry of Manpower prior to appointment, knowing that the information that the ministry wishes to obtain as a result of this condition is available through more than one source after appointment.
• The amendments demanded by the Senate regarding days off of women’s employment, maternity leaves without pay have negatively affected employers and the functioning of work. In case of childbirth, the amendment discourages employers from hiring women due to the increasing of the leave period; hence, it contributes to weakening women’s participation rates in the labor market. The amendment received from the Senate also weakens the competitiveness of micro and small enterprises and contradicts the state’s policy in encouraging these enterprises so that they can overcome the many challenges they face, consequently, can play their role in serving the national economy given due consideration that micro and small enterprises represent at least 95% of any states establishments.
• The employer shall bear the cost of the maternity leave pay alone.
• The Senate proposed restrictions on the renewal of fixed-term contracts in terms of their conversion to indefinite contracts.
• The social, health, and cultural services fund did not carry out any positive activities and did not perform its own duty throughout the period of its establishment.
• Giving the worker the right to withdraw the resignation.

• Fair representation for business owners on the Board of Directors of the employee training fund to ensure that its services are directed to the optimal way to meet the training needs of employers.
• Transferring the surplus funds of the fund from year to year to maximize the benefit of its returns for workers and employers, and the transfer of the surplus from year-to-year distances the concept of this fee as a hidden tax.
• Participation of associations of sectoral business owners (Federation of Industries, Federation of Chambers of Commerce, Federation of Chambers of Tourism, Federation of Construction and Building) in determining the rules and conditions of the total exemption as they are more familiar with the conditions of training carried out in their subsidiaries.
• Dialogue with employers and workers before promulgating laws and regulations, as most international labor conventions stipulate the need to consult with organizations regarding their affairs in order to activate the principle of social dialogue.
• To abrogate clause no. 23 completely, as there is no analogue for it in the world, concerning the possibility of revoking the license by a decision of the competent minister in cases of violation.
• Protecting the principle of irregular employment in the coverage of the state’s social safety net as it is a free profession.
•  Activating clause no.16 of the Draft Labor Law that it is not necessary to notify the administrative authority of the announcement of vacancies.
• Maintaining article no.91 of the Draft Labor Law which grants the female worker the right to a ninety-day maternity leave with compensation equal to the basic wage, as the variable wage is linked to work and the level of performance, and it is not achieved in placing the worker on maternity leave and she is not entitled to maternity leave for more than twice throughout the period of service, because the current text of the article achieves the required balance between the needs of work and the interest of the worker. 
• Following article 4, paragraph 8, of ILO Convention No. 103, which stipulates that "the employer shall in no case be liable for the costs of compensation payable to women workers on maternity leave" and article VI, paragraph VI, of ILO Convention No. 183 concerning the Protection of Maternity stipulates that "compensation for maternity leave shall be provided through compulsory social insurance or from public funds and the employer shall not be liable." Individual liability for the direct cost of any such monetary compensation without a specific agreement with the employer. In 98 countries, maternity leave pay/compensation is funded by social insurance schemes and in 29 countries it is funded in partnership with the employer.
• Maintaining Article 94 of the Draft Labor Law, which granted a female worker in an establishment that employs 50 workers or more leave without pay that does not exceed two years and is only entitled to twice throughout her service period, because the current text of the article has proven with practical proof that this is the maximum that an establishment with 50 workers can bear and that this text achieves a balance between the interest of the worker, the child on the one hand, and the employer on the other hand.
•  Maintaining the current law, which did not place any restrictions on the renewal of fixed-term contracts in terms of their transformation into indefinite contracts. The following countries do not place any restrictions on the renewal of a fixed-term contract to similar periods without converting it to an indefinite contract: Denmark, Finland, France, Germany, Ghana, Ivory Coast, Indonesia, Japan, Jordan, Italy, Korea, Ethiopia, Gabon, Malaysia, Morocco, Russia, Romania, Tunisia, Senegal, Rwanda, Syria, Turkey, Yemen, Zambia, United Arab Emirates, Uganda.
• Apply of article 3, paragraph 3, of ILO Convention No. 132 concerning Annual Leave with Pay that leave shall not be less than three weeks.
• According to ILO statistics, 68% of countries in Africa grant annual leave of 15 to 23 days, 22% of African countries grant less than two weeks of leave and 80% of countries in the Middle East grant annual leave of less than 25 days. Countries that give annual leave of more than 26 days are only England, the United Arab Emirates and Yemen. 
• The worker shall not be left with the right of recourse to resign without restriction so as not to abuse this right and exploit the employer by submitting the resignation every time he has demands and then retracts them when responding to his demands.
•  Abolishing the Social, Health and Cultural Services Fund, as subsequent legislation was issued obliging establishments to pay additional fees to increase health care for workers, and a decision was taken in the last sessions of the Fund's Board of Directors to dissolve the fund and transfer its funds to the Tahya Misr Fund.

