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On 22 April 2026, the Egyptian House of Representatives gave final approval to amend Egypt’s competition law, marking the most significant transformation of the legislation in years and carrying far‑reaching implications for the private sector. The amendments to Law No. 3 of 2005 on the Protection of Competition and Prohibition of Monopolistic Practices (the “ECL”), described by legislators as the “constitution regulating the Egyptian market”, introduce sweeping changes designed to level the playing field, enhance the powers of the competition authority, and update merger control rules. This article explores all known amendments that businesses should be aware of, as widely reported, until the new version of the ECL is published in the Official Gazette. Emphasis on Competitive Neutrality The revised law establishes a Supreme Committee for Competitive Neutrality, chaired by the Prime Minister – the first time such a framework has been introduced. The Committee has the authority to cancel any exemptions or privileges granted by government decisions or laws to state‑owned entities where such advantages distort fair competition. In addition, existing legislation and decisions issued by government bodies will be reviewed to ensure alignment with free competition principles. For private sector businesses, this represents a significant step toward a more equitable market environment. Enhanced Independence for the Competition Authority The Egyptian Competition Authority (“ECA”) receives a major upgrade in its legal status, now falling under Article 215 of the Constitution, which governs independent regulatory bodies. This grants the ECA full technical, administrative, and financial independence – placing it alongside institutions such as the Central Bank of Egypt and the Financial Regulatory Authority. Senior leadership will be appointed by the President with parliamentary approval, reinforcing the ECA’s capacity to act as a true market watchdog. Higher Thresholds for Merger Control Notifications One of the most practical changes for the private sector is the significant increase in the financial thresholds that trigger mandatory merger control review. The amendments effectively double the thresholds, reflecting Egypt’s economic growth and inflation. The key new thresholds are as follows: Domestic Thresholds: The combined annual turnover or assets of all parties must now exceed EGP 2.5 billion (previously EGP 900 million), with at least two parties each exceeding EGP 500 million (up from EGP 200 million). Worldwide Thresholds: The combined global annual turnover of the parties must exceed EGP 15 billion (previously EGP 7.5 billion), and the Egyptian target company must have annual turnover exceeding EGP 500 million (up from EGP 200 million). Notably, while transactions falling below these thresholds are exempt from mandatory notification, the ECA retains discretion to review any transaction if there is evidence that it may undermine free competition. Significantly Increased Fines The amendments introduce a two‑track penalty system with substantially higher fines. For competition‑restricting behaviors (such as price‑fixing or market division), fines can reach up to 15% of the revenues of the product in question during the entire violation period. Where revenues cannot be determined, a fixed fine of up to EGP 700 million applies. For unlawful concentrations (such as failing to notify a qualifying transaction), fines can reach up to 10% of the combined annual revenues of all parties based on the latest audited financial statements. An absolute cap of 10% of the infringing party’s total annual revenues (including all related entities) applies regardless of the calculation method. What This Means for Businesses As the final shape of the law continues to take shape, private sector entities should begin preparing now. The higher notification thresholds may exempt many smaller transactions from mandatory review, but caution is still advised given the ECA’s residual discretion to investigate any potentially problematic deal. Proactive compliance strategies are essential, particularly in light of the dramatically increased fine levels. For tailored guidance on navigating and complin with these developments and preparing for potential filings under the new framework, you reach out to our antitrust & competition team at GLA & CO. Authors: Partner and Head of Antitrust & Competition, Asad Ahmad and Associates, Khaled Al Khashab and Mounir Hany.

