Guides. Omar Hamdy, on the lender's side, in Cairo. Written in a personal capacity.

Last checked 1 November 2026

Carbon footprint reporting for non-bank financial companies in Egypt: FRA Decision 36 of 2026

If your company is licensed by the Financial Regulatory Authority (FRA) and its issued capital or net equity is above EGP 100 million, you owe the FRA a verified carbon footprint report by 31 December 2026, and then you must buy carbon credits equal to 20% of the emissions in it within 90 days. This guide sets out what the decision says, what it does not say, and how to get from today to a filed report.

Run the institution review

At a glance

The rule in one table

Item	What the text says	Source
Instrument	FRA Board Decision No. 36 of 2026 on the obligation of companies operating in non-bank financial activities to disclose and offset their carbon emissions	Al-Waqai Al-Misriya, issue 39 (supplement b), 17 February 2026
Approved	By the FRA Board on 28 January 2026; in force from the day after publication	Decision 36, preamble and Article 5
Who	Companies operating in non-bank financial activities whose issued capital or net equity exceeds EGP 100 million	Article 1
What	A detailed annual carbon footprint report on the emissions from the company's activities	Article 1
Scope	Scope 1 and Scope 2 only "at this stage"	Article 1
Verification	The data must be reviewed and verified by a verification and validation body registered in the FRA's register for that purpose	Article 1; registration criteria in FRA Board Decision 163 of 2023, as cited in the preamble
First deadline	31 December 2026 (originally the end of June 2026)	Decision 115 of 2026, Article 1
Later reports	Annually, "in conjunction with the end of the company's financial year"	Article 1
Offset	20% of total annual emissions shown in the report, by buying carbon emission reduction certificates	Article 2
Offset deadline	Within 90 days of submitting the report to the FRA	Article 2
Which credits	Certificates registered in the FRA's Climate Project Registry, bought through the regulated voluntary carbon market	Article 3
Consequence	Meeting these obligations is a condition of keeping the licence	Article 4

The extension: FRA Board Decision 115 of 2026, approved on 4 June 2026 and published in Al-Waqai Al-Misriya, issue 130 (supplement a), on 17 June 2026, replaced 30 June 2026 with 31 December 2026 for the report. The FRA's press release of 4 June 2026 describes it as giving companies "a significant grace period" after public dialogue with the market.

Who is covered

The decision addresses "companies operating in non-bank financial activities", the firms the FRA licenses and supervises outside banking. Read your own licence against that phrase; if in doubt, ask the FRA in writing and keep the reply.

The threshold is a strict "more than". Decision 36 says issued capital or net equity that "exceeds" (يزيد على) EGP 100 million. Decree 107 of 2021, the ESG disclosure rule, uses "not less than" (لا يقل عن) EGP 100 million. Read literally, a company at exactly EGP 100 million owes ESG disclosure under Decree 107 but not a carbon footprint report under Decision 36. Few companies sit exactly on the line, but if yours does, confirm with the FRA.

Either measure counts. Issued capital or net equity: a company with small issued capital and large retained earnings can still be in.

No exemptions are listed. Decree 107 exempts investment funds (including exchange traded funds), securitisation and sukuk issuance activity (Article 1 bis, added by Decree 196 of 2022). Decision 36 lists no exemptions of its own. Whether the FRA reads the Decree 107 exemptions across is not stated in the text.

What must be reported

Scope 1 is emissions from sources the company owns or controls. For a leasing, factoring, consumer finance or microfinance company that usually means:

fuel burned in standby generators at head office and branches;
fuel used by company-owned or controlled vehicles, including field staff cars and motorcycles;
refrigerant leaks from air conditioning (counted from the kilograms topped up during the year).

Scope 2 is emissions from electricity (and any purchased cooling or steam) the company buys and uses. In practice: every electricity meter at head office, branches, data rooms and warehouses.

Not in the decision: Scope 3, which for a lender includes the financed emissions of its portfolio. Decision 36 limits measurement to Scopes 1 and 2 "at this stage". The words "at this stage" signal that the FRA may widen it later; nothing in the text says when.

Verification is part of the obligation, not an extra. An unverified report does not meet Article 1.

The data table to build

Data field	Unit	Owner in the company	Source document
List of sites (head office, branches, warehouses) in the boundary	Count, address	Administration	Lease and title register
Generator fuel bought	Litres, by site	Administration	Fuel invoices, generator logs
Vehicle fuel	Litres, or km with vehicle type	Fleet or administration	Fuel card statements, mileage logs
Refrigerant top-ups	kg, by gas type	Facilities	Maintenance contractor reports
Electricity	kWh, by meter	Finance	Utility bills, 12 months
Purchased cooling or steam, if any	kWh or tonnes	Facilities	Supplier invoices
Emission factors used	Per unit, with source and year	Report owner	Published factor sources, cited
Organisational boundary choice	Control or equity approach	Report owner, approved by management	Board or management minute
Issued capital and net equity	EGP	Finance	Latest audited financial statements
Verifier's registration with the FRA	Register entry	Report owner	FRA register

