Privacy Rights in the Fintech Era: Examining the Egyptian Legal Framework and its Implementation Hurdles

Introduction

The term Fintech (Financial Technology) refers to the use of digital tools and applications to provide various financial services. Banking services are at the forefront of these services, which traditional banks have been offering through applications for many years.

The growing capabilities of digital technology, along with its reach across large segments of society following the emergence of smartphones, have driven the development of digital financial services beyond traditional banking, making them increasingly independent of banks. Today, thousands of companies—ranging in size—provide multiple financial services, some locally and others crossing national boundaries.

Egypt’s fintech sector has witnessed remarkable transformations in recent years, making it one of Africa’s most dynamic and fastest-growing fintech sectors. The number of startups operating in this sector has surged more than fivefold in just five years, reaching 177 startups by 2025. This makes Egypt a key player in the regional fintech landscape.

Masaar has previously published an introductory paper on fintech, discussing the general human rights challenges surrounding fintech implementation practices. The current paper aims to examine fintech specifically within the Egyptian context.

This paper provides an overview of Egypt’s fintech sector, examining its recent evolution, prevailing trends, and future growth prospects, alongside the obstacles and challenges impeding this growth. The paper also discusses concerns about privacy violations stemming from legislative shortcomings, the imposition of digital identity and biometric measures, along with fears related to security interventions, mass surveillance, and the social issues associated with financial inclusion.

The paper also examines women from low-income backgrounds and the challenges of including them in the technology-based financial system. Finally, it explores the potential for Egypt’s fintech sector to evolve in ways that respect human rights and promote justice. The paper examines the possibilities for legislative and regulatory reform, developing more inclusive financial tools, and integrating gender-sensitive approaches in designing financial tools and solutions.


The Fintech Sector in Egypt

Development of the Sector in Recent Years

Fintech in Egypt had humble beginnings, virtually nonexistent about a decade ago. In 2014, only two startups operated in the sector within an environment dominated by traditional financial institutions. This slow start of fintech services in Egypt reflected the broader challenges of the Egyptian financial system in general.

Foremost among these challenges was low ‘bank penetration’ – referring to the prevalence of banking services across different societal groups. Egypt’s banking sector primarily served higher-income segments, leaving a significant portion of the population excluded from financial services. Furthermore, this period’s legal and regulatory frameworks proved inadequate for addressing technology-driven financial services. This created an environment of distrust among investors and entrepreneurs considering entry into this emerging market.

The years 2017-2018 marked the beginning of a major transformation period for Egypt’s fintech sector. This coincided with a growing recognition by Egyptian executive and legislative authorities of fintech’s importance and its potential to address financial inclusion challenges. This emerging awareness stemmed from global fintech trends that demonstrated how technological solutions could bridge persistent gaps in traditional banking systems.

In March 2019, the Central Bank of Egypt launched its ‘FinTech and Innovation Strategy.‘ This strategy presented an ambitious vision to establish Egypt as a digital technology hub for both the Arab world and the African continent, and a destination for next-generation financial services, talent, and innovative development.

The strategy positioned digital technology as a cornerstone of Egypt’s Vision for 2030. It also introduced a structural approach to fostering a conducive fintech ecosystem, addressing key elements including regulatory frameworks, access to finance, market governance, and the promotion of talent and innovation.

Egypt’s digital technology sector experienced accelerated growth following the implementation of this strategy. The number of startups operating in digital technology services or technology-supported services grew to reach 112 companies by 2021. This growth trajectory continued unabated, expanding the sector to 177 startups by the beginning of 2025, achieving a growth rate of 5.5 times over five years.

This significant growth placed Egypt among the top four African countries in terms of concentration of digital technology startups. The growth encompassed various fields of digital technology services, including digital payment services, lending platforms, wealth management, insurance technology, and financial infrastructure. Digital payment services, in particular, emerged during this period along with a growing usage of mobile-connected e-wallet services, with the number of mobile wallet users increasing from 10 million in 2018 to 30 million in 2022.