On 28 July 2026, the Egyptian Minister of Labour issued Ministerial Decree No. 162 of 2026 (the "Internal Regulation Decree"), establishing the general rules governing internal work regulations under the new Labour Law No. 14 of 2025. Published on 13 August 2026 and effective the following day, this decree marks a significant step towards building a modern, balanced and fair work environment in the Egyptian labour market. At GLA, we have reviewed the decree in detail and set out below the key takeaways for employers and employees alike. Who Is Affected? The decree applies to every private-sector establishment with ten (10) or more employees, requiring the adoption of an internal work regulation in line with the new requirements. Thid means that a significant portion of Egypt’s workforce will benefit from standardized, transparent workplace rules, while employers fact strict deadlines for the preparation, ratification and submission of these regulations to the competent Labour Directorate. Mandatory Content of Internal Work Regulations The decree sets out an extensive list of mandatory content requirements that are now in force, designed to ensure that the rights and obligations of both employers and employees are clearly documented. Every qualifying establishment’s internal work regulation must address, among other things: Recruitment and selection: procedures for announcing vacancies and organising the hiring process. Training and skills development: identifying training needs and enhancing employees' capabilities. Employment contracts: rules governing the conclusion and documentation of contracts, as well as maintaining each employee's service file. Performance management: mechanisms for evaluating employee performance based on objective, fair and measurable KPIs, with a right to notification of results and a grievance mechanism. Promotions, transfers and secondment: published systems based on efficiency, merit and disciplinary record, with safeguards preserving employees' wages, grades and promotion eligibility. Wages and entitlements: linking pay to job grade and competence, guaranteeing equal pay for men and women for work of equal value, and providing periodic increments no lower than the statutory minimum. Working hours, rest periods and overtime: organising shift systems, publishing schedules and ensuring overtime compensation meets statutory minimums. Leave entitlements: covering annual leave, official holidays, casual leave, paternity and childbirth leave, sick leave, study leave and pilgrimage leave. Workplace health and safety: ensuring a safe work environment that accounts for the rights of persons with disabilities, including emergency evacuation plans and appropriate warning systems. Grievances and internal dispute resolution: establishing mechanisms for receiving and examining complaints, with particular attention to complaints from women and persons with disabilities, and providing for internal settlement of disputes before recourse to the courts. Discipline and termination: defining violations, graduated disciplinary penalties and grounds for terminating the employment relationship. Combating Harassment, Bullying and Discrimination The decree introduces robust protections against harassment, bullying and violence in the workplace. The decree itself defines harassment and bullying in detail. It then requires each employer’s regulation to set out the specific prohibited acts that constitute forms of harassment, assault or bullying; whether committed by superiors, colleagues or subordinates, and prescribe disciplinary penalties for each, with aggravated sanctions where the offender holds supervisory authority over the victim. Employers must also establish a clear mechanism for receiving complaints, investigating them and taking appropriate action. In addition, the decree prohibits all forms of discrimination, whether direct or indirect, in recruitment, training, promotion, wages or any other aspect of employment, and requires employers to guarantee equality and equal opportunity. Positive measures for women, persons with disabilities and children are expressly permitted and do not constitute prohibited discrimination. New Forms of Work: Remote, Hybrid and Flexible Arrangements One of the decree's most consequential provisions concerns non-traditional work patterns. Where employers apply flexible work, remote work or any other non-standard arrangement, the regulation must include dedicated rules covering working hours, duties, performance evaluation mechanisms and follow-up; without prejudicing employees' statutory rights. This formalises what has until now been largely informal across many Egyptian workplaces. Protection of Existing Employee Benefits The decree embeds a strong non-regression principle: all benefits actually granted to and enjoyed by employees before the regulation's preparation must be included. This means the decree cannot be used as an opportunity to reset or dilute existing entitlements; a significant safeguard for employees. Where legislation conflicts in respect of a benefit, the provision most favourable to the employee shall prevail. Prohibition of Forced Labour The decree reiterates the prohibition of forced labour through direct or indirect practice, including withholding employees' national ID cards or passports and making unlawful wage deductions to repay loans or