Does Syria's Investment Law cover me? Eligibility, sectors, and exclusions

Two constraints that come before every rule below

Before a single sentence about eligibility or sectors, the edition being read has to be named. The copy of Investment Law No. 18 of 2021 and its executive instructions that we hold is published on the Homs investment portal, not in the Official Gazette, and we do not know when that published copy was last updated.

The second constraint weighs more. Law 18 has been amended at least twice — by Law No. 2 of 2023 and by Decree No. 114 of 2025 — and we have read neither amendment. Our copy of Decree 114 is thirteen scanned pages with no extractable text at all, and Law 2 of 2023 is not in our files in any form. So every rule on this page carries the same wording: this is the rule as it appears in the 2021 text, and that text has been amended twice which we have not seen. In practice this means every article number, every sector list, and every exclusion below may since have changed.

Who counts as an "investor" in the text

Article 1 of the law defines the investor as "the natural or legal person, Syrian or non-Syrian, who invests in the territory of the Syrian Arab Republic in accordance with the provisions of this law."

Three things follow from that single sentence:

• The definition itself imposes no nationality condition. Syrian and non-Syrian are both named in the wording.
• A legal person is inside the definition alongside a natural person — the company, not only the individual founder, can be the investor as the text uses the word.
• A definition defines; it does not grant. The clause "in accordance with the provisions of this law" hands actual eligibility back to the rest of the text: scope, exclusions, sector, and the financial threshold.

"Fairness in treatment" is not "national treatment"

This is where a legal adviser stops first. Article 4/c of the law states the principle of "fairness in granting investment opportunities, and in treatment." That is the closest phrase in the text we read to a principle of equality among investors.

Investment treaties, however, use a specific term for the commitment to treat a foreign investor the same as a domestic one: national treatment. That term does not appear in the text we read. The distance between a general principle listed among guiding principles and an obligation carrying its recognised technical name is a material one, and we present it exactly as found: a stated fairness principle, and a term we did not find.

The three categories the instructions name

Article 2 of the executive instructions lists who benefits from the law's provisions:

• The Syrian and non-Syrian investor investing on their own property or on the state's private property.
• Joint companies, whether established before the law came into force or after it.
• Projects on the private property of public entities, by way of investment rather than lease.

On that last point, Article 3/b of the law states that a project arising from public entities offering their private property for investment with the private sector falls within the law's scope and is not subject to the partnership law. The partnership law is itself one of the referenced texts we do not hold, so what we can report is the carve-out, not the content of the statute carved out.

The "new economic entity" condition

Article 1 also defines investment as "investment expenditure on creating a new economic entity in one of the economic sectors." The word "new" is not filler: it ties eligibility to bringing an entity into existence rather than to spending in the market generally.

What we cannot give the reader is the precise boundary of that word. The texts we read refer the classification of projects and of activities within each sector to a separate document — the procedures guide — which we have not seen. So a reader asking whether a particular situation amounts to "creating a new economic entity" should know that the answer sits in that guide and in the amending texts, not in the pages we hold.

Two neighbouring situations, by contrast, the text addresses plainly:

• Article 39 states that where project ownership is transferred in whole or in part, the new investor takes the place of the previous one in rights and obligations.
• Article 40/a and Article 50 state that projects existing under Decree 8 of 2007, Law 10 of 1991, and decisions of the Supreme Tourism Council continue with their advantages and on the conditions stated therein.

Sectors: ten in the instructions, seventeen on the form

Article 4/a of the instructions lists ten economic sectors. The official feasibility-study form that an investor fills in offers seventeen options in its first section. This is a live divergence between two official documents; we set both out and take no side.

The reason for the divergence is not known to us. It may be an expansion introduced by Decree 114 of 2025, which we have not read, or an operational classification inside the form rather than a change in the law. Settling between the two requires a text we do not hold; this is a reporting note, not an interpretation.

Article 4/b of the instructions adds that activities within each sector are determined by the procedures guides, together with the minimum value of fixed assets approved by the Council — meaning the sector heading alone does not establish whether a given activity is covered.

Three express exclusions

Each of these three removes an entire category from the law's scope:

The first exclusion is broad in its drafting: it does not stop at banks but reaches every financial institution that accepts deposits. The second turns on exclusivity to the state rather than on the sector as such. The third excludes land as land, irrespective of the activity proposed on it.

Here we stop at the edge of what we know. "First, second, and third stability zones" is a Syrian agricultural term whose definition we did not find in any file we read, and we will not explain it to a reader before obtaining its source. What we can report is that the criterion exists in the text and that its definition lives outside it.

A financial threshold that exists in the text without a number

Article 7/g of the law states that the Supreme Investment Council sets the minimum value of fixed assets or of capital for each special economic zone or each sector. Article 4/b of the instructions repeats the same referral.

So the entry threshold is present as a rule and absent as a figure: the text confirms it exists and refers its determination to a decision, and that decision is not among the documents we have seen. We give no number here — neither for the threshold nor for fees — because a figure stated without a source that has been read is invention rather than reporting.

What the text does not say — and where the answer sits

This section is part of the article, not a footnote to it. Four questions every foreign investor asks, and four answers we do not hold:

Where the reading lands

What the 2021 text conveys clearly: a definition of investor that imposes no nationality condition; three categories named in the instructions; a condition of creating a new economic entity; ten sectors in the instructions against seventeen options on the official form; three express exclusions; and a financial threshold established as a rule with no published figure in our hands.

What it does not convey: that figure, a negative list, the position on full foreign ownership, and the definition of the stability zones — and, before all of those, whatever the two unread amendments did to everything above.

This article sets out what the text we read states, article by article; it is not legal advice. The rules presented here appear in the 2021 text, and that text has been amended twice which we have not seen.