Deadlines

Date	What is due	Source
31 December 2026	First carbon footprint report, verified, submitted to the FRA	Decision 36, Article 1, as extended by Decision 115 of 2026
90 days after you submit	Purchase of credits equal to 20% of reported emissions. If you submit on 31 December 2026, day 90 is 31 March 2027	Decision 36, Article 2
Each year after	Next report, "in conjunction with the end of the company's financial year"	Decision 36, Article 1

Two points the text leaves open:

Which year the first report covers. The decision asks for an annual report but does not name the reporting period for the first filing. Most companies will report their last completed financial year. Confirm with the FRA if your financial year does not end on 31 December.
How many days after year end later reports are due. "In conjunction with the end of the financial year" is not a number of days. Plan for the same calendar as your annual financial statements and ask the FRA to confirm.

The offset clock starts when you submit, not on 31 December. Submitting early means buying credits early. Plan the purchase before you press send.

How it connects to Decrees 107 and 108, TCFD and IFRS S1 and S2

Decision 36 is the third layer of FRA climate rules, and it is the first one that requires a verified number.

Rule	Who	What	Assurance
Decree 107 of 2021 (5 July 2021, as amended to 28 December 2022)	Non-bank financial companies with issued capital or net equity of at least EGP 100 million	ESG disclosures in the annual board report attached to the financial statements, on the indicators in Annex 1	Annex 1 asks whether the disclosures are reviewed by an independent third party; it does not require it
Decree 107 of 2021, second paragraph	Those with at least EGP 500 million	TCFD climate disclosures on the indicators in Annex 2: governance, strategy, risk management, metrics and targets	As above
Decree 108 of 2021	Companies listed on the Egyptian Exchange	ESG disclosure, as described on the FRA's ESG disclosure page	Not reviewed here: I could not find the decree text on fra.gov.eg
Decision 36 of 2026	Non-bank financial companies with issued capital or net equity above EGP 100 million	Verified Scope 1 and 2 carbon footprint report, plus 20% offset	Verification by an FRA-registered body is mandatory
Draft IFRS sustainability roadmap (press-reported, 30 August 2026)	Not yet defined	Phased move to the IFRS Sustainability Disclosure Standards	Not yet defined

Decree 107 asked; Decision 36 requires. Annex 1 of Decree 107 asks, among its environmental indicators, whether the company calculates its total carbon emissions annually in metric tonnes. Annex 2, the TCFD annex, asks whether the company discloses its total carbon dioxide emissions for Scope 1 "if any". Those were comply-or-explain questions. Decision 36 turns the answer into a verified Scope 1 and 2 figure filed with the regulator.

TCFD. The verified footprint is the metrics pillar of a TCFD disclosure. Companies above EGP 500 million can now quote a verified figure in their Decree 107 report instead of an estimate, and should make sure both documents carry the same number.

IFRS S1 and S2. The FRA discussed a draft roadmap for the IFRS Sustainability Disclosure Standards at a workshop with the EU and UNDP, reported by Daily News Egypt on 30 August 2026. As reported, it has four stages: simplified climate disclosures, initial implementation of the IFRS standards, full implementation, and a later stage of disclosures aligned with the GRI Standards. The FRA Chairman is quoted as saying the draft "remains under discussion and review before the procedures for its approval are completed". Draft, press-reported; no dates or thresholds published. IFRS S2 is effective internationally for annual periods beginning on or after 1 January 2024 (IFRS Foundation). Two things are worth knowing now: IFRS S2 asks for gross greenhouse gas emissions across Scopes 1, 2 and 3, so a Decision 36 report is the starting block, not the finished disclosure; and credits bought under Article 2 do not reduce gross emissions, so keep the offset in a separate line from day one.

What a DFI lender to a non-bank lender will ask on top

A development finance institution lending to a leasing, factoring or microfinance company will read your Decision 36 report as a sign of data discipline. It will not stop there. Expect, at least:

An environmental and social management system (ESMS) that runs on every transaction: exclusion screening, categorisation, due diligence, covenants and monitoring, as set out in IFC Performance Standard 1, IFC's Guidance Note on Financial Intermediaries (29 September 2023) and EBRD Environmental and Social Requirement 9.
The lender's exclusion list applied to your book, with evidence of the screen on each file.
Financed emissions. A DFI cares about the emissions of what you finance, not only your generators. Expect a request for a portfolio estimate under the PCAF Global GHG Accounting and Reporting Standard, with its data quality score from 1 to 5. Decision 36 does not ask for this; your lender might.
Gross emissions without offsets. A DFI will read your footprint before credits. Report the 20% purchase alongside it, never netted off.
An annual E&S report to the DFI in its template, on dates in the loan agreement.
Consistency. The Scope 1 and 2 figure in the DFI report, the Decree 107 annual report and the Decision 36 filing should be the same number for the same year.