debts. Discipline: Flexibility with Boundaries While employers retain flexibility to design their own graduated schedule of disciplinary penalties, ranging from verbal or written warnings, to wage deductions within statutory caps, suspension or demotion, tailored to their establishment's activity. However, dismissal from service may only be imposed by the competent Labour Court upon proof of gross misconduct, and only after lesser sanctions have been exhausted where the nature of the violation permits. Key procedural safeguards: Investigation must commence within seven (7) days of discovery of the violation and must not exceed three (3) months. No penalty may be imposed more than thirty (30) thirty days after the conclusion of the investigation. Deductions for a single violation may not exceed five (5) days’ basic wage, and total monthly deductions for penalties may not exceed five (5) days’ basic wage. Penalties imposed under the regulation are maximum thresholds; the employer may impose a lesser penalty or close the investigation depending on the circumstances. A Structured Ratification Process The decree introduces a certification procedure with fixed time limits: The employer files the draft regulation with the competent Labour Directorate. The Directorate forwards a copy to the competent trade union within three (3) working days. The union has fifteen (15) days to provide written comments (silence is deemed approval). The Directorate reviews and either certifies or raises a reasoned objection within thirty (30) days (silence means the regulation is deemed effective). Termination: Clear Separation of Grounds The decree requires employers to address each ground for termination separately in their regulations, without conflating constructive resignation with voluntary resignation, or resignation with the notice period, or termination with disciplinary dismissal. Notably, the decree prohibits the inclusion of a notice period for resignation in the regulation; a notice period may only be agreed in case of mutual termination, rescission by consent or similar bilateral arrangements. What Should Stakeholders Do Now? We recommend that employers take the following steps as a priority: Audit existing HR policies: map current policies, contracts and any existing regulation against the full mandatory content checklist and identify gaps. Conduct a benefits review: ensure no currently enjoyed right or benefit is omitted or narrowed in the new regulation. Formalise new work arrangements, document flexible, remote and hybrid work arrangements as now required. Develop KPI and promotion frameworks, establish objective, published performance evaluation and promotion systems. Implement anti-harassment and anti-bullying policies: establish clear definitions, complaint mechanisms and escalation procedures as required by the decree. Review termination provisions: ensure each ground for termination is addressed separately and that no resignation notice period is included in the regulation. Prepare and file the regulation: submit the completed regulation to the competent Labour Directorate without delay. For employees, the decree represents a meaningful strengthening of workplace protections. Workers should familiarize themselves with the new framework and understand their rights; particularly in relation to anti-harassment and anti-bullying safeguards, the non-regression principle protecting existing benefits, and the procedural guarantees that now govern disciplinary action. Authors: May Elmahdy, Senior Associate

The International Chamber of Commerce ("ICC") has approved a revised version of its Rules of Arbitration, which will enter into force on 1 June 2026 (the "2026 ICC Rules"), replacing the 2021 Rules of Arbitration (the "2021 ICC Rules"). The revised Rules will apply to all requests for arbitration filed on or after 1 June 2026. Described by the ICC as the most substantial revision since 2012, the 2026 ICC Rules are designed to enhance efficiency, clarity and user-friendliness, ensuring ICC arbitration remains responsive to the evolving needs of global users. Claudia Salomon, President of the ICC International Court of Arbitration, has noted that the revisions "make the Rules clearer and arbitration more efficient, while preserving the flexibility and procedural integrity that parties expect". As the 1 June 2026 entry into force date approaches, it is essential for businesses, in-house counsel and practitioners across the region to familiarise themselves with the key changes that the new Rules will bring. This article provides an overview of the most significant amendments introduced by the 2026 ICC Rules, together with our initial observations on their practical significance for businesses and practitioners in the Middle East and beyond. Introduction of a Highly Expedited Procedure One of the most notable innovations under the 2026 ICC Rules is the introduction of a new highly expedited procedure, enabling tribunals to issue a final award within just three months. This mechanism is designed to meet the increasing demand for swift and enforceable decisions in urgent, time-sensitive disputes, and will operate on an opt-in basis as a pilot project subject to ongoing review. Under this framework, disputes may be resolved solely on the basis of written submissions, without a hearing, and parties may agree to the issuance of an award without