Egypt's Financial Regulatory Authority (FRA) set September 28, 2026 as the deadline for major non-bank financial institutions (NBFIs) to purchase Carbon Emission Reduction Certificates (CERCs) on Africarbonex equal to 20% of their disclosed annual Scope 1 and Scope 2 emissions, under Board of Directors Decision No. 36 of 2026. The offset obligation falls 90 days after the 30 June 2026 carbon footprint report, which is why it lands on September 28, 2026.
FRA-licensed NBFIs with issued capital or net equity above EGP 100 million must purchase CERCs on Africarbonex equal to 20% of disclosed annual Scope 1 and Scope 2 emissions by September 28, 2026, or breach the operating-licence condition and risk suspension or withdrawal of the NBFI licence. Insurers, leasing, mortgage finance, microfinance and securitization firms above the threshold that have already filed their first verified carbon report now face the offset step, the first real crunch point under a mandate that has applied since 18 February 2026.
What applies on September 28, 2026
On September 28, 2026, the offset obligation under FRA Decision 36/2026 falls due: every in-scope NBFI must purchase CERCs on Africarbonex, the regulated voluntary carbon market operated by the Egyptian Exchange (EGX), equal to 20% of the Scope 1 and Scope 2 emissions it disclosed in its annual carbon footprint report. The 90-day window runs from the 30 June 2026 first report, which is why the offset date sits at 28 September 2026, as the Financial Regulatory Authority set out when its board adopted the decision; Amwal Al Ghad reported the same window.
The FRA adopted Decision 36/2026 on 15 February 2026 and it entered into force on 18 February 2026, making carbon disclosure and offsetting a precondition for holding an NBFI operating licence. It builds on Prime Ministerial Decree 4664/2022, which classified CERCs as tradable financial instruments, and on FRA Decisions 163/2023, which accredits the Validation and Verification Bodies (VVBs) that must sign off the carbon report, and 31/2024, which sets the carbon credit listing rules on Egyptian exchanges.
| Date | Event |
|---|---|
| 15 February 2026 | FRA Board adopts Decision 36/2026 |
| 18 February 2026 | Decision enters into force; compliance becomes a licence condition |
| 30 June 2026 | First verified annual carbon footprint report due |
| 28 September 2026 | CERC offset deadline: 20% of disclosed Scope 1 and Scope 2 emissions |
Who is covered
The mandate catches FRA-licensed NBFIs with issued capital or net equity above EGP 100 million, roughly 50 to 70 large entities across five sub-sectors: life and property-and-casualty insurers, leasing and factoring companies, mortgage finance firms, microfinance and consumer-finance companies, and securitization and portfolio-investment firms. Al-Ahram has also covered the mandate.
Banks are not in scope: they sit under the Central Bank of Egypt's separate Binding Sustainable Finance Regulations of November 2022. NBFIs below the EGP 100 million threshold are not caught, and EGX-listed companies face a different FRA ESG disclosure track under Decisions 107 and 108 of 2021. The 20% offset, verified by an FRA-accredited VVB, is specific to the NBFI carbon regime created by Decision 36/2026.
What to do before September 28, 2026
- Confirm the entity's issued capital or net equity exceeds the EGP 100 million threshold and that it holds an FRA NBFI operating licence.
- Measure annual Scope 1 emissions (fuel combustion in generators, company-owned vehicles, on-site operations) and Scope 2 emissions (purchased electricity, heating and cooling).
- Engage an FRA-accredited Validation and Verification Body (VVB) to verify the carbon footprint report.
- File the verified annual carbon footprint report with the FRA; the first report was due 30 June 2026.
- Calculate 20% of the disclosed Scope 1 and Scope 2 emissions and purchase matching CERCs on Africarbonex (EGX).
What happens otherwise
Non-compliance breaches the FRA operating-licence condition, risking suspension or withdrawal of the NBFI licence. The Financial Regulatory Authority supervises and enforces the regime, while the Egyptian Exchange operates Africarbonex as the regulated voluntary carbon market for the CERC offset. Neither the decision nor the rulebook fixes a monetary fine: the sanction is operational, a licence at risk.
Continuous, per-jurisdiction real-time monitoring surfaces this kind of deadline the moment it publishes, so compliance teams see the offset date while there is still time to act.
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