Where are the calls for a MENA Inc?

Last week at Davos, the European Commission announced a unified corporate structure that lets startups incorporate once and operate across all 27 EU member states, a development they're calling EU Inc (officially the "28th regime," a phrase that sounds more like a Netflix dystopia than regulatory reform, though perhaps that's fitting given Brussels' track record for branding). The promise is straightforwardly; one company, one registration, 450 million customers.

The backstory is worth dwelling on, as perhaps rather unsurprisingly, EU Inc didn't emerge from Brussels bureaucracy but rather from a grassroots campaign that started in October 2024, when four ecosystem figures (Andreas Klinger of Prototype Capital, Simon Schaefer of Factory Berlin, Philipp Herkelmann, and Vojtech Horna of Index Ventures) launched an open letter hoping for 700 signatures and got that number in 20 minutes. Within weeks, 22,000 founders and investors had signed on, including Patrick Collison of Stripe and Paul Graham of Y Combinator, and fifteen months later it's actual policy.

For those of us watching from MENA, the obvious question presents itself: could something similar work here?

The region shares a common language, overlapping consumer behaviours, and the fragmentation EU Inc aims to solve (27 separate company law regimes, duplicated compliance requirements, legal complexity that throttles cross-border expansion) exists regionally too, arguably in more acute form.

But the question itself misses the point, because EU Inc isn't really about corporate structure at all; it's about what that structure unlocks, and that's where the real problem lies.

Incorporating in France under the new regime means the effort to get into France now gives you, more or less, all of Europe. That in essence is the actual value proposition. Not the legal structure itself, elegant as it may be, but the 450 million customers sitting on the other side of it.

Karim Jouini (CEO, Thunders) understands this better than most, having co-founded Expensya in Tunisia, scaled it across both Europe and MENA, and sold it to Swedish firm Medius in 2023. When I asked him whether a MENA Inc would actually matter, his answer cut straight to the heart of the problem.

"We decided to expand to France, and not Algeria," he told me. "Because the effort to get into France means you can, more or less, sell anywhere in Europe. Algeria doesn't give anything more than Algeria.”

It's not that MENA lacks a unified corporate structure (though it doesn't have one of those either), it's that MENA lacks a unified market worth accessing through such a structure in the first place.

Incorporating in Riyadh doesn't give you Casablanca, incorporating in Cairo doesn't give you Dubai, and each market remains its own discrete effort requiring its own regulatory approvals, its own compliance infrastructure, its own local relationships to build and maintain over years.

A MENA Inc, in other words, would be a solution to a problem that isn't actually the binding constraint, which is perhaps why nobody has seriously proposed one.

Jouini breaks the real problem into categories, and while the framework isn't novel, the details are genuinely maddening.

On basic operations (buying, selling, paying taxes), Europe mostly just works these days: VAT collection has been simplified, currency isn't an issue for the eurozone majority, and visas aren't an obstacle. "Truly feels like one market," Jouini says. MENA, by contrast, delivers cross-border restrictions, currency complications, and visa headaches at every turn.

On regulated environments, things get properly absurd. Expensya operates as a legal archiver, which meant Jouini had to get certified in every European country. Fine, you might think, that's the cost of regulated sectors. But in Spain, he had to get certified in each federal region separately, and Germany maintains different rules depending on which region you're in: some say yes, some say no, and some apparently say "maybe," which is not a word you want to encounter in a compliance context. Getting permission to issue German or French IBANs? That took months.

"MENA: same, but worse," Jouini summarises.

His conclusion on EU Inc is measured but pointed: "A step in the right direction, but far from making a meaningful difference if it does not address the above." For MENA, though, he sees the priority differently.

The region isn't a single market, and that's the problem that needs solving first, because a large integrated market is what motivates founders to tolerate the operational headaches. You'll fight through Spanish regional certifications and German regulatory ambiguity if 450 million customers sit on the other side.

For less than $2.50 per week

I also spoke with Tambi Jalouqa, managing partner at Maza Ventures, about what regional fragmentation looks like when you're actually managing a portfolio of companies trying to scale. One of the companies he has invested in operates across Saudi Arabia, Jordan, Egypt, Oman, Qatar, the UAE, and Morocco, which means seven countries, seven subsidiaries, seven licensing regimes, and seven distinct sets of compliance requirements to satisfy simultaneously.

"The founders are killing themselves just to operate in all of these countries," Jalouqa told me. "At the end, they survive, but it could have been much faster. Whereas a Delaware-based company can operate in all US states immediately, with minimum effort."

The costs compound with alarming speed. Each new country runs around $30,000 in setup expenses alone, but that figure excludes the hidden costs that really hurt. In Saudi, if you need regulatory approval from SAMA or the CMA, you'll need a Saudi national in a compliance role, which is another additional cost.

Add office overheads, the management time spent cultivating government relationships rather than building product, and the general overhead of keeping seven separate entities in good standing, and multi-country expansion can easily runs $200,000 to $300,000 before you've acquired a single new customer in those markets.

It's worth noting that MENA isn't alone in facing this problem, and other regions have (kind of) attempted various approaches and solutions with mixed results.

Southeast Asia has the ASEAN Economic Community, launched in 2016 with promises of a "single market," but each country maintains completely different incorporation requirements, minimum capital thresholds, and foreign ownership restrictions. Singapore serves as the de facto Delaware of the region: founders incorporate there and use its network of 25+ free trade agreements to access ASEAN markets, which is functionally the same coping mechanism DIFC and ADGM provide for MENA (all of which use the English Common Law-based system). There's ongoing talk of harmonisation, but it remains a long way off.