reasons. Parties will be required to present their full case at the outset, including all evidence and arguments, and joinder and consolidation will not be permitted. A sole arbitrator is to be agreed upon by the parties within 20 days or, failing agreement, appointed by the ICC Court. It remains to be seen which sectors will adopt this procedure, although it is likely to appeal to industries such as cryptocurrency and commodities where speed is often commercially critical. Commentators have also noted that the procedure is likely to attract significant attention in the construction and energy sectors, as well as intellectual property, technology-related disputes and M&A arbitrations, where the ability to secure a rapid and final determination is often critical. In the construction and energy context, how this procedure will interact with DAB and adjudication mechanisms remains to be seen; however, it could prove a valuable additional tool for achieving timely, contemporaneous final resolution of issues central to the delivery of major projects, including disputes over development commitments, design standards, serial defects, acceleration instructions or the application of liquidated damages to interim milestones. Increased Threshold for the Expedited Procedure Under the 2026 ICC Rules, the monetary threshold for the automatic application of the Expedited Procedure Provisions ("EPP") will increase from USD 3 million to USD 4 million for claims brought under arbitration agreements concluded on or after 1 June 2026. Given that, in 2025 alone, over 40% of ICC cases did not exceed USD 4 million, this adjustment broadens the range of disputes eligible for expedited arbitration. Since the introduction of the EPP in 2017, the ICC Court has administered 1,034 cases resulting in 591 awards under these provisions. Importantly, party autonomy is preserved: parties remain free to opt in or out of the EPP regardless of whether a case falls within the automatic monetary threshold. Removal of Mandatory Terms of Reference Perhaps the most significant procedural change is the removal of mandatory Terms of Reference ("TORs"), long regarded as a defining feature of ICC arbitration. Under Article 23 of the 2021 ICC Rules, the arbitral tribunal was required to draw up TORs within 30 days of the file being transmitted to it, though extensions were frequently granted in practice. Under the 2026 ICC Rules, TORs are no longer a necessary step in ICC proceedings, although arbitral tribunals retain the discretion to establish them where appropriate as a useful case management tool. This approach builds on the experience of the EPP, under which TORs were already optional; the ICC Court has administered more than 1,000 cases under the EPP, with fewer than 25 tribunals deciding to draw up TORs. In parallel, the Case Management Conference ("CMC"), which remains mandatory and must be held within 30 days of the transmission of the file to the arbitral tribunal, assumes a more central role as the principal procedural milestone for structuring proceedings. Notably, no party may introduce new claims after the initial CMC without the authorisation of the arbitral tribunal, taking into account, amongst other factors, the nature of the new claims, the stage of the proceedings and any cost implications. Early Determination of Claims Taking inspiration from common law mechanisms and similar provisions already adopted by the LCIA, the 2026 ICC Rules introduce an early determination mechanism. Any party may request the arbitral tribunal to make an early determination of one or more claims or defences where such claims or defences are manifestly without merit or manifestly outside the jurisdiction of the tribunal. The arbitral tribunal retains full discretion as to whether to allow the request to proceed and, if so, shall adopt such procedural measures as it considers appropriate, after consulting the parties. This provision is a welcome development for practitioners seeking to prevent unmeritorious arguments from delaying proceedings and inflating costs. Flexible Time Limits for Rendering Awards Under Article 31 of the 2021 ICC Rules, arbitral tribunals were generally required to issue their final award within six months from the date the TORs were signed or approved, though this deadline was frequently extended in practice. The 2026 ICC Rules replace this fixed default with a more flexible approach: under Article 34, the President of the ICC Court shall fix, or subsequently extend, the time limit for rendering the final award, taking into account the procedural timetable or a reasoned request from the arbitral tribunal. In practice, most arbitrations will continue to operate under time limits aligned with the procedural timetable, as was already the prevailing approach under previous editions of the ICC Rules. Fully Electronic Communications and Awards Codifying what has become established practice, the 2026 ICC Rules specify that all communications and submissions should be conducted in electronic form, whether via email, ICC Case Connect or other digital means. This reflects a continued move toward greater efficiency, cost reduction and environmental sustainability in arbitration proceedings. In addition, upon consultation with the parties, arbitral tribunals will be empowered to sign awards electronically and in separate counterparts. Parties