First: Introduction
On 5 November 2026, the Egyptian Prime Minister witnessed the signing of a cooperation protocol between the Ministry of Labour, Delivery Hero (Talabat Egypt), and a number of delivery service companies contracted with it. The protocol aims to formalize the status of delivery workers and extend social protection to them. According to the official statement issued by the Cabinet, the protocol provides for the registration of worker lists submitted by delivery companies in separate databases maintained by the Ministry of Labour, under the category of irregular employment. This is intended to enable workers to benefit from the social, healthcare services, grants, and compensation1.
The announced benefits cover death and disability resulting from work-related accidents, natural death and disability, surgical procedures, the death of a first-degree relative, in addition to marriage and childbirth allowances2. The agreement represents a step towards including a category of digital platform workers within social protection procedures. However, the published announcement does not provide sufficient details on the value of each benefit, the eligibility criteria, the duration of coverage, or how to ensure its access to workers and its continuity when needed.
The signing of the protocol comes within the context of legislative and institutional changes relating to the protection of irregular workers. Labour Law No. 14 of 2025 provided for the establishment of the Emergency Aid and Social and Health Services Fund for Irregular Labour3. This was followed by the prime minister’s decree no. 2403 of 2026, which regulates the Fund and defines its mandate4.
On 2 November 2026, the Ministry of Labour announced that discussions were ongoing regarding the Fund’s operational arrangements, the preparation of its financial and administrative regulations, and the rules governing access to its services. It also stated that aid and services would continue to be provided through existing mechanisms during the transitional period5. These arrangements acquire direct importance for the implementation of the protocol, as access to the announced benefits depends on the clarity of the entity responsible for receiving applications, examining eligibility, and disbursing payments, and on the availability of the resources and procedures necessary for that.
The protocol also raises an issue that goes beyond access to social assistance, concerning the legal status of delivery workers and the responsibilities of the companies benefiting from their work. The operational arrangements that bring together a digital platform and intermediary delivery companies require examining the actual relationship between the worker and each party, and determining the entity that controls the conditions of work, remuneration, tasks, and penalties.
Registering a worker in the Ministry of Labour lists categorized as “irregular Labour” does not, in itself, determine their category within the social insurance system or settle their labour rights, nor does it resolve the status of the employer and the resulting legal liabilities. A worker may receive social aid in cases of injury, however, medical expenses, income compensation during periods of work incapacity, and the entitlement to remuneration and social insurance contributions remain subject to other rules and responsibilities that must be examined separately.
From this perspective, this paper addresses the cooperation protocol as an entry point for enhancing the protection of delivery workers. It also offers recommendations that combine ensuring their access to the stated social benefits with the enforcement of their legally established labour and social security rights.
Second: The Protocol and the Problem of the Decree
The protocol was announced as a step towards formalizing the status of delivery workers and providing them with social protection. The announced registration mechanism relies on lists submitted by delivery companies contracted with Talabat Egypt, which this paper refers to as “intermediary offices”. These lists are used to register workers in separate databases under the category of irregular labour, and to make benefits available in accordance with the regulating decisions. The benefits cover death and total or partial disability resulting from a work-related accident, as well as natural death and total or partial disability arising from natural causes. They also include the death of first-degree relatives, major and minor surgical procedures, a one-time marriage grant, and grants upon the birth of a worker’s first and second child, or twins6.
While these benefits may help workers afford emergency expenses or a loss of income, the announcement does not, however, specify the amount or the value of each benefit or its duration, nor does it clarify the extent of coverage for the treatment of temporary injuries, rehabilitation, and compensation for periods of cessation of work. It is therefore difficult to assess what the protocol adds to the protection of workers without comparing what each worker is entitled to by law with the services and benefits they were actually receiving, and hereby determining the additional benefits the agreement provides while verifying their access to those entitled to them. Moreover, registering a worker in the Ministry of Labour’s lists does not automatically expand their social insurance coverage or ensure that they receive the announced services. Safeguards that are not mentioned in the announcement, but included in the full text of the protocol, should be made public, their eligibility requirements clarified, and their implementation monitored.
The registration mechanism announced under the protocol relies on lists submitted by delivery companies contracted with Talabat to the Ministry of Labour, making the accuracy and completeness of these lists key factors affecting workers’ access to social benefits. Missing an eligible worker’s name or having an error in their data may result in the disruption of their registration or the consideration of their eligibility, particularly if they do not have an independent means of verifying and correcting their data.
Workers’ movement between intermediary companies or cessation of work also raises questions concerning the continuity of their registration and their eligibility for benefits, which the published announcement of the protocol does not explain how to address. The distinction between eligibility procedures and a worker’s legal status is particularly important, as registration under the category of irregular labour does not resolve their relationship with the companies or their labour and social insurance rights. Conflating these pathways may result in disrupting the worker’s access to a benefit to which their eligibility has been established, because of a separate dispute concerning their remuneration or insurance contributions.
