The Central Bank of Egypt (CBE) announced this week that banks may use authorised agents to provide selected services on their behalf, including customer identification, to widen financial inclusion and reach underserved areas. The circular sent to bank chief executives says the board approved the framework on 28 October. Its text is more restrictive than the public summaries suggest. For the payment companies, mobile-wallet operators and retail networks that built businesses moving money, it defines an agent as a point of customer acquisition and paperwork, not a place to deposit or withdraw cash. 

A closed list of tasks

The circular limits agents to the activities it names. They may identify and verify customers, including electronically through the central bank’s Digital Financial Identity platform, and update customer records. They may receive and complete application forms for accounts, cards, transfers and cheque books, and pass them to the bank. They may complete loan and credit-card application forms, but not the contracts, cheques or promissory notes. They may hand over bank cards, provided the cards are not yet activated. They may also run financial-literacy campaigns and distribute marketing material printed by the bank.

The list does not mention taking deposits, paying out cash, executing transfers or disbursing loans. A separate provision bars agents from carrying out transactions for a customer unless the customer is physically present, has been identified, and shows a valid identity document. Agents may deal only with the account holder, not with a proxy or authorised representative. The exception is awareness and marketing activity, which may be open to anyone.

This differs from the agent models that spread banking in Kenya and Nigeria. Their frameworks, introduced in 2010 and 2013 respectively, allow agents to take deposits and pay out cash. The narrow Egyptian scope limits the risks that come with handling cash, such as theft, float shortfalls and fraud. It also limits what an agent can earn.

Why the central bank is doing this

The stated aims are to bring excluded individuals and small businesses into the formal system and to avoid the cost of building more branches. The CBE says financial inclusion reached 79% in June 2026, up 229% on 2016. The official measure counts adults with an active account of any kind, including bank accounts, Egypt Post accounts, mobile wallets and prepaid cards. At the end of 2025, 54.7m of 70.5m citizens aged 15 and over had such an account. That implies about 16m adults were outside the count at the time. Egypt is aiming for an 80% adult inclusion rate by the 2029/30 fiscal year. 

Agents follow a run of recent rules aimed at the same gap. In August the CBE approved rules for opening accounts remotely through electronic customer identification. A circular of 1 September 2025 set controls for “banking service units.” These come in three types: mobile units such as buses or fitted-out vehicles, fixed units set up in places such as youth centres or agricultural associations, and temporary units for financial-literacy work. The agent rules extend this to third parties that already have premises and customers. 

Egypt also has long experience of non-bank retail networks. Fawry, the payments company, had about 356,000 agents across 36 member banks as of March 2024. Its FawryPlus unit was set up in 2017 as a joint venture with Banque Misr, CIB and ACIS, and describes itself as the first banking agent authorised by the CBE. The new framework does not say how such arrangements will be treated. FawryPlus has offered services including paying credit-card dues and loan instalments, and the circular’s list of permitted activities contains no payment collection. 

Who can be an agent

The circular sets four categories of eligible entity. The first is institutions supervised by the CBE that have not been sanctioned in the previous two years. The second is non-bank financial firms supervised by the Financial Regulatory Authority (FRA). They also need a letter from the FRA approving the activity and must have had no sanctions in two years. The third is ministries and other government bodies. The fourth is embassies and consulates, with the foreign ministry’s approval. A fifth, residual category covers any other entity with a valid commercial register and tax card. The bank must carry out due diligence on its owners and senior managers, including checks for criminal convictions and offences involving dishonesty.

Fintechs may qualify through the first two routes if they hold CBE or FRA licences, or through the general route if they do not. The CBE’s June 2025 licensing rules for payment institutions required existing operators to regularise their status by June 2026, so licensed payment firms may fall within the first category. The circular does not address this directly. 

Every agent, other than a government body or diplomatic mission, must meet minimum conditions:

• It must be a legal person, not an individual.
• It must never have been classed as a defaulter or faced bankruptcy proceedings.
• It must have at least two years of experience in its field.
• It must have suitable infrastructure and staff, and its owners and managers must be of good standing and financially sound.

Agency work cannot be its only line of business. It may not use the word “bank” in its name or marketing. It may not subcontract its obligations. The two-year requirement rules out newly formed companies, including start-ups, whatever licence they hold.

Who carries the risk

The bank carries it. The circular makes the contracting bank ultimately and fully responsible for the agent’s conduct and for compliance with anti-money-laundering rules. Banks must adopt a board-approved agent policy covering selection, risk assessment, monitoring, termination and business continuity. They must build agent risk into their money-laundering and terrorist-financing risk assessments and include agent inspections in the annual internal audit plan. They must also train agent staff before they start. Banks must publish a list of their agents and the services they provide on their websites and in their annual reports.

The contract terms favour the bank. Contracts run for at most three years and are renewable after the CBE is notified at least three months before expiry. The bank may add, change or withdraw services or contract terms alone, while the agent may not change the services it is given. Agents may operate only from the premises named in the contract and during the hours it specifies. The agent’s fees are fixed in the contract and the agent may not charge customers more. The bank has rights to inspect the agent’s systems, records and premises, and so does the CBE.

The data clause may matter most commercially. All records and documents relating to transactions the agent carries out belong to the bank. The agent may not use them in any way or share them with anyone else, during or after the contract. It must hand them over within 30 working days of termination. For a business whose value lies partly in what it knows about its customers, the rule bars using agency data to build or sell anything else. The agent must display a sign naming the banks it works for, which implies it may serve more than one bank.

A slow approval path

The CBE keeps tight control over who becomes an agent. A bank must first submit a package for the programme as a whole. It includes the board policy, evidence of infrastructure, a risk assessment signed off by its compliance and risk functions, a plan for geographic expansion and a business continuity plan. The expansion plan must give priority to governorates with low inclusion and be coordinated with the central bank’s financial inclusion sector. The bank must also supply an agent assessment model that the CBE says it will provide.

Each new agent then needs the CBE’s written approval. The submission includes:

• A conflict-of-interest declaration from the agent and the bank.
• A commercial register extract less than six months old.
• Criminal-record certificates for owners and managers.
• Evidence of solvency.
• A report from the Egyptian Credit Bureau.
• Beneficial ownership down to natural persons holding 25% or more.
• The draft contract, service list and working hours.

Approval lapses if the agent does not start work within six months. Changes to any approved item need prior approval, and the CBE must receive at least a month’s notice before an agent is dropped. Banks file quarterly reports on agent numbers, transactions by product, location, sex and age band, complaints, outlets opened and closed, outages, and cases of fraud, theft or data breach.

What the circular leaves open

The text does not give an effective date or say how existing arrangements with third-party “service providers” will be treated. It sets no penalty regime for banks or agents. It requires agents to report cyber, fraud and operational incidents “within a defined timeframe” but does not state it. The CBE’s agent assessment model has not yet been published, so banks cannot complete their applications.

Nor does it say what agents will earn. Fees are left to the contracts, and the central bank sets no scale. An agent that fills in forms and hands over cards, cannot use the data it collects, may have its services changed by the bank at any time, and works under a three-year contract will be paid whatever the bank decides to offer.

The CBE says the rules aim to widen access while protecting customers’ rights and the confidentiality of their data. Whether they reach people now outside the system will depend on banks choosing and supervising suitable agents, making services easy to reach and protecting customers. For the fintechs that applied for the work, the framework settles who may collect the forms. It does not yet settle who gets paid for collecting them.