Egypt’s fintech sector currently holds a prominent position both regionally and globally. As of early 2025, Egypt ranks tenth worldwide among emerging markets in fintech development. The sector has achieved a growth rate of 12%, surpassing many comparable economies.

Egypt’s fintech sector demonstrates core strengths in payment systems, digital lending, and financial inclusion solutions. The country now ranks second in the Middle East and North Africa (MENA) region in terms of digital technology funding deals, reflecting the strong investors’ confidence in the sector’s future potential.

In Egypt’s current digital technology landscape, innovative fintech startups offering new financial tools and solutions are now competing with major established financial institutions that are increasingly relying on digital solutions in their operations. Local companies operating in the sector have demonstrated a high level of innovation by developing solutions specifically tailored to the local market, taking into account its conditions and consumer preferences. So far, these innovations have effectively addressed the challenges of financial inclusion by circumventing traditional barriers to accessing financial services.

One of the greatest achievements of Egypt’s fintech sector is its contribution to boosting the financial inclusion rate, which has risen by 70.7%. This progress has been reflected in the growing adoption of prepaid cards and increased trust in financial services. This expansion has attracted millions of Egyptians who had never previously engaged with the banking system, allowing them to be integrated into the formal financial system and enabling them to save, transfer, borrow, and invest money through digital channels.

Digital savings plans have also had a particularly notable impact, not only by offering returns on savings but also by enabling consumers to build a financial history that paves the way for access to a broader range of financial services. For many Egyptians, these platforms represent their first formal interaction with the financial system, laying the foundation for greater financial participation.

Barriers and Challenges to Growth

Despite the significant progress of the fintech sector in Egypt, several challenges continue to hinder its expansion and growth. Cultural factors and awareness gaps pose major obstacles to adopting fintech among many Egyptians. For the majority, fintech concepts remain unfamiliar, leading them to prefer traditional methods of financial transactions, whether through cash or conventional bank accounts.

This preference is often reflected in the differing attitudes across age groups, with older individuals in particular showing reluctance to replace cash transactions with digital alternatives. The tangible nature of physical money provides a deep-rooted sense of security for those accustomed to it, whereas digital transactions—being intangible—are often met with a sense of mistrust and discomfort.

Like other technology-driven sectors, Egypt’s fintech industry faces the persistent digital divide between different segments of Egypt’s population, manifested in income disparities, urban-rural gaps, and uneven access between major cities and regional areas.

In spite of Egypt’s remarkable smartphone adoption, achieving a significant penetration growth rate in recent years, the gap in digital technology usage capabilities depends on several other factors. These include average income, education, and skill levels, prevailing social and cultural attitudes, and gender disparities.

For example, the availability of a smartphone to an individual does not necessarily mean they can access financial services through it if they are illiterate. Therefore, the continued literacy rate in Egypt, along with gender disparities, is a significant factor in the potential for adopting fintech. Moreover, even among educated groups, there are varying levels of digital literacy that affect individuals’ ability and confidence in using various digital services, particularly financial services.

The regulatory environment also represents a significant challenge for the fintech sector in Egypt. The complexity of this environment poses a challenge for startups operating in the sector, especially in their early stages. Despite the efforts made by both the Central Bank and the Financial Supervisory Authority to support these companies, the constant changes in regulations and administrative decisions create an atmosphere of uncertainty. This undermines market confidence and complicates the preparation of feasibility studies needed to secure financing.

Moreover, traditional regulations designed for large financial institutions often impose disproportionate burdens on fintech startups, which operate with innovative business models. Companies offering solutions that combine multiple economic sectors face additional challenges, struggling to adapt to the different regulations governing each sector. This multiplicity of regulations forces companies to comply with a range of conflicting rules, making it potentially impossible to adhere to all of them simultaneously.


