Egypt · Data Privacy

Egypt's Personal Data Protection Law (PDPL, Law No. 151/2020) is in force, establishing a Personal Data Protection Center and benchmarking the GDPR framework: processing personal data requires a lawful basis, data subject rights must be guaranteed, and cross-border transfers must meet restrictive conditions. Chinese companies processing Egyptian user or employee data must comply with this law and also meet China's Data Security Law and PIPL export requirements.

Key points

Law No. 151/2020 (PDPL) is in force, establishing the Personal Data Protection Center as the regulator.
Processing personal data requires a lawful basis and guarantees data subject rights (access, rectification, erasure, etc.).
Cross-border transfers: must meet equivalent protection levels or obtain data subject consent, among other conditions.
Violations can be penalized with fines and business restrictions.
China's PIPL dual compliance also applies: domestic employee or user data leaving China must pass a security assessment or use a standard contract.
China data export obligations (pkulaw verified 2026-07): transfers/return of data to China must use one of three routes — security assessment (CAC Order No. 11), standard contract (Order No. 13), or certification (CAC·SAMR Order No. 20, effective 2025-10-14); the 2024–2025 regulatory stance has relaxed — the Provisions on Promoting and Regulating Cross-Border Data Flows (Order No. 16) and the Regulations on Network Data Security Administration (State Council Order No. 790) exempt some situations.

Procedure

Data inventory and lawful-basis confirmation.
Draft privacy policies and data subject rights response mechanisms.
Pre-transfer assessment (Egyptian PDPL + China PIPL).
Appoint a data processing officer and conduct training.
Establish data breach emergency procedures.

Hard requirements

Lawful basis; cross-border transfer compliance; PIPL linkage.

Costs

Compliance system building; legal consulting.⏱ ⏱ Timeline：Continuous compliance.

⚠ Common risks

Non-compliant processing faces regulatory penalties.
Cross-border transfer violations (dual violation on Egyptian and Chinese sides).
Data breach reputational damage and legal liability.

Handbook

📘 Step-by-Step Handbook (with owner / timeline / cost / penalties)

Applies to：Chinese companies processing Egyptian residents' personal data in Egypt, or transferring it back to China (governed by Law No. 151/2020 and the 2025 implementing regulations, full enforcement from 2026-10-31).

Prerequisites

Processing activities clarified and a PDPC general license (valid 3 years) obtained.
Cross-border transfers, sensitive processing, etc. require separate special licenses.
Budget reserved for DPO registration and Arabic notices.

Step	Action	Owner	Timeline	Cost	Official form / system	Notes & penalties
1	Data inventory and lawful-basis confirmation. Map personal data categories and processing purposes, confirm the lawful basis (mainly explicit consent), and establish a ROPA.	Legal/Compliance	2–3 weeks	Internal cost	ROPA, data inventory	Consent must be specific and recorded in writing. Penalty：Fine EGP 200,000–5,000,000.
2	Apply for PDPC processing licenses (general + special). Apply to the Personal Data Protection Center (PDPC) for a general processing license (3-year validity); cross-border transfers and sensitive data require separate special licenses.	Legal	Per portal opening (mid-2026)	License/application costs	PDPC license application	Grace period until full enforcement on 2026-10-31. Penalty：Processing without a license can be penalized and business restricted.
3	Publish Arabic privacy notices and consent. Publish concise, visible privacy notices in Arabic and obtain explicit, itemized, verifiable consent (no bundling or pre-checking).	Legal	1–2 weeks	Internal/translation costs	Arabic privacy notice, consent records	Sensitive information or children (<15) require written consent or parental consent. Penalty：Same ceiling as step 1.
4	Cross-border transfer license and mechanism. Apply to the PDPC for a cross-border transfer license and prove the destination's protection level; returning data to China requires simultaneous PIPL export mechanisms.	Legal	3–6 weeks	License/lawyer costs	Cross-border license, PIPL export documents	Cloud storage also requires a license. Penalty：Unlicensed cross-border transfer is penalized and business suspended.
5	Appoint and register a DPO. Where applicable, appoint a qualified data protection officer and register with the PDPC (obtain an accountability code).	Management	Ongoing	DPO staffing/exam costs	DPO appointment, PDPC registration	Categories A/B/C, reassessed every three years. Penalty：Failure to appoint or register is penalized.
6	Data subject rights response (6 working days). Establish access, rectification, erasure response mechanisms; the PDPL requires responses within about 6 working days (fees up to EGP 20,000).	DPO/customer service	No more than 6 working days	Internal cost	DSAR process	Must establish a PDPC-recognized mechanism. Penalty：Refusing to respond is penalized.
7	Notify breaches within 72 hours. Notify the PDPC within 72 hours of a breach and affected individuals within 3 working days thereafter.	DPO/IT	72 hours + 3 working days	Internal cost	PDPC breach report	Set up automatic triggers. Penalty：Late or concealed reporting aggravates penalties.

✅ Self-check list

⚠ Common pitfalls

Assuming the PDPL is still 'dormant' and non-compliant影响：Directly penalized after 2026-10-31规避：Complete licenses and systems within the grace period

Transferring cross-border without a PDPC license影响：Penalized and relevant business suspended规避：Apply for the cross-border data transfer license first

English-only privacy notices影响：Notice invalid规避：Provide notices in Arabic

Ignoring PIPL export for data return to China影响：Dual violation规避：Handle China-side mechanisms in parallel

DPO not registered with the PDPC影响：Penalized for missing accountability mechanisms规避：Register immediately after appointment to obtain the code

Breach reported after 72 hours影响：Aggravated penalties规避：Set up automatic reporting triggers

📅 Ongoing post-incorporation obligations

Renew PDPC licenses (general term 3 years)
Maintain DPO registration and 3-year reassessment
72-hour breach notification and individual notice
Continuously respond to DSAR requests
China PIPL data export mechanisms remain effective

🔗 Official portals

Egyptian Ministry of Communications and Information Technology (MCIT, issuer of the PDPL)Cyberspace Administration of China (CAC, cross-border data)

📎 Source：Egyptian Personal Data Protection Law No. 151/2020; Egyptian Data Protection Center; https://www.cac.gov.cn

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