Meeting the quota and building an Emirati team are different projects, and only one of them survives an inspection. **Fictitious hiring attracts penalties running to AED 1,000,000 per case** with criminal exposure, and MOHRE can examine bank records to test whether employment is genuine. Everything in this document assumes you are doing the real thing.
Emirati Talent
Nafis, recruitment and retention
Meeting the quota and building an Emirati team are different projects, and only one of them survives an inspection. Fictitious hiring attracts penalties running to AED 1,000,000 per case with criminal exposure, and MOHRE can examine bank records to test whether employment is genuine. Everything in this document assumes you are doing the real thing.
| Item | Detail |
|---|---|
| Employer | [COMPANY NAME], [licence] [NUMBER] |
| Skilled workforce | [NUMBER] |
| Emiratis employed | [NUMBER] |
| Current rate | [PERCENTAGE] |
| Target at the next assessment | [PERCENTAGE] by [DATE] |
| Shortfall | [NUMBER] positions |
| Nafis registered | [DATE] |
| Nafis support claimed | [DETAIL] |
| Owner | [NAME], [DESIGNATION] |
| Recalculated | [DATE] — monthly |
1. The Obligation
| Point | Position |
|---|---|
| Who it applies to | Mainland establishments at the prescribed headcount thresholds. Free zones, DIFC and ADGM generally outside |
| The base | Skilled workforce, not total headcount |
| Targets step up | Annually, with half-yearly assessment points |
| Penalty for shortfall | A monthly amount per unfilled position, escalating each year |
| The target moves with hiring | Every skilled non-Emirati hire raises the requirement |
| Fictitious employment | AED 100,000 to 1,000,000 per case; criminal exposure; bank records examinable |
| Enforcement | MOHRE inspection, data matching, and complaint |
1.1Recalculate monthly, not at the assessment date. A company hiring steadily can fall below target without losing a single Emirati employee, and the penalty accrues from the point of shortfall rather than from discovery.
1.2Confirm the current thresholds, target percentages, assessment dates and penalty amounts with MOHRE. They step up annually and any figure printed here would be a snapshot.
2. What Counts, and What Does Not
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These notes accompany the template and explain the drafting choices, the compliance points and the mistakes most often made with this document. They appear as a final page in the Word file, intended to be deleted before the document is executed.
The target moves with the skilled workforce, so a company hiring steadily falls below it without losing a single Emirati employee. Penalties accrue from the shortfall, not from discovery. A monthly calculation is the single most valuable control here.
Approving a hiring plan without modelling its effect on the quota is how a compliant company becomes non-compliant while doing nothing wrong. Make the quota check part of recruitment approval.
Penalties run to AED 1,000,000 per case, with criminal exposure, and MOHRE can examine bank records to test whether salary was genuinely paid and retained. Any arrangement that would not survive being explained to an inspector should not be entered into.
Does the role have duties, a manager, objectives and output? That is the question an inspection asks, and no amount of paperwork answers it if the answer is no.
A vacancy advertised at a salary or specification designed not to attract anyone is visible as such. It defeats the purpose of the programme while leaving the shortfall and the penalty intact.
Enrolment and monthly contributions are mandatory, arrears are pursued, and registration also supports the evidence that the employment is genuine.
End-of-service gratuity does not apply to Emirati employees in the same way, because the pension scheme takes its place. Confirm the position rather than accruing both, or neither, by default.
Hiring to a number and providing no role, no manager and no progression produces departures within a year, a renewed shortfall, and a reputation among Emirati candidates that makes the next hire harder. Track retention, not headcount at assessment dates.
A single Emirati employee in an otherwise homogeneous team rarely stays. Where the target requires several hires, sequencing them into the same function tends to work better than scattering them.
Underpaying to meet a headcount number produces turnover, which produces a renewed shortfall. The penalty for an unfilled position is a monthly amount that quickly exceeds the difference between a below-market and a market salary.
Emiratisation obligations attach to mainland establishments at the prescribed thresholds. Free zone, DIFC and ADGM entities are generally outside — but confirm rather than assume, particularly where a group spans both.
An Emirati employed by one establishment counts for that establishment. Groups sometimes assume a group-wide rate applies; it does not, and the shortfall sits with the entity that has it.
Registered contract, WPS payment records, GPSSA contributions, job description, objectives, appraisals and actual work product. This is what answers the fictitious-hire question, and it needs to exist contemporaneously.
Thresholds, target percentages, assessment dates and penalty amounts step up each year. Any figure in a policy document is a snapshot — confirm the current position with MOHRE at the start of each year.
Reflects UAE requirements current as of {{DATE OF USE}}. Emiratisation thresholds and targets, assessment dates, penalty amounts, Nafis support levels, GPSSA contribution rates and the treatment of part-time and flexible arrangements all change — confirm the current position with MOHRE and Nafis, and take advice before relying on any arrangement to meet the quota.
This is a ready-to-use template provided for convenience. Laws and requirements change, and every situation is different — please have it reviewed by a qualified professional (a lawyer, corporate secretary, or accountant as relevant) before you rely on it.