will, however, still be able to request hard copies where necessary — for instance, for enforcement purposes in jurisdictions where national courts require certified hard copies or original signed documents. Enhanced Disclosure Requirements and Arbitrator Independence The 2026 ICC Rules strengthen the framework governing arbitrator independence and impartiality. From the outset of the arbitration, each party must submit to the ICC Secretariat a list of persons and entities which it believes prospective arbitrators should consider, together with the reasons for such consideration. This new provision formalises a structured mechanism through which parties can proactively raise potential points at an early stage, thereby promoting efficiency and reducing the risk of late-stage challenges. For the first time, the 2026 ICC Rules codify the ICC Court's long-standing practice that any doubts a prospective arbitrator may have about whether to make a disclosure shall be resolved in favour of disclosure, and that disclosure alone does not, by itself, establish a lack of independence or impartiality. Confidentiality The ICC considered introducing default confidentiality for ICC arbitrations under the 2026 ICC Rules but ultimately decided against it. A blanket confidentiality regime was seen as potentially problematic, particularly for government parties that may require a greater degree of transparency. Instead, the 2026 ICC Rules introduce an express duty of confidentiality on arbitrators themselves, mirroring the existing obligation applicable to the ICC Court and Secretariat. By comparison, arbitral proceedings are confidential by default under several other leading arbitration rules, including the LCIA Rules (Article 30), the SIAC Rules (Rule 59) and the HKIAC Rules (Article 45). Enhanced Emergency Arbitration Provisions The 2026 ICC Rules introduce important clarifications to the emergency arbitration provisions. Emergency arbitrator proceedings may now be initiated not only against signatories to the arbitration agreement and their successors, but also against any party for which the President of the ICC Court is satisfied, on a prima facie basis, that a binding arbitration agreement may exist. This reflects the evolution in practice developed over 287 emergency arbitration applications administered since the provisions were first introduced in 2012. For the first time, the 2026 ICC Rules also expressly acknowledge preliminary orders, including on an ex parte basis. A party may request a preliminary order directing another party not to frustrate the purpose of the application — for instance, to prevent asset dissipation or destruction of evidence. Procedural safeguards are built into the framework: if a preliminary order is granted, the emergency arbitrator must immediately afford all other parties a reasonable opportunity to present their case and retains the power to modify or revoke the order in light of subsequent submissions. Truncated Tribunals The 2026 ICC Rules introduce a new provision addressing situations where an arbitrator dies or is removed after the last hearing or the filing of the last submissions. In such circumstances, the ICC Court may decide that the remaining arbitrators shall continue the arbitration without replacing the departed member, having taken into account the views of the remaining arbitrators and the parties, as well as any other relevant matters. This is a pragmatic measure designed to prevent the costly re-running of arbitrations that have already reached an advanced stage. Tribunal Secretaries The 2026 ICC Rules formalise the role of tribunal secretaries. After consulting the parties, the arbitral tribunal may appoint a tribunal secretary to work under its direction and control, without delegating its decision-making authority. Tribunal secretaries shall satisfy the same requirements of independence, impartiality and confidentiality as those applicable to arbitrators under the Rules, and shall sign a declaration of acceptance, availability, impartiality and independence prior to their appointment. Practical Implications for the Middle East The 2026 ICC Rules are of particular relevance to practitioners and businesses operating in the UAE, KSA, Egypt and Kuwait, where ICC arbitration remains a widely used dispute resolution mechanism across sectors including construction, energy, banking and finance, and infrastructure. The removal of mandatory TORs, the introduction of the highly expedited procedure, and the strengthening of the emergency arbitration provisions are likely to be of significant practical value in these jurisdictions, where the speed and enforceability of arbitral awards are often of paramount commercial importance. Businesses and in-house counsel in the region should review their existing arbitration clauses and dispute resolution strategies in light of the 2026 ICC Rules ahead of their entry into force on 1 June 2026. In particular, parties may wish to consider whether the new highly expedited procedure or the enhanced EPP threshold may be suitable for the types of disputes they most commonly encounter. GLA & Co's dispute resolution team is available to assist clients in understanding the impact of the 2026 ICC Rules and in reviewing and updating their contractual dispute resolution provisions accordingly. Authors: May El Mahdy, Senior Associate and Mohammed Al Awadhi, Partner.