The distinction between registering for access to the benefits provided under the protocol and workers’ labour and social insurance rights reveals the multiplicity of entities responsible for protecting workers. The lists received by the Ministry of Labour enable workers to be registered among the categories eligible for social benefits, while their social insurance and healthcare rights are governed by other rules and systems, which may involve different entities responsible for their administration and financing. This overlap appears in the competences of the Emergency Aid and Social and Health Services Fund for Irregular Labour defined by the Prime Minister’s decree No. 2403 of 2026, which includes supporting medical treatment and contributing to social insurance premiums.
Moreover, the Fund’s contribution to these social insurance premiums is conditional on agreement with the Ministers of Finance and Social Solidarity and the National Organization of Social Insurance, and is subject to the limits of its available resources. Accordingly, registering a worker under the protocol does not automatically mean that their social insurance contributions will be paid, nor does receiving a benefit from the Fund resolve the companies’ responsibility for the labour and social insurance obligations arising from the employment relationship. This overlap between competences makes the Fund’s operational arrangements and the rules for benefiting from its services an influencing factor in determining the protection that the protocol can actually provide7.
The Fund’s institutional status is particularly significant given the timing of the protocol’s signing. On 2 November 2026, three days before signing the agreement, the Ministry of Labour announced the continuity of its work on finalizing the arrangements necessary for the Fund’s operation, preparing its financial and administrative regulations and the rules for benefiting from its services, while continuing to provide aids and services to irregular workers through the existing mechanisms8.
Thus, the announcement of the protocol came during a phase in which the Fund’s operational arrangements had not yet been completed, which raises the question of how the announced benefits are to be implemented during this transitional phase. Assigning the disbursement of benefits to the Fund does not, on its own, clarify which entity will assume responsibility for receiving delivery workers’ applications, examining their eligibility, and disbursing their entitlements until the Fund’s operational arrangements are completed. It also does not clarify the way these procedures will be transferred from the existing mechanisms to the Fund. Lacking these details in the published information makes it difficult to assess the readiness of the concerned entities to implement the protocol, and the extent to which workers can access their entitled benefits without disruption resulting from the regulatory changes.
The Protocol’s arrangements reveal a fundamental distinction between the social benefits managed and disbursed by the Fund and the rights arising from workers’ relationships with the companies. Including delivery workers within the categories of irregular labour opens a pathway for them to benefit from the aids and services established in accordance with their criteria. However, this does not resolve the status of the relationship between workers and Talabat or its intermediary companies, nor does it specify labour and insurance obligations arising therefrom.
Assigning responsibility for disbursing benefits to the Fund also raises questions about how the costs of social protection are distributed between the state and the companies that benefit from these workers’ labour. However, the information published about the protocol does not clarify the extent of each party’s contribution to financing the benefits, nor does it provide data that would allow an assessment of whether public resources are being used to cover costs arising from obligations that companies are legally required to fulfill. It is therefore difficult to assess the protocol’s actual impact on workers’ protection without distinguishing between the additional social benefits it provides and the existing rights that the legally responsible entities are obligated to fulfill, which is quite relevant to determining the nature of the employment relationships and the allocation of responsibilities among the parties involved.
Third: Protection Requirements and the Responsibilities of the Parties Involved
Article 75 of Labour Law No. 14 of 2025 provides for the application of rights and obligations to irregular workers and workers in the informal sector who work for employers. The definition of a worker in Article 1 of the Law links the employment relationship to the performance of work in return for remuneration, under the management or supervision of an employer9. Accordingly, assessing the relationship between delivery workers and the companies requires identifying who determines remuneration and tasks, monitors performance, and imposes disciplinary measures. Being paid per order or having variable working hours does not, in itself, determine whether these criteria apply.
Determining the nature of the employment relationship affects the worker’s social insurance status and the entity responsible for paying contributions. Social Insurance and Pensions Law No. 148 of 2019 distinguishes between workers employed by others, self-employed workers, and categories of irregular workers, with contributions and benefits varying according to the requirements applicable to each category. Even where subscription to pension insurance is fixed, entitlement to healthcare or income compensation during periods of illness remains subject to other conditions and coverage arrangements10. The assessment of the worker’s insurance status therefore depends on knowing their category, their periods of subscription, the income on which the subscription was paid, and the scope of their rights.
A delivery worker may, for example, receive assistance under the protocol to undergo surgery, but subsequently require medication, medical rehabilitation, and compensation for income lost during the period of work incapacity. The continuation of treatment and the coverage of its costs depend on the worker’s healthcare coverage11, while compensation for the period of work incapacity depends on their insurance status and the cause of the incapacity. Where employment injury insurance applies and the injury prevents the worker from performing their work, Article 49 of the Social Insurance and Pensions Law provides for compensation equivalent to the full remuneration on which contributions have been paid, in accordance with its provisions12.
If the protocol provides an additional guarantee of income compensation during periods of work incapacity, its impact will depend on the eligibility conditions and the entity responsible for providing it, details that are not clarified in the published announcement. Protection against occupational risks and the safeguards applicable when workers are exposed to imminent and serious danger, including those provided for under Article 253 of the Labour Law, remain independent from compensation following an injury, where the relevant provisions apply13.
