View the publication here.

Following our previous article, the Abu Dhabi Global Market (“ADGM”) has published the Employment Regulations 2024 (the “New Employment Regulations”), which impact hiring practices, employee entitlements, and employer obligations.

Key Changes:


Category

Employment Regulations 2019

New Employment Regulations (2024)
   
Hiring and Employment Contracts   

Employers were required to provide a fully executed employment contract within one (1) month of the employee’s start date.

The requirement remains the same, but a fine up to level 3 on the Standard Fines Scale is now introduced for non-compliance.

No explicit penalties for misleading job candidates.

Employers can now be fined for misleading job candidates about wages, job duties, or working conditions.
   
Probationary Period   

Employees on probation were not entitled to sick leave.

Employees on probation can now take sick leave, but without sick pay.

Termination during probation required at least one (1) weeks’ notice.

The same requirement applies, but the right to repatriation flights after termination is now explicitly stated.
   
Part-Time and Remote Employees   

No clear provisions on remote work or equipment requirements.

Employers must provide necessary equipment for remote employees, unless agreed otherwise.

No explicit rules on pro-rata benefits for part-time employees.

Pro-rata benefits for part-time employees are now clearly defined, with leave entitlements adjusted based on the number of working days per week.
   
Wage Protection & Payment Timelines   

Employers were required to pay wages within seven (7) days of the end of the pay period.

Employers must now pay wages within fourteen (14) days of the end of the pay period.

No specific penalties for delayed final wage payments.

Employers must now pay all final wages within twenty-one (21) days of termination, or they face a penalty equal to the employee’s daily wage for each day of delay, capped at six (6) months.
   
Maternity & Paternity Benefits   

Maternity leave was sixty-five (65) days but applied only to biological mothers and adoptive mothers of children under three (3) months.

Maternity leave remains sixty-five (65) days, but now explicitly includes adoptive mothers of children under five (5) years old.

No specific provisions for stillbirths or late miscarriages.

Now explicitly covers mothers of stillborn babies or those who experience a miscarriage after twenty-five (25) weeks.
   
No specific provisions for termination during maternity leave.   

Now explicitly states that employers must now pay full maternity pay even if terminating an employee during maternity leave, unless termination is for cause.

Paternity leave was five (5) days, but adoptive fathers were not explicitly mentioned.

Paternity leave remains five (5) days, but now explicitly includes adoptive fathers.
   
No additional nursing break entitlements.   

Employees returning from maternity leave can now take one (1) hour nursing breaks daily for nine (9) months after childbirth.
   
Termination & Notice Periods   

End of service gratuity was capped at two (2) years’ pay.

The two (2) years’ cap has been fully removed.

Employers were required to provide a written statement of reasons for termination, but there was no strict deadline and no penalty for non-compliance.

Employers must now provide a written statement of reasons for termination upon an employee’s request, within twenty-one (21) days.

Employers were required to pay all wages and other amounts owed within fourteen (14) days of the termination date, and no explicit penalty was implemented.

Employers must now pay all wages and other amounts owed within twenty-one (21) days of the termination date. If an employer fails to comply, they must pay a penalty equal to the employee’s daily wage for each day of delay, capped at six (6) months.

Notice periods: - Seven (7) days for employees with less than three (3) months of service. - Thirty (30) days for employees with more than three (3) months of service.

Notice periods remain the same, but a penalty for non-compliance was introduced, requiring employers to compensate employees for any wages and benefits they would have received during the outstanding notice period.
   
Employer Responsibilities & Liabilities   

Employers were responsible for ensuring a non-discriminatory workplace, but liability was not explicitly defined.

Employers are now vicariously liable for discrimination, harassment, and victimization by their employees, unless they can prove that they took all reasonable steps to prevent such behaviour.

Implications for Employers in ADGM:

The ADGM's New Employment Regulations introduce stricter rules that increase employer accountability and compliance risks. To avoid penalties and legal exposure, employers should:

  • Review and update employment contracts to align with new legal requirements;
  • Ensure payroll systems meet the new payment deadlines to avoid fines;
  • Adjust HR policies to accommodate part-time, remote, and nursing employee entitlements; and
  • Strengthen workplace policies on discrimination and harassment.

If you need assistance in reviewing contracts, policies, or compliance strategies, our firm is available to assist in navigating these changes.

Romain Rolland
Romain Rolland
Partner
Logaina M Omer
Logaina M Omer
Associate