• Penalties involving the deprivation of liberty

• Abolish all penalties involving the deprivation of liberty
• The insurable earnings should not be less than 50% of the total earnings of the employee, with a maximum of LE 6,520; this is the maximum cap (base earnings + variable earnings) prescribed in the law, which is scheduled to come into force on 1/1/2020.
• Exclude all elements of variable earnings, including incentives and allowances, not to exceed 100%, from the total insurable earnings. (SEIF)
• Dividends paid to employees should not be considered as earnings for the purpose of calculating insurable earnings.
• Do not increase the maximum cap amount of insurable earnings beyond the amount which will be applied on 1/1/2020, when the law enters into force (LE 6,520); contributions against any amount that exceeds this cap should be borne only by the insured, however, the amount should not exceed double the total maximum limit on 1/1/2020. 

A new Social Insurance and Pension Law No. 148 of /2019 was issued on 19/08/2019. Key features of the law include:

• Elimination of penalties involving the deprivation of liberty.
• Monetary penalties—fines— are reduced, and the amount of the fine varies according to the offense committed. For example, the fine was reduced from LE 50,000 to LE 20,000; the LE 20,000 is set as the fine floor, and LE 100,000 the fine ceiling, if the offense is not repeated. 
• Allowances are fully excluded from the calculation of the insurable earnings.

• The contribution rates for old-age, disability, and death insurance that the employer and the insured employee should commit to (Clause 2 of Article 19)

• Specify the contribution rates for old-age, disability, and death insurance that the employer and the insured employee should commit to (Clause 2 of Article 19). In the absence of specific contribution rates, conflicts between employers and insured employees are likely to arise. 
• Set the contribution rates referenced in Clause 2 of Article 19 (pertaining to private sector employment) at 11% for the employer, and 10% for the employee.

• Pharmaceutical pricing policies are out of sync with changing market conditions, including exchange rate movements, rising inflation, and increases in energy prices; operating costs; and interest rates.
• The current pricing scheme— a cross-reference pricing scheme that takes into account the prices of pharmaceuticals in 36 countries— is unfavorable to the industry. Under this scheme, the lowest price in any of the reference countries is used to guide the pricing of pharmaceuticals in the Egyptian market, with no consideration for the difference in distribution margins, which should be a key factor in pricing. Thus, the current system needs to be seriously and comprehensively reviewed in order to make it more responsive to market changes, and render investment in the industry attractive.

• Revisit the current pricing policy to bring it in line with the requirements of the global market and the practiced pricing methods. This should increase the volume of pharmaceutical exports, and make it commensurate with the size and capacity of the industry in Egypt.
• For new Common Technical Document (CTD) submissions for generics, price them at 65% of the price of the innovator or branded counterpart (the patented).
• Approve the pricing of registered pharmaceutical products, giving priority to alternative products that are in short supply or missing in the market.
• Expedite the re-pricing of registered pharmaceuticals, which are not yet marketed, even if their notifications have lapsed (these pharmaceuticals were priced prior to the floating of the Egyptian pound).
• Abolish the VAT on imported pharmaceutical raw materials, which are pre-blended and processed using two or more ingredients. At the same time, impose on them the 2% tariff rate prescribed for customs category No. 3003, rather than the 5%, tariff rate prescribed for customs category No. 3824, in addition to the 14%VAT. 