Determining who is responsible for labour and insurance rights requires examining the distribution of operational functions between the Talabat platform and the intermediary delivery companies contracted with it. Talabat’s restaurant terms and conditions in Egypt indicate that the company selects logistics service providers to provide delivery services14. The legal formalization of these arrangements may differ depending on whether the arrangement constitutes an enrollment of the worker, labour supply, or service outsourcing to another employer. An intermediary company may retain employment contracts and payment records, while the platform maintains order records or holds powers that affect work management. This makes the allocation of responsibilities dependent on the contractual arrangements and actual practices. The determination of employer status, the lawfulness of outsourcing arrangements, and the existence of joint liabilities depend on the actual circumstances and the applicable legal provisions, including the cases governed by Articles 10 and 94 of the Labour Law15.
The data held by the operating entities can help examining power distribution. Talabat’s Rider Privacy Policy indicates that location data, shift planning, and performance information are used, and identifies “Delivery Hero Egypt S.A.E. as a” data controller”16, while conditioning some of its provisions to the worker’s status defined as “employee”. However, data controller status does not resolve employer status, and determining the legal relationship between the mentioned entity and the party that signed the protocol requires examining the relevant corporate documents and the agreement.
The reliance of delivery workers’ registration on lists submitted by intermediary companies makes their participation in monitoring and following up on registration process, eligibility, and correcting their data, a key factor in the implementation of the protocol. Law no. 213 of 2017 on Labor Trade Union Organizations and the Protection of the Right to Organize, amended by Law No. 142 of 2019, permits, under its conditions, categories of irregular labour to organize trade union that transcend the limits of a single enterprise17 . This provides a legal basis for independent representation chosen by workers to participate in consultation regarding the implementation and monitoring of the protocol. This consultation differs from collective bargaining over working conditions, which is regulated by other provisions of the Labour Law18, while workers’ individual rights and legal remedies available to them remain in place.
Fourth: Recommendations
The following recommendations combine measures to be taken by public authorities within the limits of their competences, and additional guarantees requiring explicit commitment from the platform and the intermediary companies, while the legal obligations in force remain due during the preparation and implementation of these arrangements.
Publication of the Protocol and Ensuring Workers’ Access to Its Benefits
The paper recommends that the Ministry of Labour publish the full text of the protocol, its annexes, and the decisions or decrees regulating its implementation. It also recommends that the Minister of Labour, in consultation with worker representatives and civil society organizations, issue the regulations governing services and emergency financial aids, pursuant to his competence set forth in Article 80 of the Labour Law19.
Access to these documents should be complemented by the Fund’s Board of Directors adopting a procedural guide setting out the rules in force for accessing the announced benefits. The guide should specify the eligible categories, the amount or value and duration of each benefit, the documents required to access it, the entity responsible for disbursement, the source of funding, and the procedures for challenging decisions concerning these benefits. These arrangements should cover both the transitional period while the Fund’s regulatory framework is being completed and the period thereafter.
The guide should also clarify how a worker’s transfer between intermediary delivery companies, account suspension, or cessation of work affects their eligibility for benefits, as well as the conditions for combining these benefits with other entitlements, without creating entitlements that conflict with the applicable legal framework. Making official documents publicly available is also grounded in the transparency guarantee enshrined in Article 68 of the Constitution20.
To address registration errors, the Ministry of Labour, in coordination with the Fund, should provide an independent mechanism enabling delivery workers to verify their registration, correct their data, and submit applications to benefit from the services, including cases in which their names do not appear in the lists submitted by the companies. These procedures should be accessible through both a digital channels and in-person service offices, with workers receiving proof that their applications have been submitted, a written and reasoned decision in the event of rejection, and clearly defined procedures for challenging such decisions. Applicants’ and complainants’ data should be protected, without prejudice to the Labour Law safeguards against dismissal on grounds of trade union activity or filing complaints, where its provisions apply to the worker’s relationship with the company21.
Implementing this mechanism should include requiring companies to provide the necessary data and correct any errors in their records, while assigning eligibility verification to the competent public authority, without making the acceptance or determination of an application contingent solely on the approval of the intermediary company. The mechanism should also ensure that workers can continue to track their applications when they move between companies, without being required to resubmit documents that remain valid and available to the competent authority.
Among the proposed monitoring safeguards is the involvement of independent representatives chosen by delivery workers in consultation regarding the implementation of the protocol and the monitoring of registration, eligibility, benefit disbursement, and data correction procedures. Labour directorates should provide the information and procedural assistance necessary to enable workers to choose their representatives independently of the companies and exercise their trade union rights in accordance with the law22. Consultation should begin immediately upon the adoption of the implementation plan, with the announcement of the mechanism for selecting representatives, the channels of communication, and the outcomes of the consultation. The existence of general trade union representation on the Fund’s Board of Directors is not sufficient to demonstrate the participation of delivery workers themselves in the preparation and monitoring of implementation arrangements23.
