Hiring without valid UAE work permits : risks, penalties and compliance steps

The UAE’s Ministry of Human Resources and Emiratisation (MoHRE) has taken a firm stance against the employment of workers without valid permits. Beyond technical noncompliance, illegal hiring undermines worker protections and distorts the labour market. This practical briefing outlines the legal risks, enforcement trends, and the steps employers should take to stay compliant.

Why illegal hiring is high risk ?

Workers employed without valid permits fall outside the legal framework designed to protect their rights, leaving them vulnerable to exploitation and disputes. For employers, noncompliance may lead to administrative, financial, and potentially criminal consequences, as well as operational disruption (e.g., inability to onboard or transfer staff while the labour file is suspended).

Intensified enforcement : coordinated inspections

MoHRE works with the Federal Authority for Identity, Citizenship, Customs and Port Security (ICP) to conduct joint inspections and identify violators. Cross agency enforcement underscores the government’s commitment to a fair and transparent labour market.

Penalties : suspensions, hefty fines, imprisonment

Sanctions may include :

• Labour file suspensions, significantly disrupting HR operations (hiring, renewals, transfers).
• Substantial fines, often in the range of AED 200,000 to AED 1,000,000 depending on severity and repeat offences.
• Imprisonment in serious cases.

Beyond fines, reputational damage and internal disruption can have longterm impact.

Use licensed recruitment agencies only

MoHRE advises employers to work exclusively with licensed recruitment agencies verified via official MoHRE channels. Using unlicensed intermediaries creates coliability for irregularities (undeclared work, misleading job offers, lack of permits).

Enhanced protections for domestic workers

Recent changes have strengthened protections for domestic workers, including an extended six month probation period and mandatory financial guarantees for recruitment agencies, aimed at safeguarding obligations and preventing abuse in three party arrangements (household – agency – worker).

Compliance best practices

• Map roles : ensure job titles and duties align with licensed business activities.
• Verify authorisations before work starts : work permits, residence visas, Emirates ID, document validity.
• Keep audit trails : maintain evidence of authorisations and expiry dates in HR files.
• Assess partners : confirm agencies are licensed, uptodate on guarantees, and compliant with MoHRE guidance.
• Train managers : raise awareness of risks tied to informal work (unpaid trials, “volunteering,” freelance without permits).

Handling sensitive scenarios

Worker identified without a permit

Stop work immediately, attempt to regularise status (expedited filing, temporary suspension of the role), cooperate with authorities, and assess payroll/contract implications.

Noncompliant agency

Terminate the relationship, document breaches, notify MoHRE if required, and adopt enhanced due diligence for new licensed providers.

Prevention through governance

Implement standardised procedures (onboarding checklists, renewal calendars, HRLegal double checks) and regular audits. For high volumes or cross border profiles, consider outsourcing to specialised providers to accelerate processing and ensure compliance.

Hiring without valid UAE work permits brings significant legal and operational risks. Strong HR governance, systematic document checks, licensed agency selection, renewal planning and manager training, meaningfully reduces exposure and supports a transparent labour market. Proactive compliance is the best defence against costly sanctions and business interruption.

Our lawyers, who are experts in labour law, are available to answer all your questions and provide advice. We offer face-to-face meetings or videoconferencing. You can make an appointment directly online at https://www.agn-avocats.fr/.

AGN AVOCATS – Labour Law
contact@agn-avocats.fr
09 72 34 24 72