A national body to oversee the safety of pharmaceuticals, the Egyptian Drug Authority (EDA), was created in 2019. However, the following requirements pose obstacles for manufactures:

• The requirement that manufacturers obtain an import approval for each consignment of imported raw materials; the additional fees associated with this requirement result in raising the price of the final.
• The extreme processing delays in obtaining certificates of Free Sale and certificates of GMP negatively affects the exportation of products.
• The Central Administration for Pharmaceutical Affairs refuses to accept the trading certificates for non-sterile products, which are issued by the IDA and sent by express mail.
• Exporters must fulfill additional requirements to be able to export their products, including a commitment to provide production materials for a period of 6 months; receiving visits for verification; and obtaining the approval of the Public Authority for Unified Procurement.

• Abolish the requirement that manufactures obtain an import approval for each consignment of imported raw materials.
• Expedite the issuance of the certificates of Free Sale and the certificates of GMP.
• Refrain from issuing any new export requirements without consulting with exporters.

• On August 25, 2019, the President ratified Law No. 151 of 2019; Article 14 established the Egyptian Drug Authority (EDA), and Article 16 specified its mandate. According to Article 14, “A public service authority, called the Egyptian Drug Authority, is created; it has a juridical personality and is affiliated with the Prime Minister; the location of its headquarters is to be determined by the Prime Minister, and the board of directors may decide to open additional locations.” 
• Article 16 stipulates that “The new Authority aims to organize, implement, and control the quality, effectiveness, and safety of the medical preparations and devices provided for in the provisions of this Law.  It is also tasked with enforcing the  provisions of  the current law governing the practice of pharmacy, provided that they do not contravene any of the provisions of this law. To accomplish this, it shall also assume all the necessary powers, functions and legal actions.”

• The absence of a clear legal framework governing the pharmaceuticals and medical devices sector.

• Develop a new legal and institutional framework to govern the pharmaceuticals and medical devices sector.

• The inclusion of cosmetics in the definition of pharmaceuticals is problematic as they will be subject to the same registration, pricing, and testing rules and procedures applicable to pharmaceuticals. This is contrary to the nature of the industry and how cosmetics are regulated across most countries globally. Cosmetics are non-medical products, and are treated as such; they are governed by separate laws and regulations in many countries (e.g., European Union countries, the US, Saudi Arabia, the Arab Gulf States, and all African countries). Categorizing cosmetics under the rubric of pharmaceuticals is likely to have a significant adverse impact on the industry, and its ability to attract future investments, which was estimated at approximately LE 18 billion in 2018.
• The definition of cosmetics is inconsistent with the definition currently adopted in Egypt, which agrees with the internationally recognized definition of cosmetics. 
• The draft law includes mandatory standard specifications for cosmetics.
• The controls and procedures regulating the importing, exporting, registration, and pricing of cosmetics go against the nature of the product itself. 
• The absence of a clear definition of the term “pharmaceutical entity”, which is to be licensed under this law. 
• The release of imported medical products and other materials that fall under the jurisdiction of the Egyptian Drug Authority “EDA” is not allowed before all required tests and analyses are completed.
• The trading of domestic pharmaceuticals and other related products that fall under the jurisdiction of EDA is not allowed before all required tests and analyses are completed.
• Absence of a clear grievance processing procedures, including the specific time frame for filing a grievance and receiving a determination on it.   
• The fees associated with the record-filing and inspection of cosmetics are excessively high. 
• The cosmetics industry is a fast- moving and changing industry, where products develop periodically and 25% of the used formulas change annually. Thus, applying the rules and regulations pertaining to medical and pharmaceutical products on cosmetic products will hinder the development and prosperity of the industry.
• Requiring that each shipment of cosmetic products be analyzed will cost the government and the industry large sums of money for intangible benefits, and does not provide any assurance that the products are safe for consumers. This requirement is largely applied to companies and products that conform and comply with required standards, while many cosmetic products illegally reach the Egyptian market.
• Requiring that cosmetics be subject to testing prior to their release from customs release and their placing on the market is inconsistent with the global trend in cosmetic product control and analysis, which rely heavily on in-market control; this is more appropriate to the nature of the products, their volume of circulation, and the degree of potential health risks associated with using cosmetics, compared to other medicinal and pharmacological products.