To protect rights independent of social benefits, the rules governing the implementation of the protocol should expressly provide that receiving these benefits does not entail any waiver of workers’ separate labour or social insurance rights or claims. They should also define the Ministry of Labour’s responsibility for monitoring procedures and coordinating between relevant entities, while ensuring that benefits continue to be disbursed by the competent entity at each stage of the institutional transition. The necessary resources should be allocated within the budget of the responsible entity to receive, examine, and determine applications, in accordance with the regulations and decisions in force.
If these safeguards are already provided for in the protocol or its implementing documents, the procedures for accessing them should be published and their effectiveness assessed. To measure the success of implementation, the paper proposes adopting indicators covering the time required to process applications and disburse benefits, the number of pending applications and the reasons for delays, the outcomes of registration data corrections, and the number of workers who have actually received benefits.
Examining Employment Relationships and Social Insurance Registration among the Agreement’s Parties
The paper recommends that the Ministry of Labour and its directorates, in coordination with The National Organization for Social Insurance (NOSI), launch a programme to examine the operational arrangements of the parties to the protocol. The programme should include reviewing contracts, payment records, and deductions; identifying the entity that determines remuneration, shifts, tasks, and disciplinary measures; and examining the insured wage, contribution periods, and actual payment of contributions. Records should also be requested from the entity holding them, whether the platform or the intermediary company, in order to apply the legal rules to each employment relationship according to its actual circumstances, without pre-classifying all delivery workers into a single category24.
Based on the findings of the examination, each entity should, within the limits of its competence, correct the violations revealed by the examination of the employment relationship and insurance registration, and require the obligated parties to fulfill their due obligations. Where the Labour Law applies, the relevant obligations should be reviewed, including remuneration, deductions, and rest periods, and making wage statement available according to article no. 11525. Other labour and social insurance rights should likewise be examined and enforced, as applicable, in light of the nature of the relationship and the relevant legal provisions.
Where the examination establishes that the conditions for any of the cases provided for under Articles 10 and 94 of the Labour Law are met, claims should be pursued on the basis of joint liability26. Where those conditions are not met, each party’s obligations should be determined separately. Workers should be informed of the review’s findings, the reasons for them, and the documents required to challenge them. Workers and the competent authorities should also be able to obtain copies of, or extracts from, the records necessary to establish eligibility for benefits or review workers’ employment and social insurance status, including records held by the platform or intermediary company, while protecting workers’ and customers’ data and restricting access to what is necessary for the review or examination27. 28The findings should also be used to distinguish cases requiring registration corrections or collection of outstanding entitlements, and shortcomings in the scope of protection that require new rules.
Ensuring the continued follow-up and tracking of the worker’s claims and due benefits is one of the proposed implementation requirements when they move between intermediary companies or cease working with them. The parties should be required to provide workers with a statement of their entitlements, periods of work, and pending applications or claims, and to retain the records necessary to prove them. Insurance contribution periods and benefits remain subject to the relevant legal provisions, without presuming that obligations automatically transfer between intermediary companies29. Claims should be referred to the competent authorities without delaying benefits due. Public authorities should bear the costs of oversight, while the entities legally liable should pay contributions and arrears in accordance with the findings of the review.
Ensuring Access to Healthcare and Injury-Related Benefits
The paper recommends that the Ministry of Labour, the Fund, and the relevant social insurance and healthcare authorities adopt a referral guide specifying each worker’s existing healthcare coverage, the entity responsible for providing and financing healthcare services, and the additional benefits available under the protocol. The guide should outline the process for accessing benefits in governorates where universal health insurance is in effect30, as well as the arrangements for categories covered by services provided by the Health Insurance Organization in other areas31. It should also clarify eligibility conditions, available services, and procedures for following up on treatment and rehabilitation, without presuming that a single coverage scheme applies to all workers.
For workers who cannot establish healthcare insurance coverage, the competent authority should determine which services provided by the Fund or public healthcare arrangements they may be eligible for, and identify any gaps in coverage, without treating emergency aid as ongoing health insurance32. The rights of workers who are eligible for services under the Universal Health Insurance System should be safeguarded, including the guarantee provided under Article 48 where an employer fails to remit contributions33. Workers who have not been registered in the system or whose coverage under it has not been established should be referred to the competent authority to determine their status and entitlements.
Among the elements of the proposed claims guide is the separation of treatment expenses, wage compensation, and any additional income guarantee during cessation of work, and the clarification of procedures for submitting injury documents where the employer refrains from notification34. The special insurance coverages that some workers were benefiting from before the protocol should also be verified, and reviewed whether they remain in force35. Eligibility conditions and exclusions should be reviewed, while preserving any more favourable rights and benefits to which workers are entitled by law or contract.
