• 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.

• The Vocational Training Fund is not economically feasible, and it does not serve its intended purpose.

• Reconsider the management mechanism of the Vocational Training Fund; the private sector, the main financier, should be adequately represented on the board of directors, and decisions should be made by vote. Additionally, the board of directors should create sectoral councils, each to be allocated a budget, the percent of which should be commensurate with the sector’s contribution to the fund’s overall budget.  This will ensure that benefits are shared fairly among sectors. 

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 draft law does not establish a careful balance between workers' and employers' rights. It revives the concept of open-ended employment contracts, under which an employer has no choice but to resort to the courts to dismiss a worker who has committed a serious infraction.

• Discard the concept of open-ended employment contracts and ensure that employers and employees comply with the terms and conditions of the employment agreement.

• 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.