UAE

Impact date: 1 April 2025 The Abu Dhabi Global Market (“ADGM”) new Employment Regulations 2024 (the “Regulations”) came into force on 1 April 2025.

The main changes made by the Regulations are:

• Visa and work permit matters: employers are required to obtain and pay for work visas, sponsorship (if required) and Emirates ID (if required), with applications required to be made before employment commences. Employers must not seek payment for these from the employee. On termination, employers must cancel work permits as soon as is reasonably practicable and must not seek payment or make such cancellation conditional upon any waiver of rights or payment being made to the employer
• Clarification of employee rights during probationary periods: employees may take annual leave if approved by their employer. Employees are entitled to sick leave but not to sick pay. Employees are entitled to receive a repatriation flight on the termination of their employment, provided their employment was terminated for cause. There is no entitlement to hajj, maternity/paternity/ante-natal leave. There is also no entitlement on termination to written reasons, a reference or end of service gratuity. If the contract is less than six months, the probation should be half of that period
• Contract matters: a written employment contract is required to be issued as soon as reasonably practicable and in any event no more than one month after the commencement of employment
• Remote Workers: new categories of employees: (i) fully remote employee; (ii) overseas fully remote employee; and (iii) UAE fully remote employee. For those working outside the UAE, no UAE residence visa or ADGM work permit is needed
• Family-related leave: new maternity leave rights for female employees adopting a child of five years old or less (this is currently only applicable to adopted children aged three months or less); the introduction of nursing breaks for returning female employees (at least one break of one hour for up to nine months after the date of childbirth); maternity leave is extended to permit leave in the event of a stillbirth or miscarriage after the start of the 24th week of pregnancy; confirmation that if an employee is dismissed during maternity/adoptive leave they will be paid the maternity pay they would otherwise have enjoyed; and the introduction of paternity leave for fathers of five working days to be taken within two months of the child’s birth or adoption; the introduction of ante-natal leave; the introduction of bereavement leave of five days on the death of a spouse, parent, child or sibling to be used within one month of the bereavement
• Pay-related matters: wages must be paid within 14 days of the end of the relevant pay period. There will be a choice available between end of service (“EOS”) or savings plan. If EOS, wages are payable regardless of the reason for termination if the employee has sufficient service. Basic pay cannot be less than 50% of an employee’s wage for the purposes of EOS calculations
• Working hours: Muslim employees have an entitlement to reduced hours of 25% during Ramadan
• Non-victimization: the concept of victimization is introduced, defined as subjecting an employee to detriment (including dismissal) if the employee does a protected act (issue proceedings, give evidence, or make an allegation) in good faith. Remedies include compensation of up to three years wages
• Non-discrimination: there is additional clarification in relation to what constitutes direct discrimination, indirect discrimination and harassment; and victimization being added as a protected type of discrimination
• Vicarious liability: confirmation is provided that an employer may be liable for any act, attempted act or omission of an employee done in the course of their employment with the employer
• Termination: EOS is always payable; payments must be made within 21 days, otherwise late penalty payments can be imposed; reference letters must be provided within 21 days of request; pay in lieu of notice is payable only with the employee’s agreement; visa cancellation must not be linked to any waiver; settlement agreements must confirm that the employee had the opportunity to take legal advice
• Employment contracts and records: employers are required to retain a copy of certain information as part of the employment record, and employment contracts will need to confirm that they are governed by the laws of the ADGM and that any dispute will be subject to the jurisdiction of the ADGM courts. Records must be in English, accessible in the employer’s place of business in the ADGM and fines may be imposed if not retained for every employee
• Application: the Regulations do not apply to employers with dual licenses governed by UAE federal law

Impact date: 16 April 2025 A Cabinet Decision (no. 43 of 2025) has updated the position on violations and administrative penalties related to the Emiratisation initiatives and programmes. Administrative fines will now range from AED 20,000 to AED 100,000 for each instance of submitting false data to benefit from the ‘Nafis’ program or to evade Emiratisation requirements.

Impact date: 22 April 2025 The UAE Ministry of Human Resources and Emiratisation (“MoHRE”) has directed that employers are legally required to report work-related injuries or suspected occupational illnesses. Employers must notify the competent medical authority and the police station within the geographical area, as well as inform the Ministry through designated channels, within a maximum of 48 hours from the date of their knowledge or their legal representative’s knowledge of the occurrence of an injury or suspected work-related illness.

Impact date: 7 May 2025 The Sharjah Executive Council approved amendments to the executive regulations of the Sharjah Human Resources Law (Resolution No. 12 of 2021). The amendment allows for fully paid care leave to female Government employees who give birth to children with medical conditions or disabilities requiring constant care. This leave lasts for one year after maternity leave and can be extended annually for up to three years with medical approval.

Impact date: 14 May 2025 The Ministry of Human Resources and Emiratization (“MoHRE”) has implemented a four-step penalty framework for employers who fail to make timely contributions to the Voluntary Savings Scheme. Non-compliant employers face penalties, including permit suspensions and fines, to ensure contributions are made within the specified timeframe.

Impact date: 31 May 2025 The ADGM has introduced the Whistleblower Protection Regulations 2024 (“Regulations”), to reinforce a culture of transparency and accountability within the ADGM.

The Regulations establish that protected disclosures relate to knowledge or a reasonable suspicion that an ADGM entity, employee or agent has contravened a law applicable in the ADGM or has, may have or is likely to engage in money laundering, fraud or any other financial crime. Disclosures can be made to designated persons within the entities, regulatory bodies, or law enforcement agencies, ensuring a wide range of options for whistleblowers to report their concerns.

Individuals making good faith disclosures are entitled to protection against civil or contractual liability, employment termination, or any form of detriment due to the disclosure.

ADGM employers must now implement and maintain effective arrangements to facilitate the making of protected disclosure, assess and escalate concerns arising from those disclosures and protect the identity of those making disclosures. Employers with a larger headcount and more significant tools at their disposal will be held to a higher standard in terms of implementation of the rules.

The arrangements must be set out in written policies and procedures by various entities including those with more than 35 employees or more than $13.5m USD in annual turnover.

Impact date: 28 July 2025 Dubai has passed a new public health law, outlining a wide range of measures to improve community health and reduce disease transmission. Specifically, the law contains provisions requiring food-related establishments, owners of labor accommodations and entities in the field of public health pest control to comply with applicable legislation related to the health and safety of their employees and other training requirements.