Transparent Financing and Monitoring of Realized Rights
The paper recommends that the Fund’s Board of Directors and the participating entities, each within its respective mandate, adopt a publicly available financial statement that distinguishes the cost of benefits from the costs of registration, complaints, and oversight. The statement should identify the allocated resources, any additional contributions and their limits, and the entity responsible for financing and disbursement during the transition to the Fund’s operational arrangements. It should also specify the legal basis for any contribution by the Fund towards social insurance contributions, the agreement required for such a contribution, and the amounts actually paid36. Contributions payable by employers, workers, and the Treasury should be reported separately, according to the relevant legal category and its applicable conditions, and distinguished from assistance provided under the protocol37. Expenditure by the Fund should not, in itself, be treated as evidence that employers have fulfilled their obligations or that the costs of those obligations have been transferred to the state, without accounts establishing this.
Assessing implementation needs requires each entity to determine the cost of the procedures it undertakes, the human resources required for them, and its capacity to receive and process claims, while disclosing the allocations available and the needs for which funding has not been secured. Any additional financial expansion should be based on an assessment linking the number of beneficiaries and the value of benefits to sustainable funding resources. A legal basis and an impact assessment are also required before introducing any mandatory subscription or fee, as the Fund’s resources stipulated in Article 82 of the Labour Law do not extend to new fees outside their scope38.
The proposed monitoring measures should include the Ministry of Labour publishing a consolidated quarterly report on the participating entities’ implementation of the protocol, with personal data protected and pending claims reported alongside those resolved. The report should be made available to worker representatives to discuss its findings, correct any demonstrated inaccuracies, and identify the entity responsible for addressing recurring delays or disruptions, together with the scheduled date for follow-up. The report should be limited to monitoring implementation of the protocol by its parties, without prejudice to the continued enforcement of workers’ statutory rights outside it, or to any more favourable benefits established for each worker under the law or their contract.
Implementation and Monitoring Indicators
The paper recommends that the Ministry of Labour coordinate implementation of the plan among the relevant entities, with a designated contact person at the Fund, the National Organization of Social Insurance, and each participating healthcare entity. The coordination structure should include authorized representatives of Talabat and the intermediary delivery companies, independent worker representatives, and a representative of the entity responsible for disbursing benefits during the transitional period. Each entity should retain its statutory powers over decision-making, disbursement, and collection. The Ministry should, however, follow up on the referral of workers’ applications or claims to the competent authorities, verify that they have been received, and ensure that applicants are informed of their status. This coordination should not create a new mandatory claims procedure or confer additional authority on any entity to adjudicate disputes39. The legally established dispute procedures should also be preserved, including the request for examination of an insurance dispute under Article 148, without presuming that coordination suspends legal deadlines40.
To order the implementation steps, it is suggested that a timetable be adopted starting from the date of the plan’s adoption, with the proposed periods treated as implementation objectives rather than deadlines announced by the government entities. The first month should be devoted to publishing the documents, designating the responsible officials, initiating consultation, assessing resources, and identifying the entities responsible for receiving applications and disbursing benefits during the transitional phase. During the first three months, the examination of employment relationships and insurance registration and the remittance of contributions should begin, and the procedures for correcting data and initial referral should be activated.
The proposed monitoring of implementation relies on indicators that clarify what each indicator measures, the category it covers, and the entity responsible for providing its data. The measurement of the protection coverage rate should be based on the number of actual beneficiaries, not merely the number of registered persons. The periods that applications have taken since their submission should also be presented, along with the status of completion of their documents, the reasons for their suspension, and the outcomes of their determination, so that the average disbursement time does not conceal old applications that remain pending.
The first monitoring report should describe the situation at the start of implementation, including the services available, actual registration, and pending claims, to establish a baseline against which subsequent results can be assessed. Where some baseline data cannot be documented, this limitation should be disclosed, without attributing all subsequent services or improvements to the protocol. The resource review should also assess staff capacity to process applications and identify training needs in digital recordkeeping, thereby linking the expansion of procedures to the actual capacity to implement and monitor them.
On the benefits access side, the proposed indicators include the time required to determine applications and disburse entitlements, the number of pending applications, and the outcomes of correcting registration data. These indicators are derived from the records of the labour directorates and the disbursing entity, and from the Fund’s records according to the stage of implementation.
Among the proposed indicators for the enforcement of labour and insurance rights is the comparison of the entitlements that have been collected, and the registrations and insurance periods that have been corrected, with the rights whose entitlement has been established in the examined files. The Ministry of Labour and its directorates and the National Organization for Social Insurance shall provide the necessary data, each within the limits of its competence.
For healthcare protection, the proposed indicators should be limited to services and benefits demonstrably covered by the protocol. They should measure the time required to decide on applications, disburse benefits, and initiate and continue treatment where covered by the agreement, as well as compensated days of work incapacity where included among its benefits. These results should be reported separately from treatment entitlements and wage compensation provided under social insurance and other laws, with the data source and responsible entity identified for each indicator. Workers’ accounts should also be used to verify whether the benefits have actually reached them.
