ADGM Employment Regulations: Major Amendments 2019–2024

The Abu Dhabi Global Market (ADGM) has issued the Employment Regulations 2024,(2024 Regulations) a comprehensive refresh of its employment law framework came into force on 1 April 2025, these Regulations repeal the ADGM Employment Regulations 2019 and provide a modernised set of rules designed to reflect today’s workplace realities.  

The 2024 update retains that familiar structure but refines it substantially. Among the most notable developments: 

1. A dedicated framework for part-time and remote employees  
2. Tighter rules on visa and work permit procedures 
3. A new daily penalty for late post-termination payments 
4. Expanded equality law protections, including a stand-alone victimisation claim 

According to the ADGM Registration Authority (RA), the aim is simple: align with international best practice, address global workplace shifts, and offer clarity to both employers and employees. 

Who Qualifies as an Employee as per the 2024 Regulations

Under the 2019 Regulations, an “employee” was essentially someone working in or from ADGM, with the definition closely tied to a physical presence within the jurisdiction. Under the 2024 Regulations, the scope has widened significantly. Now, any individual who agrees in their employment contract to be subject to the Regulations is deemed an employee even if they are not physically based in ADGM. This contractual “opt-in” provision means employers can bring offshore or remote staff within the ADGM framework simply by agreeing to it in writing.  

Section 11 of the Regulations formally introduces the category of the “Remote Employee”, defined as an employee whose usual workplace is not the employer’s ADGM premises. This can cover: 

1. Fully remote staff: working entirely away from the employer’s ADGM office 
2. Hybrid workers: splitting their time between ADGM premises and other locations agreed with the employer. 

 This blog is a part of our ADGM Practices.

Key Employer Duties for Remote Employees 

Provision of Equipment (Section 11): Unless otherwise agreed, employers must provide and maintain the technical equipment necessary for remote employees to carry out their work. This ensures employees have the tools they need to perform effectively, without bearing the cost themselves. 

Adjusted Workplace Obligations Sections 11(2) & (3): The Regulations recognise that some workplace health and safety provisions are not relevant for remote work. Accordingly: 

1. For Remote Employees based in the UAE: relevant rules which deals with covering ventilation, temperature, lighting, cleanliness, room space, workstations, sanitary facilities, and drinking water) do not apply. However, employers must still comply with visa and work permit requirements. 
2. For Remote Employees outside the UAE: Relevant rules covering visa/work permits, health & safety duties, workplace facilities, and health insurance do not apply.  
3. Equal treatment: Unless expressly excluded, all other references to “employee” in the Regulations apply equally to remote employees. This means rights relating to leave, wages, termination protections, and non-discrimination still entirely apply. 

Part Time Entitlements: For part-time employers, Rule 10 sets out how benefits for part-time employees are calculated. If a part-time employee’s contract requires them to work every day of their employer’s working week, their entitlements such as paid leave, sick leave, and other benefits are not reduced; they receive the same benefits as full-time employees. However, if a part-time employee works fewer than five days per week, their entitlements are adjusted (pro-rated). The calculation is simple: the number of days the part-time employee works each week is divided by the number of days a full-time employee works. This percentage is then applied to their benefits. 

Work Permits, Visas, and Costs  

Under the 2019 Regulations:  The employers were already responsible for securing work permits and visas for employees under 2019 Regulations, but the framework lacked detail on exact timing, cancellation requirements, and cost responsibility. 

Under 2024 Regulations: The 2024 update, set out in Section 4, changes this by consolidating the rules, closing loopholes, and making it very clear what employers must do and when. First, employers must now obtain, or at least apply for, an Employee Work Permit before the employee starts work in ADGM. This is a precondition to employment commencing. Second, the employer must bear the full cost of the work permit, any sponsored UAE residency visa, and the employee’s Emirates ID. No reimbursement from employees is permitted, even if the employment ends early or during probation.  

Impact on termination of employment: Following termination, employers are required to cancel the work permit and any associated visa within the timeframe prescribed by the ADGM Registration Authority. Delays are no longer treated as minor oversights; they are compliance breaches. Importantly, employers cannot make visa or work permit cancellation conditional on an employee waiving statutory rights, such as notice pay or end-of-service benefits or agreeing to settlement terms outside the Regulations. Any such practice is prohibited and may result in enforcement action. Non-compliance with these obligations can attract fines of up to Level 7 on the Standard Fines Scale, underlining that immigration and identity compliance is taken seriously by the ADGM authorities. For employers, this means work permit and visa management must be treated as a front-line compliance issue, with proper processes, budgeting, and HR training in place. For employees, the changes offer greater protection and transparency.  

Late-Payment Penalty After Termination  

The Employment Regulations 2024 introduce, for the first time in ADGM, an explicit penalty regime for late payment of wages and other entitlements following termination. This marks a clear departure from the 2019 Regulations, which, while requiring employers to make final settlement, did not impose any statutory daily penalty for delay. 