Fintech Sector and Rights-Based Safeguards

Legislative Shortcomings

Protecting the right to privacy, especially personal data, is a cornerstone for the continuity and growth of the fintech sector. The tools and applications within this technology deal with some of the most sensitive data, and any failure to adequately protect this information could lead to significant risks and severe harm to individuals or institutions. Therefore, the fintech industry cannot thrive without comprehensive safeguards to protect the personal data of users of its tools and applications. These safeguards fundamentally depend on the existence of a legislative and regulatory framework for data protection.

Issuing the Personal Data Protection Law in 2020 was a key step in establishing a data protection framework in Egypt. This legislation consists of 49 articles divided into 14 chapters, and it generally aligns with international standard practices, particularly those represented by the European General Data Protection Regulation (GDPR).

The law prohibits the processing of personal data without the explicit consent of the data subject. It also grants individuals important rights, such as restricting access to their data, the right to withdraw consent for data processing, and the right to be notified in the event of a data breach. The law generally defines personal data as information related to an identified or identifiable natural person. Additionally, the law classifies specific types of information, such as health, financial, religious data, and data concerning children, as sensitive data, subjecting them to greater protection.

Previous papers from Masaar have discussed the Personal Data Protection Law and the obstacles to its implementation, most notably the fact that the executive regulations have not been issued until today, almost five years after its promulgation. In the context of fintech, the law has a very serious shortcoming related to the existence of important exemptions from its provisions. These exemptions include, in particular, entities directly under the supervision of the Central Bank of Egypt (Article 3 of the promulgation law, paragraph 6).

This creates a significant regulatory gap for many financial service providers. It may also lead to insufficient safeguards for the protection of sensitive personal data of consumers when they interact with traditional banking institutions or entities regulated by the Central Bank of Egypt. At a minimum, this exemption means that different entities offering similar services are subject to different standards for protecting customer data due to their classification under different supervisory bodies. This results in a lack of consistency in privacy protection across the fintech sector.

On the other hand, the interplay of several pieces of legislation that govern transactions in the fintech sector creates a complex regulatory environment. These include:

  • Personal Data Protection Law, No. 151 of 2020
  • Central Bank and Banking System Law, No. 194 of 2020
  • Law Regulating and Developing the Use of Financial Technology in Non-Banking Financial Activities, No. 5 of 2022

This complexity in the regulatory environment is further exacerbated by the rapid development of fintech, which can sometimes outpace regulatory frameworks. This creates periods during which fintech innovations operate in a legal gray area concerning data protection guarantees and standards.

Enforcing Digital Identity and Biometric Measurements

In July 2023, the Financial Supervisory Authority in Egypt issued three pivotal decisions to implement the Law Regulating the Use of Financial Technology. This law governs the use of technology in non-banking financial activities. Resolution No. 140 regulates digital identity and digital contracts. It outlines the procedures for digital identification and authentication, mandating identity authentication using biometrics during transactions with the services of non-bank financial institutions that use fintech solutions.

This process requires individuals to undergo multi-step verification, combining information-based authentication, possession-based authentication, and biometric data, which includes both facial recognition and fingerprint scanning. While strong identity verification procedures align with global trends, the use of biometric data raises concerns about privacy and data security, as well as the appropriateness of such highly intrusive methods for accessing basic financial services.

The mandatory collection of biometric data to access financial services raises significant concerns regarding the right to privacy. Biometric information is highly sensitive and differs fundamentally from passwords or PINs, as biometric data cannot be altered if it is breached.

Additionally, creating large databases containing biometric information of citizens presents an attractive target for cyberattacks. It also raises questions about data retention policies, access control procedures, and the potential for data misuse—where data may be collected for legitimate purposes but later exploited for different, unauthorized purposes.

Resolutions promulgated in this regard lack the necessary details clarifying how data protection considerations should be handled, such as the principle of data minimization, and the transparency requirements regarding the collection, storage, and processing of biometric data.