• Develop effective implementation mechanisms to facilitates the enforcement of the law. The mechanisms should be appropriate to the nature of the cosmetics market, which differs drastically from that of pharmaceuticals.  FEI’s recommendations should be taken into consideration when developing the executive regulations of the law.
• Issue separate executive regulations to govern the cosmetics industry; the regulations should be appropriate to the nature of cosmetic products that are not used for medicinal purposes. 
• Adopt the internationally recognized definition for cosmetics— “Any product containing one or more substances intended for use on the external parts of the human body, including skin, hair, nails, and lips, or on the external parts of the genitals, teeth, or mucous membrane of the oral cavity for the purpose of cleaning them, or perfuming them, or protecting them, or keeping them in good condition, or changing and improving their appearance, or correcting body odors and improving it”.
• Delete the reference to “mandatory standard specifications” and replace it with “mandatory technical regulations based systems adapted from globally recognized systems, such as those adopted in EU countries.
• Cosmetics should not be subject to product registration requirements but to a notification system. This aligns with practices in EU countries, Saudi Arabia, as well as all East Asian countries, and is in line with the discussions that took place between the Cosmetics Sub-Chamber at FEI, and the Central Administration for Pharmaceutical Affairs as directed by the Minister of Health and Population.
• Cosmetic products should not be subject to an enforced pricing system 
• due to their nature, the manner in which they are traded, and being consumer products that are used regularly and daily (shampoo, skin and shaving creams, and toothpaste). 
• Include a definition for pharmaceutical entities.
• Institute an in-market control system for cosmetic products to protect consumers.
• The time frame for filing a grievance must be within 15 days from the receipt of the notice of the decision. 
• Inspection should be limited to accessing and reviewing records, books, and other documents related to the products and manufacturing processes; manufacturers should be given sufficient time to provide the required documents. 
• Include an article in Law No. 151 of 2019 to mandate the issuance of separate executive regulations to govern the cosmetics industry; the regulations should be informed by the draft paper under discussion between and the Central Administration for Pharmaceutical Affairs, and the Cosmetics Sub-Chamber at FEI. 
• Develop a separate fee schedule, including reasonable fees for the administration and testing of inspecting cosmetics.
• Similar to special food  products, registration of cosmetic products should be based on the product category and not the retail package.  

• According to Law No. 151 of 2019, cosmetics are defined as “any preparations developed for use on the external parts of the body, teeth, or the mucous membrane of the oral cavity for the purpose of cleaning them, or perfuming them, or protecting them, or keeping them in good condition, or changing and improving their appearance, or any other existing preparations, or yet to be developed and will be categorized as cosmetics according to international standards”. 
• Article 17, Section 2, Item 3 of the law vested EDA with the responsibility, among several  other executive responsibilities, of inspecting and analyzing cosmetic products. It stipulates that EDA will have the responsibility to inspect and analyze “pharmaceuticals, and biological preparations, medicinal plants and herbs, cosmetics and all other similar or related products, according to international standards and references to verify their quality, validity, efficacy, and safety, as well as ensure the compliance of pharmaceuticals with pharmacopoeia requirements and the mandatory standard specifications approved by EDA”.
• FEI will continue to engage and advocate for improving the Executive Regulations to better serve the needs of the industry. 

• Imports of medical appliances (for the benefit of public hospitals and universities) are granted exemptions under Chapter 4 of the new Customs Law; this undermines the competitiveness of local industries as they do not enjoy the same exemptions, which range between 5-30%, on imports of production inputs; thus, both domestic and foreign investors are disincentivized from investing in these industries.

• Eliminate any preferential treatment given to imported products or grant domestic manufacturers the same advantages; develop an investment plan to encourage the production of needed products that are currently imported, including making available low-interest, medium and long-term loans.

The lack of a consistent export assistance strategy.

• Ensure that banks offer low-cost export finance facilitation services.

• Ineffective oversight over the legal and illegal markets for medical devices—failure to follow a robust supply chain monitoring process to detect informal markets.  

• Enforce the law, and criminalize the sale and purchase of unregistered medical devices.  

• The unified food has not yet been issued.

• Expedite the issuance of the unified law to replace all other existing relevant laws.