Under the 2024 Regulations, employers are now required to pay all wages and other amounts due, excluding genuinely variable elements such as commission or performance-related bonuses that cannot reasonably be calculated at the time, within 21 calendar days of the termination date. 

If the employer fails to meet the 21-day deadline, Rule 14(3) imposes a daily penalty equal to the employee’s Daily Wage for each calendar day the payment remains overdue. However, this penalty is subject to important conditions: 

1. The Court may waive or reduce the penalty where it considers it just and equitable, taking into account the conduct of both the employer and the employee. 
2. The penalty applies only if the unpaid amount exceeds one week’s wage. 
3. The total penalty cannot exceed six months’ worth of the employee’s daily wage. 

Working Time & Leave  

The 2024 Regulations retain the familiar structure of working time and leave entitlements but introduce meaningful refinements that better reflect the realities of diverse working patterns and family needs.  

1. Bereavement Leave: For the first time, 2024 Regulations introduces a statutory right to bereavement leave of five working days with pay upon the death of a close family member. 
2. Nursing Break: Mothers returning from maternity leave are now entitled to one hour of paid nursing time per day for nine months following childbirth, in addition to their normal rest breaks.  

Parental rights 

The 2024 Regulations retain the core parental leave structure but expand eligibility, enhance clarity, and ensure greater protection for both parents and adoptive families. 

Maternity Leave: Female employees are entitled to 65 working days of maternity leave, with the scope now broadened to include: 

1. Adoption of a child under 5 years old, whether inside or outside the UAE (previously limited to adoption of children under 3 months). In such cases, “childbirth” is deemed to mean the date of adoption. 
2. Stillbirth or miscarriage after the 24th week of pregnancy, ensuring compassionate leave in such circumstances. 

During maternity leave, the vacation leave accrues and can be taken separately after maternity leave. Additionally, the employee has the right to return to the same role or, if not reasonably practicable, to a suitable alternative on substantially the same terms, conditions, and seniority rights. 

Maternity Pay: Maternity pay is available if the employee has at least 12 months’ continuous service before the expected or actual week of childbirth and meets the notice and evidence requirements, including: 

1. Written notice of pregnancy at least 8 weeks before the expected childbirth week. 
2. A medical certificate confirming the expected or actual date of childbirth (if requested). 
3. Written notice at least 21 calendar days before maternity leave begins 

Paternity leave: Male employees are entitled to a minimum of 5 working days of paternity leave, to be taken within 2 months of childbirth or adoption of a child under 5 years old. This entitlement covers both biological and adoptive fathers. To qualify for paternity pay, the employee must have 12 months’ continuous service before the week of birth or adoption. The leave is paid at the employee’s daily wage, public holidays during the leave extend it, and payment in lieu is prohibited. 

Specific provisions for Non-Discrimination and Victimisation.   

The 2024 Regulations significantly strengthen workplace equality obligations, with Part 9 retitled “Non-Discrimination and Victimisation” to better reflect its expanded scope. The definition of unlawful discrimination is now broader, prohibiting both direct and indirect discrimination on a wide range of protected characteristics. The 2019 position prohibited discrimination but only had a narrower scope.  

Victimisation as a standalone claim: The new text introduces a freestanding cause of action for victimisation. An employee is protected if they are subjected to detrimental treatment because they: 

1. Have brought a discrimination claim; 
2. Have given evidence or information in connection with such a claim; or 
3. Have otherwise supported or raised concerns about discriminatory conduct. 

This provision makes retaliation claims more accessible and enforceable, ensuring employees can speak up without fear of adverse consequences. Also, employees are expressly shielded from being in breach of confidentiality obligations when making a protected disclosure. Employers cannot impose civil, contractual, or any other form of liability for doing so, nor can they enforce legal or contractual remedies against the employee in retaliation. Also, there are clear provisions which stipulates that employers and any related parties must not retaliate or even threaten to retaliate, because an employee has made, or intends to make, a protected disclosure. Retaliation is broadly defined to cover: 

1. Dismissal or disciplinary action; 
2. Forcing or pressuring the employee to resign or retire; 
3. Denying equal terms, benefits, training, promotion, or transfer opportunities compared to peers in similar roles; 
4. Any other action reasonably likely to cause detriment or disadvantage, whether by act or omission; 
5. Organising or arranging for others to carry out such acts. 

Conclusion for ADGM Employment

The 2024 Regulations modernise ADGM’s employment framework, retaining its familiar foundation while introducing sharper definitions, clearer processes, and stronger protections in line with the shift in global employment practises. For employers, the priority is to update contracts to capture remote and hybrid work terms, apply part-time pro-rating rules, and reference overtime entitlements. Onboarding and offboarding procedures must be tightened, with strict compliance on work permits, visa processing, and the new 21-day final-payment rule to avoid daily penalties. Policies on non-discrimination, victimisation, grievance handling, and record-keeping require alignment with the enhanced statutory standards, while remote-work applicability must be assessed based on UAE or overseas location. For employees, the changes deliver clearer rights on flexible working, guaranteed timelines for final pay, expanded parental and bereavement leave, and stronger safeguards against retaliation.