Security Intervention and Surveillance

Perhaps the most concerning development regarding digital rights, in general, is the passing of amendments to the Criminal Procedures Law by the Egyptian Parliament last January. Some of these amendments directly affect digital rights, most notably the right to privacy, and are necessarily an impediment to all forms of digital technology use. Fintech is among the most sensitive sectors to privacy concerns and risks related to the protection of privacy as well as due legal process guarantees. Among the most disturbing amendments in the law is Article No. 79, which allows prosecutors, with judicial authorization, to issue an order monitoring communications, including social media accounts and personal content.

One of the key obstacles preventing many citizens from using fintech services—or even traditional banking services—is the increased exposure of their financial transactions to security interventions, whether within or outside the legal framework. These interventions may include the suspension of activity on bank accounts or mobile-linked digital wallets without prior notice or any explanation provided to the user. The widespread nature of such actions erodes public trust in the formal financial system as a whole, especially since they often occur without judicial procedures, without avenues for appeal, and can happen randomly or by mistake.

Between Financial Inclusion and Social Inclusion

Financial inclusion undeniably brings significant benefits to the local economy, as it provides additional financial resources necessary for investment and growth. However, true financial inclusion cannot be achieved unless all segments of society are included. This can only be realized if these segments perceive a real and tangible benefit in becoming part of the formal financial system.

Fintech tools have the potential to achieve a great deal in this regard. This has already been realized through tools such as mobile wallet services linked to mobile phone lines, which serve as a model of services that provide direct benefits to wide segments of the population. These tools make it easier and more flexible to transfer money digitally compared to exchanging it in cash form.

In addition to their direct benefit, mobile wallets and payment services such as Fawry have achieved significant success due to the extreme simplicity of their operations, which has helped overcome barriers related to education, technological skills, and more. However, these barriers have not been genuinely overcome in other financial services that could offer a greater degree of financial inclusion—particularly savings, investment, and lending services.

The growth of these services remains limited due to two main factors. The first is the complexity of their processes for the vast majority of the population, and the second is regulatory requirements that are often disproportionate to the nature of small-scale transactions.

A Closer Look at Women from Low-Income Backgrounds

Given the social circumstances in which many women, especially those from poor backgrounds, bear the burden of supporting a large proportion of households, there is considerable potential for providing financial services that include these women in the formal financial system and offer them meaningful benefits they are in urgent need of.

Millions of Egyptian women also suffer from social restrictions imposed on their access to the formal labor market in most economic sectors. As a result, they turn to various forms of informal work, which provides them with low and irregular incomes, with no guarantees or protections.

One of the main obstacles to the existence of financial technology policies specifically tailored to women’s needs in Egypt is the scarcity of available data on women’s access to these technological tools and their behavioral trends in using them.

Currently, the available financial technology tools do not offer services that could attract these women to engage with them effectively beyond mobile phone wallet services, which are limited to transferring funds between individuals. This is largely due to the general obstacles preventing the wider use of financial technology services across large segments of Egyptian society.

These obstacles are exacerbated when it comes to women in general, particularly women from poor socioeconomic backgrounds. This group suffers from the highest literacy rates among society’s categories, as well as the highest poverty rates and the highest levels of (official) unemployment.

This is also reflected in the fact that this group has the least exposure to digital technology compared to other segments, as well as the lowest rate of basic technological skills. All of this makes women from poor socioeconomic backgrounds the least likely to benefit from financial technology services. This situation is further exacerbated by the lack of attention from companies providing financial technology services to offer tools that are tailored to the capabilities of this group and financial solutions that align with their needs.


Potential for Rights-Respecting and Justice-Oriented Development

Legislative and regulatory reform

As with all uses of technology based on data collection and processing, the first and repeated requirement is to activate the Personal Data Protection Law by issuing an executive regulation. The issuance of this regulation would lead to the establishment of a Data Protection Center to fulfill its role in enforcing the provisions of the law.

