Explaining shadow banking

Gamal Wagdy
Tuesday 30 Jun 2026

Healthy financial systems are built on well-regulated commercial banks that provide most household and small-business financing complemented by a properly supervised non-bank sector

 

In April, the Central Bank of Egypt (CBE) issued new directives to tighten the oversight of credit extended by commercial banks to non-banking financial institutions (NBFIs), a move that has sparked a growing debate over the rapid expansion of market-based finance and consumer credit standards in Egypt.

The issue has drawn media attention, especially after the CEO of a leading bank publicly warned about the rapid growth of non-banking financing and what he described as a growing pool of subprime borrowers.

The CBE’s new rules prohibit the commercial banks from granting or renewing credit facilities to non-bank lenders that are not fully coded with the CBE and are not actively reporting customer data to both the CBE’s information network and the Egyptian Credit Bureau (I-Score).

They also require the commercial banks to liquidate debt positions tied to non-compliant NBFIs if they fail to regularise their status within a three-month grace period.

These measures address a clear regulatory gap and improve the quality of credit information available to lenders. However, the broader debate should not be confined to credit-scoring practices or regulatory compliance. The growth of non-bank finance raises wider questions about credit expansion, household indebtedness, aggregate demand, financial stability, and ultimately the role of shadow banking in Egypt’s economic development.

The discussion is particularly relevant because household credit remains relatively modest within Egypt’s banking system. According to CBE data for December 2025, total domestic credit stood at approximately LE16.5 trillion, while credit facilities extended by the banks to households totaled approximately LE1.4 trillion.

The value of non-banking finance portfolios on the same date reached about LE417 billion, as reported by the Financial Regulatory Authority (FRA). This brings the total amount of credit extended by both the banking sector and NBFIs to LE1.8 trillion, representing about 11 per cent of total domestic credit.

The picture looks somewhat different when household credit is compared with lending to the private sector rather than with total domestic credit. This is the approach commonly used in international comparisons because it focuses on financing provided to households and businesses.

From that perspective, household borrowing represents a larger share of overall credit activity in Egypt. As a broad reference point, household credit accounts for roughly 40 to 50 per cent of private-sector credit in many advanced and middle-income economies.

The debate has also revealed confusion among many about NBFIs and shadow banking. While the terms are related, they are not equivalent. Shadow banking refers to private credit intermediation outside the formal banking system, but this does not mean that shadow banks are completely disconnected from the banks. Rather, it means that the institution performing the intermediation is not itself a licensed bank.

NBFIs, on the other hand, are financial entities that offer services such as investment and lending but do not hold a full banking license and cannot accept deposits. In practice, the two sectors are usually closely interconnected.

The key distinction is who performs the intermediation. A commercial bank may lend to an NBFI, which then uses the funds to provide financing to households or businesses. Although the original funding may have come from a bank, the final act of credit intermediation is performed by the non-bank institution.

In this sense, shadow banking is not separate from the banking system but rather exists alongside it, connected through multiple funding and liquidity channels.

This explains why regulators pay close attention to the sector. Regulators care because when banks lend, they do not simply transfer existing money from one borrower to another. New deposits are created in the process, which is why credit growth has consequences that extend far beyond individual borrowers.

Non-bank lenders do not create deposits in the way that banks do, but they can still expand credit and purchasing power. The result is an increase in effective purchasing power within the economy, even if the process differs from traditional money creation.

Consequently, rapid growth in shadow banking can influence spending patterns, asset prices, and financial conditions in ways that resemble the effects of conventional bank lending. For policymakers, the practical question is whether this additional credit is growing at a pace that remains consistent with broader economic stability.

Continued credit expansion can create macroeconomic pressures. If household purchasing power grows faster than the economy’s capacity to expand production, demand could outpace supply, contributing to inflation. The impact varies across sectors. Consumer finance tends to influence retail demand and consumer prices, while housing finance affects real-estate values, rents, and land prices.

Housing credit warrants particular attention because of its distinct economic effects. Unlike productive investment, which increases future output, mortgage expansion often boosts demand for existing assets. When housing supply cannot respond quickly enough, rising credit availability can push property prices higher and encourage speculative activity.

However, this does not mean that consumer credit or housing finance are inherently harmful. Credit plays an essential role in modern economies. The more relevant question is whether credit growth remains consistent with income growth, productive capacity, and financial stability.

Problems arise when credit expands rapidly, lending standards weaken, and borrowers accumulate debt that becomes difficult to service under less favourable economic conditions.

The existence of shadow banking reflects practical realities. The formal banking system is not risk-averse because banks, by their very nature, are risk takers. However, their extension of credit to meet financing needs is subject to strict rules that exclude those who do not meet the requirements.

Non-bank lenders can fill such gaps by serving customers and market segments that the banks are unwilling or unable to reach. The policy challenge, therefore, is not whether shadow banking should exist at all, but rather about how it can be allowed to operate without creating excessive financial vulnerabilities.

Better regulation alone will not solve every problem, but experience in many countries suggests that transparency and effective supervision are the first line of defence against excessive risk-taking. From a supervisory perspective, the label attached to an institution matters less than the risks it creates. When a non-bank lender engages in activities that closely resemble banking, regulators have good reason to pay closer attention.

Equally important is the question of how fast total credit is growing across the economy, regardless of whether it originates from banks or non-bank lenders.

Focusing exclusively on commercial bank balance sheets does not provide a complete picture of financial conditions. Regulators must track total private sector credit, household indebtedness, real estate exposures, and the funding structures of nonbank lenders. Greater transparency and improved data collection are prerequisites for disciplined lending.

A further distinction should be made regarding the purpose of credit. Shadow banking is generally less problematic when it supports productive investment, trade finance, small and medium-sized (SME) business expansion, infrastructure projects, or activities that enhance future productive capacity.

History shows that problems often emerge when credit becomes concentrated in speculative property markets or fuels consumption that is not matched by income growth.

Ultimately, the issue should be evaluated from a macroeconomic perspective rather than through isolated examples. The objective is not to prevent alternative forms of financial intermediation but to ensure that they develop in a disciplined and controlled manner.

The writer is a banking consultant.


* A version of this article appears in print in the 2 July, 2026 edition of Al-Ahram Weekly

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