The proposed monitoring framework should also track whether workers remain eligible for benefits under the protocol when they move between intermediary companies or their status in the registration lists changes. The methodology for collecting workers’ accounts and its limitations should be made public, and findings from limited samples should not be generalized. Worker representatives should also be able to raise issues that may not appear in official records, such as refusal to accept applications, inability to obtain proof of registration, or difficulty accessing the records needed to substantiate a claim. The impact of workers participation should be measured by the number of complaints concerning registration, eligibility, and disbursement, the proportion addressed, and the outcomes of the measures taken. This requires protecting workers’ identities when reporting findings and specifying access permissions and retention periods for workers’ accounts in accordance with their purpose and the applicable legal rules, so as to monitor the obstacles that precede the formal registration of a complaint.
Among the implementation risks requiring special measures are the transformation of coordination into repeated referrals between entities, the limitation of companies’ obligations to submitting worker lists without correcting their status, or unjustified expansion in the sharing of personal data. To address these risks, the paper proposes documenting receipt of claims and identifying the entity responsible for following them up, measuring benefits actually disbursed and corrections actually implemented, and restricting access to data to what is necessary. Where a dispute arises over the status of the employer, benefits that workers have been determined to be eligible for through other channels should continue to be provided, subject to the applicable conditions. As for the shortage of resources, its impact on implementation and the plan to address it must be disclosed, without using it as a justification for dropping legal obligations or concealing delayed applications.
Fifth: Conclusion
The protocol announced on 5 November 2026 provides a pathway for extending social and healthcare benefits to delivery workers whose details are submitted by companies contracted with Talabat as an established protection for irregular labour. However, the impact of this pathway depends on details that remain unclear in the published information, including the value of each benefit and the conditions for accessing it, the procedures for correcting worker lists, and the entity responsible for receiving applications, deciding on them, and disbursing entitlements while the Fund’s operational arrangements are being completed. Publishing the full text of the protocol and its annexes is important not merely for procedural transparency, but also for identifying the actual obligations of its parties and distinguishing between what has been announced and what has become enforceable and actionable.
The examination of employment relationships reveals that benefiting from a Fund grant does not, in itself, determine the worker’s labour or insurance status. Determining the employer, the contributions, and the rights arising from an injury or period of work incapacity depends on the actual circumstances and the applicable laws, including how operational and data-related functions are distributed between the platform and intermediary companies. The extent of protection therefore depends on the ability of the competent authorities to examine these relationships and enforce existing obligations alongside the disbursement of benefits in accordance with the applicable rules. Assessing the cost of intervention also requires disclosing the resources allocated to benefits and the contributions made by the parties, without presuming that companies’ obligations have been transferred to the Fund or that companies have been relieved of those obligations before verification.
This approach translates into specific responsibilities for implementation and monitoring. The Ministry of Labour is responsible for making the relevant documents available and establishing clear procedures for registration, data correction, and complaints. The Fund and the competent authorities should clarify the eligibility, financing, and disbursement rules during the transitional period and thereafter, while the parties involved in the operation should provide the records necessary for review and correction. The participation of independent worker representatives would enable the procedures to be assessed against workers’ actual experiences, alongside periodic reports showing the number of eligible workers and beneficiaries, cases of exclusion and rejection, the time required to decide on applications and disburse benefits, and the labour and social insurance corrections implemented. The protocol’s success should ultimately be measured by the protection workers have actually received, which can be substantiated and sustained, while ensuring that their other statutory rights remain enforceable.
References