Latin America has Mercosur and the Pacific Alliance, both of which have achieved some tariff reduction, but neither offers anything resembling a unified corporate structure. Many LatAm founders do exactly what MENA founders do: flip to Delaware when raising international capital, because international investors understand Delaware and don't want to learn Argentine corporate law.

Africa, interestingly, has the closest thing to what EU Inc is trying to be, and it predates EU Inc by thirty years. OHADA (the Organisation for the Harmonisation of Business Law in Africa) covers 17 francophone countries and has maintained unified corporate law since 1993. The same company forms (SARL, SA, SAS) apply directly across all member states, with a supranational court in Abidjan ensuring uniform interpretation. It's essentially EU Inc avant la lettre.

The catch however is instructive; OHADA works because its members share a colonial legal inheritance (French civil law) and had relatively undeveloped corporate frameworks to begin with, making harmonisation less politically costly. The underlying single market, however, still doesn't exist; intra-African trade remains around 15% of total African trade, compared to 67% in Europe. The corporate structure exists, but the market it unlocks remains fragmented.

What remains under-appreciated about last week's announcement is that EU Inc isn't just a European story about European founders building for European customers, it's in many respects also a competitive threat to MENA, offering founders an exit ramp we'd really rather they not take.

A Tunisian founder building a SaaS product used to face a constrained set of choices. You could incorporate in DIFC and spend $300,000 navigating MENA's fragmentation for a collection of mid-sized markets that don't connect to each other. Or you could flip to Delaware and chase the US market, accepting that you'd be a small fish in a very large pond competing against founders with home-field advantage.

Now there's a third option that might be more attractive than either: incorporate under EU Inc, open a Revolut account in a few days, and access 450 million relatively wealthy customers with unified compliance and a regulatory framework that actually makes sense. The effort to get into France now genuinely does give you Europe, no asterisks or caveats required.

For founders in Casablanca or Cairo or Tunis weighing their options, that changes the calculus considerably. Why spend years and hundreds of thousands of dollars trying to crack Saudi, UAE, Egypt, and Morocco (four separate markets with four separate regulatory regimes that don't talk to each other) when you could incorporate in Tallinn and sell to Germany, France, and Spain with one structure, one compliance framework, and one set of rules to learn?

I asked Jalouqa where he advises founders to incorporate today: Delaware for deep tech and software companies, ADGM or DIFC for fintech.

The free zones work, to be clear, and they've served the region's startup ecosystem reasonably well as a coping mechanism. But coping mechanisms aren't solutions, and now founders have a better coping mechanism available elsewhere, and one that happens to come with a larger and more integrated market attached at that.

All of this being said, it’s important to note that individual governments in the region are, by and large, quite responsive to what their startup ecosystems need.

Saudi Arabia's SAMA has approved over 50 fintechs through its regulatory sandbox since 2018, iterating on frameworks for open banking, peer-to-peer lending, and debt crowdfunding based on direct feedback from companies testing products in live environments. The sandbox moved to an "always open" model, with dedicated teams working alongside founders to refine regulations that actually work.

Dubai's VARA, the world's first dedicated virtual assets regulator, explicitly operates on the principle that "set and forget does not work for crypto; it's all about feedback and open channels." When tokenisation emerged as a use case, VARA worked with the Dubai Land Department to launch the region's first licensed real estate tokenisation platform, with ambitions to tokenise up to 7% of Dubai's property market by 2033. The UAE Central Bank has iterated on open banking rails, the DFSA has launched tokenisation sandboxes, and Saudi's CMA runs a fintech lab for capital markets innovation.

So, in isolated instances, each of these states is collaborative, innovative, and genuinely helpful to the founders operating within their borders. The problem is that "within their borders" is precisely the constraint. Each government listens to its own ecosystem in its own silo, producing excellent national-level frameworks that don't talk to each other. A fintech licensed by SAMA still needs separate approval from the UAE Central Bank. A VARA-licensed crypto company can't operate in Riyadh without going through Saudi's own licensing regime. The consequence is that innovation happens in parallel then rather than in coordination.

The GCC has maintained a Common Market since 2008. The Digital Cooperation Organisation exists and theoretically aims to harmonise digital policy across member states. The Greater Arab Free Trade Area eliminated customs duties among 18 members back in 2005. None of these frameworks has translated into anything resembling mutual recognition of regulatory approvals or a unified corporate structure for startups, let alone the underlying single market that would make such a structure worth having.

Europe got EU Inc through grassroots pressure: 22,000 signatures, sustained advocacy, fifteen months of pushing until Brussels moved. That model doesn't translate to the Gulf context, where the political economy of policy change works differently, but that doesn't mean the outcome is impossible, just that the path would need to look different.

The GCC has demonstrated it can coordinate when the political will exists. The Peninsula Shield Force, the interconnected power grid, the (still aspirational) rail network connecting the six member states: these required government-to-government negotiation, and they happened because leadership decided they should happen.

The question is whether anyone with convening power, whether that's the DCO, the GCC Secretariat, bilateral business councils, or individual ministers who've shown themselves willing to innovate domestically, will decide that cross-border startup mobility matters enough to put on the agenda. The individual pieces exist. SAMA's sandbox model could theoretically extend to mutual recognition. DIFC and ADGM could theoretically harmonise their frameworks. The will to coordinate hasn't materialised, but the technical capacity isn't the constraint.

What the ecosystem can do, in the meantime, is articulate what it would actually need. Mutual recognition of regulatory sandboxes, a GCC startup visa, harmonised securities frameworks for cross-border fundraising, standardised KYC/AML that doesn't require re-verification in each jurisdiction. Something concrete enough that a responsive government could say yes to if it wanted to.

Because across MENA, governments have shown they'll say yes to good ideas, presented through appropriate channels, when those ideas serve their strategic interests. Whether cross-border integration counts as a good idea, in their assessment, remains to be seen.