• The lack of human resources within NFSA to effectively and efficiently carry out their functions and adopt new work mechanisms that are in line with international food safety control systems. Under the pretext of an increasingly bloated bureaucracy, competent authorities continue to deny the requests of the newly- established NFSA to recruit or contract with qualified individuals with diversified expertise to assist in meeting its mandate. Additionally, lack of awareness and appreciation of the important role to be played by NFSA is further aggravating the situation; competent authorities are requested NFSA to shrink its already-approved organizational structure, which is necessary for implementing the type of integrated activities and mission NFSA aims to achieve. So far, NFSA did not receive the necessary approvals from the Central Agency for Organization and Administration regarding the staffing table and job descriptions, at the same time, in an effort to undermine NFSA, agencies that were assigned the oversight functions prior to its establishment either refuse to second their employees to it, or prevent them from joining its ranks. 
• All powers and prerogatives granted to NFSA under Law No. 1 of 2017, are ignored; it is treated like any other public agency with regards to public expenditure rationalization. Thus, NFSA is not able to secure the needed resources, such as vehicles, for its staff to carry out food safety inspections of food establishments. More generally, the lack of an adequate budget is impeding NFSA for fulfilling its expansive and important mandate, entails ensuring the food safety for millions of Egyptians, including vulnerable groups such as children, the elderly, the sick, and others; the work of NAFS also safeguards investments in two major revenue-generating sectors: the food processing sector, one of the leading sectors in terms of exports, as well as the tourism sector by ensuring the provision of safe and hygienic food in tourist facilities, being one of the most critical success factors in tourism. 

• Allocate sufficient resources to NFSA to attract qualified professionals, and provide professional development training to its staff.
• Provide NAFS with a realistic budget allocation commensurate with its expansive responsibilities and functions to allow it to carry out its mandate in an effective manner (e.g., procure vehicles needed for carrying out actual food safety inspection nationwide).

• Exempt buildings belonging to mines, quarries, and salterns from the real estate tax, in accordance with Article 18 bis of Law No. 23 of 2020. 

• The resources of the special funds isare re-directed to support other budget deficits rather than being employed to serve the actual cause of its establishmentestablishment.
• There is no proper legal and regulative framework for special funds in Egypt
• Special funds do not comply with accountability requirements and transparent budget preparation process
• There is no governance framework that identifies responsibility and independence of the boards as well as accountability measures and transparency
• There is an accumulative financial responsibilitiesaccumulative financial responsibility on many special funds that altered its scope and direction and overlapped with government responsibilitiesresponsibilities.

Policy Recommendations for Special Funds’ Policy Reforms: 

• Creating policy and technical tools to avoid establishing new special funds away from the state budget to ensure the efficiency of the state budget structure. 
• Amending the laws and regulations to ensure the ratification of financial bylaws as a requirement for the existence of any special funds. Additionally, the parliament should ensure any exceptional privilege for any special fund
• Modernization of the financial administration of special funds and listing specific KPIs to ensure accountable revenues and expenditure schemes with internal and external auditing process
• Ensuring transparency in all collected fees by special funds. The investor should know clearly in advance all the required money that he will pay.
• Ending all sorts of exceptions as no fund should be excluded from the state budget. 
• Reforming the state budget to be more flexible so there is no demand for special funds 
• The Ministry of Finance in cooperation with the General Authority for Organization and Administration should create comprehensive database with all workers and beneficiaries of all special funds in order to deal with any unfair grievances. 
• Putting KPIs for employment in special funds and either to freeze hiring new personal or limiting salary amounts in the budget to 20-25%

• The minimum number of workers required for establishing a trade union committee at the level of the establishment, as well as the number of general unions required for establishing a federation is high.  
• The draft law includes penalties involving the deprivation of liberty.
   

• Lower the number of members required to form a trade union committee at the establishment level or an occupational committee from 150 members to 50.
• Lower the number of union committees required to form a general union from 15 committees with 20,000 member workers to 10 committees with 15,000 members.
• Lower the number of general unions required to form a federation from 10 unions with 200,000 members to 7 unions with 150 members.
   

On August 5, 2019, the President ratified Law No. 142 of 2019, which amended a number of provisions of Law No. 213 of 2017.
The new law introduced a number of changes, including:

• Reducing the number of members required to form a trade union committee at the establishment level to 50 members.
• Reducing the number of union committees required to form a general union to 10 committees with 15,000 members. 
• Reducing the number of general unions required to form a federation to 7 unions with 150,000 members.