1 Prime Minister Witnesses the Signing of a Cooperation Protocol to formalize the Status of Delivery Workers and Provide Them with Social Protection, State Information Service, 5 November 2026, https://sis.gov.eg/ar/المركز-الإعلامي/الأخبار/رئيس-الوزراء-يشهد-توقيع-بروتوكول-تعاون-لتوفيق-أوضاع-عمال
2 Ibid
3 Law No. 14 of 2025 Promulgating the Labour Law (Article 80 concerning the Emergency Aid and Social and Health Services Fund for Irregular Labour, President of the Republic, Official Gazette, Issue No. 18 (cont.) , 3 May 2025, copy hosted by the Egyptian Tax Authority, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf
4 Prime Ministerial Decree No. 2403 of 2026 Concerning the Emergency Aid and Social and Health Services Fund for Irregular Labour, Prime Minister, Official Gazette, Issue No. 31 bis (C), copy hosted on Marjaak Alqanuni, 5 August 2026, https://hazemmousa852-dot.github.io/marjaak-alqanuni/decisions/
5 “Continuing to Provide Support and Protection for Irregular Workers and Expand Their Database.. In Implementation of President El-Sisi’s Directives, Minister of Labour Chairs Meeting of the Board of Directors of the Emergency Aid and Social and Health Services Fund for Irregular Labour,” Ministry of Labour, 2 November 2026, https://www.labour.gov.eg/ar/
6 Prime Minister witnesses the signing of cooperation protocol to formalize the status of delivery workers and provide them with access to social protection services, State Information Service, 5 November 2026, https://sis.gov.eg/ar/المركز–الإعلامي/الأخبار/رئيس–الوزراء–يشهد–توقيع–بروتوكول–تعاون–لتوفيق–أوضاع–عمال–الدليفري–وتوفير–الحماية–الاجتماعية–لهم/
7 Prime Ministerial Decree No. 2403 of 2026 Concerning the Emergency Aid and Social and Health Services Fund for Irregular Labour, Prime Minister, Official Gazette, Issue No. 31 bis (C), copy hosted on Marjaak Alqanuni, 5 August 2026. https://hazemmousa852-dot.github.io/marjaak–alqanuni/decisions/قرار رئيس مجلس الوزراء رقم ٢٤٠٣ لسنة ٢٠٢٦ بشأن صندوق إعانات الطوارئ والخدمات الاجتماعية والصحية للعمالة غير المنتظمة.pdf
8 ibid
9 Law No. 14 of 2025 Promulgating the Labour Law (Articles 1 and 75), President of the Republic, Official Gazette, Issue No. 18 (cont.), copy hosted by the Egyptian Tax Authority, 3 May 2025, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf
10 Social Insurance and Pensions Law No. 148 of 2019 (Articles 2, 19, 45, and 70–73), President of the Republic, Official Gazette, Issue No. 33 bis (A), copy hosted by the National Social Insurance Authority, 19 August 2019, https://www.nosi.gov.eg/ar/Lists/NOSILibrary/2-12-2019 كتاب القانون الجديد.pdf
11 Law No. 2 of 2018 Promulgating the Universal Health Insurance System, President of the Republic, Official Gazette, Issue No. 2 (cont.) (B), copy hosted by the Universal Health Insurance Authority (UHIA), 11 January 2018, https://uhia.gov.eg/wp-content/uploads/2024/02/قانون2-لسنة-2018.pdf
12 Social Insurance and Pensions Law No. 148 of 2019 (Wage Compensation, Article 49), President of the Republic, Official Gazette, Issue No. 33 bis (A), copy hosted by the National Social Insurance Authority, 19 August 2019, [https://www.nosi.gov.eg/ar/Lists/NOSILibrary/2-12-2019 كتاب القانون الجديد.pdf](https://www.nosi.gov.eg/ar/Lists/NOSILibrary/2-12-2019 كتاب القانون الجديد.pdf)
13 Law No. 14 of 2025 Promulgating the Labour Law (Article 253), President of the Republic, Official Gazette, Issue No. 18 (cont.), copy hosted by the Egyptian Tax Authority, 3 May 2025, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf
14 Restaurants Terms & Conditions (Egypt), Delivery Hero Egypt S.A.E., Talabat, undated (accessed 7 November 2026), https://www.talabat.com/page/vendor/terms/restaurants/egypt
15 Law No. 14 of 2025 Promulgating the Labour Law (Articles 10, 40, 41, 45, and 94), President of the Republic, Official Gazette, Issue No. 18 (cont.), copy hosted by the Egyptian Tax Authority, 3 May 2025, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf
16 Riders Privacy Policy, Delivery Hero Egypt S.A.E., Talabat, undated (accessed 7 November 2026), https://terms.talabat.com/eg/
17 Law No. 213 of 2017 Promulgating the law on Labor Trade Union Organizations and the Protection of the Right to Organize (Articles 2, 10, and 11), President of the Republic, Official Gazette, Issue No. 50 bis (B), copy hosted by Manshurat Legal Publications, 17 December 2017, https://manshurat.org/file/33330/download?token=zHm79Um8
18 Law No. 14 of 2025 Promulgating the Labour Law (Articles 194–203), President of the Republic, Official Gazette, Issue No. 18 (cont.), copy hosted by the Egyptian Tax Authority, 3 May 2025, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf
19 Law No. 14 of 2025 Promulgating the Labour Law (Article 80), President of the Republic, Official Gazette, Issue No. 18 (cont.), copy hosted by the Egyptian Tax Authority, 3 May 2025, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf
20 Constitution of the Arab Republic of Egypt, as amended in 2019 (Article 68), House of Representatives, General Secretariat (preparation of the text), Presidency of the Arab Republic of Egypt, April 2019, https://www.presidency.eg/media/46122/دستور–جمهورية–مصر–العربية-2019.pdf