A 10-step readiness plan

Today is eight weeks from the deadline. The order matters more than the speed.

Confirm you are in scope. Check issued capital and net equity against "exceeds EGP 100 million" on your latest audited statements. Record the check and who approved it.
Name the owner and the sponsor. One person owns the report; one member of senior management signs it off. Article 4 makes this a licence matter, so the board should know the date.
Book the verifier now. Choose a body on the FRA's register of verification and validation bodies. Agree scope, timetable and the evidence they will sample before you collect a single invoice.
Set the boundary in writing. Which legal entity, which sites, which vehicles, and whether you use the control or equity approach of the GHG Protocol. Leased branches and shared buildings need a stated rule.
Collect 12 months of activity data using the table above: fuel, refrigerants, electricity, any purchased cooling. Invoices first, estimates only where an invoice does not exist, each estimate labelled.
Choose and cite emission factors. Use published sources, state the year of each factor, and keep the same sources next year so the trend means something.
Calculate and reconcile. Activity data times factor, by site. Reconcile litres and kilowatt hours back to the invoices the verifier will sample.
Verify and correct. Expect findings. Fix them, keep the correspondence, and get the verification statement in writing.
Submit by 31 December 2026 and record the date. The submission date starts the 90-day clock for the offset.
Buy the 20% within 90 days. Credits must be registered in the FRA's Climate Project Registry and bought through the regulated voluntary carbon market. Keep the purchase and retirement evidence with the report, and carry the verified figure into your Decree 107 report and any DFI reporting.

Frequently asked questions

Who must file a carbon footprint report under FRA Decision 36 of 2026?

Companies operating in non-bank financial activities whose issued capital or net equity exceeds EGP 100 million.

Does Decision 36 apply to leasing, factoring and microfinance companies?

Yes, if the company is licensed by the FRA for a non-bank financial activity and its issued capital or net equity exceeds EGP 100 million. The decision does not distinguish between activities and lists no exemptions; if your licence type is in doubt, ask the FRA in writing.

What is the deadline for FRA carbon footprint reports?

31 December 2026 for the first report, after FRA Decision 115 of 2026 extended the original 30 June 2026 date. Later reports are annual, tied to the end of the company's financial year.

Does Decision 36 cover Scope 3 or financed emissions?

No. Measurement is limited to Scope 1 and Scope 2 "at this stage".

Who can verify the report?

A verification and validation body registered in the FRA's register for that purpose. The registration criteria are in FRA Board Decision 163 of 2023.

How does the 20% offset work?

Within 90 days of submitting the report, the company must buy carbon emission reduction certificates equal to 20% of the total annual emissions in the report. The certificates must be registered in the FRA's Climate Project Registry and bought through Egypt's regulated voluntary carbon market.

How does Decision 36 relate to FRA Decrees 107 and 108?

Decree 107 requires ESG disclosure from non-bank financial companies of at least EGP 100 million and TCFD disclosure from those of at least EGP 500 million; Decree 108 covers listed companies. Decision 36 adds a verified Scope 1 and 2 figure and an offset obligation for non-bank financial companies above EGP 100 million.

Is Egypt adopting IFRS S1 and S2?

The FRA has discussed a draft phased roadmap towards the IFRS Sustainability Disclosure Standards (reported 30 August 2026). It is a draft under review, with no published dates or thresholds.

What happens if a company does not comply?

Article 4 makes the obligations a condition of keeping the FRA licence. The decision sets no other penalty in its text.

Send me what you received

If the FRA, your lender or your verifier has sent you a request about Decision 36, send it to me in five short lines: what you received, from whom, the deadline, your sector, and what you want to know. I'll reply by email. I can help prepare the report and the data file; the registered body verifies it.

Send me what you received How engagements run

Guides, checks, toolkit and newsletter are free. Advisory is paid work in a personal capacity: scope agreed in writing, fee quoted after a free first call.

I don't arrange finance, introduce lenders or work on files for my employer's credit decisions. Every enquiry gets a conflicts check before any work.

Sources

FRA texts

Standards

IFRS S2 Climate-related Disclosures, effective for annual reporting periods beginning on or after 1 January 2024 ifrs.org
IFC Performance Standard 1 and Guidance Note on Financial Intermediaries (29 September 2023) ifc.org
PCAF, The Global GHG Accounting and Reporting Standard, Part A carbonaccountingfinancials.com

Press-reported, not yet in law

Daily News Egypt, "FRA discusses proposed roadmap for implementing sustainability disclosure standards", 30 August 2026 dailynewsegypt.com

All views are my own, written in a personal capacity. They do not represent my employer or any other institution. This guide explains published rules; it is not legal advice, and the FRA's own reading prevails.

Cite this guide

Hamdy, O. (2026) "FRA Decision 36: carbon footprint reports for NBFIs in Egypt". omarhamdy.com, 1 November 2026. https://omarhamdy.com/guides/fra-decision-36-carbon-footprint/