Legal Insights · Employment Law
MOHRE’s expanded authority under Federal Decree-Law No. 9 of 2024 and what it means for employers and employees in 2026.
The United Arab Emirates has, over recent years, moved decisively to modernise its labour framework and tighten enforcement. Federal Decree-Law No. 33 of 2021 on the Regulation of Employment Relations remains the cornerstone of that framework, but Federal Decree-Law No. 9 of 2024, which took effect on 30 August 2024, has fundamentally recalibrated how the law is enforced. As 2026 unfolds, both employers and employees are encountering a markedly stricter and more interventionist regulatory environment.
At a Glance
- MOHRE may issue binding decisions in labour disputes up to AED 50,000, enforceable as executive instruments.
- Appeals go directly to the Court of Appeal; decisions are final within 30 working days.
- Fines on employers now range from AED 100,000 to AED 1,000,000, multiplied per affected worker up to AED 10 million.
- The limitation period for worker claims has been extended to two years from end of service.
1. Amended Article 54: MOHRE’s Binding Resolution Authority
The amendments to Article 54 of the Labour Law significantly expand the powers of the Ministry of Human Resources and Emiratisation (MOHRE). The Ministry is now empowered to issue binding decisions in individual labour disputes where the claim does not exceed AED 50,000, or where a party fails to comply with an earlier amicable settlement reached under MOHRE supervision. These decisions carry the force of an executive instrument, meaning they can be enforced directly through the execution judge without the need to file a separate substantive claim.
Either party retains the right to challenge the Ministry’s decision before the competent Court of Appeal within fifteen working days of notification. The court must schedule the first hearing within three working days of registration and deliver its judgment within thirty working days. The appeal judgment is final and not subject to further recourse. This accelerated timeline is designed to ensure that workers recover amounts owed promptly, while giving employers a clear and expedited route to contest decisions they consider unfounded.
Penalties are multiplied by the number of affected workers, up to an aggregate cap of AED 10,000,000.
2. A Revamped Penalty Regime — Up to AED 10 Million
Perhaps the most consequential change introduced in 2024, and now fully visible in enforcement trends during 2026, is the upgraded sanctions framework. Fines imposed on employers for serious violations now range between AED 100,000 and AED 1,000,000. Qualifying violations include employing workers without valid work permits, fictitious or sham employment, circumventing Emiratisation obligations, and failure to pay wages or end-of-service entitlements.
Crucially, the law provides that penalties are multiplied by the number of affected workers, up to an aggregate cap of AED 10,000,000. In addition to financial penalties, MOHRE may order the employer to pay all outstanding worker entitlements and may apply administrative measures such as downgrading the establishment’s classification, suspending its Ministry file, or striking it off altogether. The cumulative effect is a compliance environment where non-observance of basic worker protections now carries real, enterprise-level risk.
3. Worker Rights and Procedural Safeguards in 2026
The 2024 amendments consolidate a number of employee-protective reforms that employers must internalise:
- Extended limitation period: workers may now bring claims within two years of the end of the employment relationship, instead of one year.
- Continued wage payments during disputes: MOHRE may order the employer to continue paying salary for up to two months where a dispute has disrupted payment.
- Enhanced statutory leaves: five days of parental leave, five days of bereavement leave for a spouse and three days for a relative up to the second degree, and ten days of study leave per year for employees with two years’ service.
- End-of-service gratuity: calculated as 21 days’ wage for each of the first five years of service, and 30 days’ wage for each subsequent year.
4. Practical Recommendations for Employers
Given the heightened enforcement posture in 2026, employers are well advised to conduct a comprehensive legal audit of their employment contracts, HR policies, and internal regulations to ensure full alignment with the 2021 Law and its 2024 amendments. Particular attention should be paid to timely salary payments through the Wages Protection System (WPS), proper registration of workers, and renewal of work permits. Employers should also implement a robust internal grievance mechanism to resolve disputes before they reach MOHRE, and train HR personnel on the new procedural timelines governing binding resolutions and appeals.
How We Can Help
Mohamed Al Azazi Advocates & Legal Consultants
The year 2026 marks a decisive phase in the enforcement of UAE employment law — closer supervision, heavier financial sanctions, and faster administrative resolution of disputes. Our firm advises private-sector establishments and individual employees on the practical implications of these reforms and represents them before MOHRE and the competent courts, ensuring full compliance for employers and effective protection of rights for workers.