By The UAE’s Ministry of Human Resources and Emiratisation (MOHRE) has warned private-sector employers that five labour law violations can attract fines ranging from Dh100,000 to Dh1 million. The warning, issued on 23 October, urges employers to review recruitment practices and ensure compliance before hiring or employing workers.
MOHRE stated that “compliance with labour legislation is a legal obligation for private-sector establishments and is essential to protecting workers’ rights.” The five violations are: employing a worker without a valid MOHRE work permit; recruiting a worker without providing assigned duties; using a work permit for purposes other than those for which it was issued; closing an establishment without settling employee status; and employing minors in breach of labour law provisions, including rules on parental or legal guardian consent.
What the five violations mean in practice
The first violation covers bringing someone onto the payroll before MOHRE approval is finalised, which can happen during urgent hiring or when a new starter begins work while paperwork is pending.
The second addresses “bringing in workers and leaving them without assigned duties,” which can occur when a company recruits overseas workers for a delayed or cancelled project, or holds workers in reserve without active roles.
The third involves misusing permits: a permit issued for a temporary project cannot be used for a permanent role, and a permit for one establishment cannot be used to assign work at another location.
The fourth concerns business closure. MOHRE emphasised that “employers’ obligations extend beyond the period of business operations, requiring them to address workers’ employment status through the approved procedures when a business closes.” This means settling end-of-service benefits, cancelling permits, and notifying MOHRE before ceasing operations.
The fifth relates to minors aged 15 to 18. MOHRE clarified that parental consent “does not permit employers to disregard the legal conditions governing the employment of minors.” Employers must obtain the correct juvenile work permit and follow restrictions on working hours, job types, and conditions.
How MOHRE work permits structure compliance
MOHRE outlined the permit categories employers must use correctly: recruiting workers from abroad, transferring non-citizen workers between establishments, employing individuals holding family-sponsored or Golden Visas, hiring workers for temporary projects or part-time positions, employing or training students, recruiting citizens and children of Gulf Cooperation Council countries, permits for juveniles aged 15 to 18, training permits for citizens, and authorisations for qualified individuals.
Each permit type carries specific conditions. A part-time permit does not authorise full-time employment. A student training permit does not authorise regular employment. HR teams should map each employee to the correct permit category and verify that the actual work performed matches the permit’s stated purpose.
The fine range of Dh100,000 to Dh1 million is substantial enough to affect cash flow and budgeting for small and mid-sized businesses. The ministry has not published a detailed schedule showing which violation attracts which exact amount within that range, so employers should treat the upper figure as a realistic risk for serious or repeated non-compliance.
What HR and payroll teams should check now
A practical compliance review should cover several areas.
First, audit every active employee against their MOHRE work permit. Confirm the permit is valid, unexpired, and matches the worker’s current role and establishment. Second, review any workers who have been recruited but are not yet assigned duties. If a project is delayed, communicate with MOHRE about the correct procedure rather than leaving workers idle. Third, check that no permit is being used for a purpose outside its original approval. Fourth, if a business closure is planned or underway, ensure employee status is settled through approved procedures before operations cease. Fifth, review any employment of workers aged 15 to 18 and confirm that the correct juvenile permit is in place and that all legal conditions are met.
Payroll teams should also confirm that salary payments through the Wages Protection System remain current, as payment failures can trigger separate enforcement actions that may draw inspection attention to other compliance gaps.
Enforcement and risk considerations
MOHRE enforces labour law through inspections, worker complaints, and data from systems such as the Wages Protection System. A single complaint about an incorrect permit or lack of assigned duties can trigger an inspection that uncovers broader issues. Fines may apply per violation, and businesses with multiple affected workers could face compounded penalties.
The ministry’s warning does not state whether free zone employers are covered by these specific fines, and the legal framework for free zones can differ from mainland regulations. Employers in free zones should confirm with their free zone authority and MOHRE whether the same penalty schedule applies.
The appeal process for MOHRE fines typically involves submitting a grievance to the ministry within a set period, followed by escalation to the labour court if the grievance is rejected. Employers who receive a fine should document all evidence, including permit records, payroll data, and correspondence with workers, before submitting a grievance.
The ministry’s message is direct: compliance is a legal obligation, and the cost of getting it wrong now reaches seven figures in dirhams. HR and payroll leaders in the UAE should treat the warning as a prompt to run a full permit and worker status audit before an inspection or complaint brings the issue to MOHRE’s attention.
Sources: ET HREMEA
Photo: Cheap labour working of new subway line in Dubai, UAE (9426902759) by Jeroen Komen from Utrecht, Netherlands, CC BY-SA 2.0
