Our latest Navigating Employment Law in the Middle East webinar—Part 1 of the UAE edition—kicked off the fourth installment of this multipart series. The session focused on the UAE private sector employment framework—excluding the Abu Dhabi Global Market (ADGM) and Dubai International Financial Centre (DIFC)—and explored what employers need to know about the law, Emiratization, employment contracts, onboarding, and Golden Visa considerations.
This blog post explores the key takeaways.
The Legal Framework: UAE Labour Law at a Glance
Employment relationships in the UAE private sector are governed by UAE Decree-Law No. 33 of 2021, as amended (the UAE Labour Law), together with its Implementing Regulations. This legislation fully replaced the former labour law in February 2022.
The law applies broadly to private-sector employers but excludes federal and local government employees, members of the armed forces, police and security services, and domestic workers.
Enforcement and Penalties
Compliance is enforced by the Ministry of Human Resources & Emiratization (MOHRE). Penalties can be significant—ranging from AED 5,000 to AED 1 million, and multiplied by the number of employees affected, up to a maximum of AED 10 million.
How Employment Disputes Are Handled
The UAE Labour Law sets out a clear dispute resolution pathway:
- Claims must first be filed with MOHRE, which will attempt to facilitate a settlement.
- If the claim is AED 50,000 or less, or if a settlement is agreed but not complied with, MOHRE may decide the dispute directly. That decision can then be appealed to the Court of First Instance.
- For claims exceeding AED 50,000, and where no settlement is reached, MOHRE will refer the matter to the Labour Court.
Importantly, the courts will not accept claims unless these preliminary steps have been followed.
Emiratization: What Employers Need to Know
Emiratization is a central pillar of UAE employment policy, designed to increase the participation of Emirati nationals in the private sector. The programme combines training initiatives, role reservations, and targeted legal requirements for employers.
The results have been notable. As of end-June 2025, MOHRE reported that 152,000 Emiratis were employed across 29,000 private-sector companies.
Emiratization Targets
Requirements vary depending on company size and sector:
- Companies with 50 or more employees must increase Emirati representation by 2% per year from 2022 to 2026, reaching 10% by the end of 2026. Targets are assessed semi-annually (1% by June and a further 1% by December).
- Companies with 20–50 employees operating in 14 designated sectors were required to employ one Emirati in 2024 and a second in 2025.
- At the time of the webinar, MOHRE had not announced whether these requirements will extend into 2026 for companies with fewer than 50 employees.
Minimum Wage Update for Emiratis
From 1 January 2026, the minimum wage for Emiratis under new or renewed work permits will be AED 6,000 per month. Existing Emirati employees must reach this threshold by 30 June 2026, with enforcement measures—including work permit suspensions—beginning 1 July 2026 for non-compliant employers.
Employment Types and Contract Essentials
The UAE recognises a wide range of work arrangements, including full-time, part-time, temporary, flexible, remote, and job-sharing models.
Some key contract points to keep in mind:
- Certain authorities (such as MOHRE and JAFZA) require standard-form contracts, while others (including DMCC and DDA) make them optional.
- Contracts must be prepared in duplicate, with Arabic as the governing language.
- Any amendments must be in writing and signed by both parties.
- All employment contracts must be for a limited term, although there is no maximum duration.
- Contracts may be terminated at any time on notice, and early termination generally does not attract compensation, except in limited cases of arbitrary dismissal.
Well-drafted contracts should clearly cover details such as the role, start date, workplace, working hours, probation, remuneration, leave entitlements, and termination procedures.
Onboarding in the UAE: Getting the Sequence Right
To legally work in the UAE, employees must hold a valid work permit and, where applicable, a residence visa.
- Gulf Cooperation Council (GCC) nationals, including UAE citizens, require a work permit but not a residence visa.
- Golden Visa holders also require a work permit.
- Crucially, all approvals must be in place before the employee starts work.
For non-GCC hires recruited from outside the UAE under MOHRE, the onboarding process typically includes quota approval, an offer letter, an entry permit, arrival in the UAE, medical testing, Emirates ID registration, health insurance enrollment, and issuance of the residence visa, work permit, and employment contract.
Golden Visas: Clearing Up Common Misconceptions
The Golden Visa is a long-term, self-sponsored residence visa (up to 10 years) available to specific categories, including investors, entrepreneurs, scientists, specialists, top graduates, and humanitarian contributors.
The webinar addressed several persistent misconceptions, including the belief that:
- Employers do not need to provide health insurance to Golden Visa holders
- A Golden Visa replaces the need for a work permit
- Golden Visa holders fall outside the scope of UAE Labour Law
- Employers must sponsor or fund Golden Visa applications
None of these assumptions are correct. Golden Visa holders working in the UAE remain subject to the UAE Labour Law and standard employment compliance requirements.
What’s Coming Next
Our Middle East employment law series continues throughout 2026, with upcoming sessions covering key employment terms and termination issues across ADGM, DIFC, Kingdom of Saudi Arabia (KSA), and the UAE. The next webinars are scheduled for 10 February 2026 (DIFC), 10 March 2026 (KSA), and 14 April 2026 (UAE).