21 Law No. 14 of 2025 Promulgating the Labour Law (Articles 150 and 165), President of the Republic, Official Gazette, Issue No. 18 (cont.), copy hosted by the Egyptian Tax Authority, 3 May 2025, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf
22 Law No. 213 of 2017 Promulgating the Trade Union Organisations and Protection of the Right to organize, President of the Republic, Official Gazette, Issue No. 50 bis (B), copy hosted by Legal Publications, 17 December 2017, https://manshurat.org/file/33330/download?token=zHm79Um8
23 Prime Minister’s Decree No. 2403 of 2026 Concerning the Emergency Aid and Social and Health Services Fund for Irregular Labour, Prime Minister, Official Gazette, Issue No. 31 bis (C), copy hosted on Marjaak Alqanuni/ (Your Legal Reference), 5 August 2026, https://hazemmousa852-
24 Law No. 14 of 2025 Promulgating the Labour Law, President of the Republic, Official Gazette, Issue No. 18 (cont.), copy hosted by the Egyptian Tax Authority, 3 May 2025, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf
25 Law No. 14 of 2025 Promulgating the Labour Law (Articles 113–115 and 117–125), President of the Republic, Official Gazette, Issue No. 18 (cont.), copy hosted by the Egyptian Tax Authority, 3 May 2025, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf
26 Law No. 14 of 2025 Promulgating the Labour Law (Articles 10 and 94), President of the Republic, Official Gazette, Issue No. 18 (cont.), copy hosted by the Egyptian Tax Authority, 3 May 2025, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf
27 Decree No. 816 of 2025 Promulgating the Executive Regulations of the Personal Data Protection Law, Minister of Communications and Information Technology, Masaar, 1 November 2025, https://masaar.net/ar/egypt_laws/اللائحة–التنفيذية–لقانون–حماية–البي/
28 Law No. 151 of 2020 Promulgating the Personal Data Protection Law, President of the Republic, Official Gazette, Issue No. 28 bis (E), copy hosted by Legal Publications, 15 July 2020, https://manshurat.org/file/78585/download?token=1EvFEHyy
29 Social Insurance and Pensions Law No. 148 of 2019, President of the Republic, Official Gazette, Issue No. 33 bis (A), copy hosted by the National Organization Social Insurance, 19 August 2019, https://www.nosi.gov.eg/ar/Lists/NOSILibrary/2-12-2019 كتاب القانون الجديد.pdf.
30 Law No. 2 of 2018 Promulgating the Universal Health Insurance System Law, President of the Republic, Official Gazette, Issue No. 2 (cont.) (B), copy hosted by the Universal Health Insurance Authority, 11 January 2018, https://uhia.gov.eg/wp-content/uploads/2024/02/قانون2-لسنة-2018.pdf.
31 Frequently Asked Questions, Universal Health Insurance Authority, undated, (accessed 7 November 2026), https://uhia.gov.eg/الأسئلة–الشائعة/.
32 Prime Ministerial Decree No. 2403 of 2026 on the Emergency Aid and Social and Health Services Fund for Irregular Labour, Prime Minister, Official Gazette, Issue No. 31 bis (C), copy hosted by Marjaak Alqanuni(your Legal Guide), 5 August 2026, https://hazemmousa852-dot.github.io/marjaak-alqanuni
33 Law No. 2 of 2018 Promulgating the Universal Health Insurance System Law (Article 48), President of the Republic, Official Gazette, Issue No. 2 (cont.) (B), copy hosted by the Universal Health Insurance Authority, 11 January 2018, https://uhia.gov.eg/wp-content/uploads/2024/02/قانون2-لسنة-2018.pdf.
34 Notifying the Social Insurance Authority of the Work Injury and providing the necessary documents, National Organization of Social Insurance, undated (accessed 7 November 2026), https://www.nosi.gov.eg/ar/Services/Pages/Info/إخطار–الصندوق–بإصابة–العمل–وموافاته–بالمستندات–اللازمة.aspx.
35 Fawry Partners with talabat to Provide Medical Coverage for Delivery Riders Through “Sehetak Fawry” Product، Ahmed Zekry, Fawry 5 January 2026, https://www.fawry.com/2026/01/05/fawry-partners-with-talabat-to-provide-medical-coverage-for-delivery-riders-through-sehetak-fawry-product/
36 Prime Ministerial Decree No. 2403 of 2026 on the Emergency Aid and Social and Health Services Fund for Irregular Labour, Prime Minister, Official Gazette, Issue No. 31 bis (C), copy hosted by Marjaak Alqanuni, 5 August 2026, https://hazemmousa852-dot.github.io/marjaak-alqanuni/decisions/
37 Social Insurance and Pensions Law No. 148 of 2019, President of the Republic, Official Gazette, Issue No. 33 bis (A), copy hosted by the National Organization of Social Insurance, 19 August 2019, https://www.nosi.gov.eg/ar/Lists/NOSILibrary/2-12-2019 كتاب القانون الجديد.pdf.
38 Law No. 14 of 2025 Promulgating the Labour Law (Article 82), President of the Republic, Official Gazette, Issue No. 18 (cont.), copy hosted by the Egyptian Tax Authority, 3 May 2025, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf.
39 Law No. 14 of 2025 Promulgating the Labour Law (Articles 149 and 150), President of the Republic, Official Gazette, Issue No. 18 (cont.), copy hosted by the Egyptian Tax Authority, 3 May 2025, https://portal.eta.gov.eg/sites/default/files/2026-03/law.no_.14.of_.2025.pdf.
40 Social Insurance and Pensions Law No. 148 of 2019 (Article 148), President of the Republic, Official Gazette, Issue No. 33 bis (A), copy hosted by the National Organization of Social Insurance, 19 August 2019, https://www.nosi.gov.eg/ar/Lists/NOSILibrary/2-12-2019 كتاب القانون الجديد.pdf.