However, this does not mean overlooking the need for several amendments to the law in its current form to ensure that the protection it provides for personal data is truly effective. For the fintech sector, it is essential to eliminate exemptions for entities directly supervised by the Central Bank of Egypt from being subject to the provisions of the law.

Such an exemption is unjustified and has serious consequences that harm the interests of financial services consumers in Egypt. If there are specific considerations for financial institutions, these can be addressed through special measures outlined in the law, ensuring the protection of citizens’ rights, foremost among them the right to privacy and the protection of personal data, especially sensitive data.

On the other hand, the unnecessary and generalized requirement to collect biometric data to authenticate the identity of users of digital financial services should be reconsidered. There are many electronic means of authenticating people’s identities without the need to store their biometric data, in a way that protects their right to privacy and data protection and does not expose them to risks to their interests and security.

Developing More Inclusive Financial Tools

Achieving true and effective financial inclusion requires social inclusion. What this means is that the financial technology tools offered must gain the trust of Egyptian consumers from different segments and attract them by providing services that align with their needs and are compatible with the prevailing circumstances.

There is no doubt that developing such tools in the context of the fragile economic reality of the vast majority of Egyptian society is a significant challenge. However, overcoming this challenge is possible through innovative solutions that aim to provide real benefits to users.

Developing more inclusive financial tools requires a collaborative effort between the developers of these tools and regulatory and legislative bodies. Regulatory frameworks should adopt a gradual approach, imposing requirements that are proportional to the amounts involved. This will enable companies in the fintech sector to provide simplified tools for small-scale financial transactions, which align with the needs of the vast majority of low-income segments of society.

Such tools should also take into account the irregular income flows of the majority of users from low-income groups. This requires providing tools with acceptable flexibility in payment scheduling. Additionally, financial tools could be developed to help citizens manage relatively high seasonal expenses by spreading these costs over appropriate periods.

Respecting Gender Considerations

The real start lies in the commitment of fintech companies to adopt a clear social responsibility strategy. Through such a strategy, the potential of technology can be harnessed to make a positive impact on improving the lives of the less fortunate, particularly women from poor backgrounds.

There is a great opportunity to innovate low-risk financial solutions that offer investment returns while simultaneously providing women from low-income groups with better opportunities to improve their living conditions and enhance their financial security, especially in the face of health emergencies and other challenges. To ensure the effectiveness of these tools, they must be designed to take into account the irregular nature of these women’s work and ensure that income fluctuations do not pose an obstacle to their use and sustainability.

Developing these tools requires specialized market research to accurately understand the conditions of this group and come up with designs that suit their needs. The tools must be user-friendly and not hindered by factors such as educational level or lack of experience with digital technology.


Conclusion

With the rapid expansion of the fintech sector in Egypt in recent years, it has become necessary to explore ways to overcome the obstacles to its growth, addressing the human rights and social risks associated with it. This paper reviewed the reality of the sector, focusing on the impact of its growth and development on digital and social rights, especially the right to privacy.

The first section of the paper discussed the overall landscape of the fintech sector in Egypt. It examined the stages of its development, its current state in recent years, and its key trends. The section also addressed the challenges and obstacles the sector faces.

In its second section, the paper focused on the human rights and social concerns accompanying the growth and development of the fintech sector in the Egyptian context. It discussed issues related to the right to privacy and the potential for achieving social inclusion alongside financial inclusion. The paper also addressed the specific barriers that prevent women from poorer socioeconomic backgrounds from benefiting from fintech tools and solutions.

Finally, the paper presented several proposals for how the fintech sector in Egypt could develop in a way that respects rights and contributes to enhancing social justice. It discussed the need for legislative and regulatory reform, the development of more inclusive financial tools, and the importance of incorporating gender considerations in the design and deployment of fintech solutions.