This is the compliance obligation with the sharpest teeth in UAE employment law. Penalties accrue **monthly per unfilled position** and rise each year, and Federal Decree-Law 9 of 2024 added penalties of AED 100,000 to AED 1,000,000 per fictitious hire for collusion — with inspectors able to examine bank records to verify that salaries actually landed.
Emiratisation Compliance
Nafis targets, tracking and penalties
This is the compliance obligation with the sharpest teeth in UAE employment law. Penalties accrue monthly per unfilled position and rise each year, and Federal Decree-Law 9 of 2024 added penalties of AED 100,000 to AED 1,000,000 per fictitious hire for collusion — with inspectors able to examine bank records to verify that salaries actually landed.
| Item | Detail |
|---|---|
| Establishment | [COMPANY NAME], MOHRE establishment [NUMBER] |
| Jurisdiction | Mainland — Emiratisation generally does not apply to free zone, DIFC or ADGM entities |
| Sector | [SECTOR] — some sectors carry additional targets |
| Total employees | [NUMBER] |
| Skilled employees (ISCO levels 1–5) | [NUMBER] — the quota base |
| Emiratis currently employed | [NUMBER] |
| Current Emiratisation rate | [PERCENTAGE] |
| Target at the next assessment date | [PERCENTAGE] |
| Shortfall in positions | [NUMBER] |
| Estimated monthly exposure | AED [AMOUNT] |
| Nafis registration | [Registered on ______ ] |
| Responsible officer | [NAME], [DESIGNATION] |
1. Who the Targets Apply To
| Establishment size | Obligation | Note |
|---|---|---|
| 50 or more employees | Percentage target of skilled roles, increasing annually | Assessed at set dates; 8% by end-2025 rising to 10% by end-2026 on the published trajectory |
| 20 to 49 employees | A fixed number of Emirati hires rather than a percentage | One by end-2024 and a further one by end-2025 on the published trajectory |
| Fewer than 20 employees | Generally outside the quota | Confirm — sector rules may still apply |
| Banking, insurance and financial services | Additional sector-specific targets | Higher than the general trajectory |
| Free zone entities | Generally outside the regime | Confirm with the zone |
| DIFC and ADGM | Outside the regime |
1.1The quota base is skilled roles, classified by MOHRE skill levels 1 to 5 — legislators, managers, professionals and technicians. Unskilled and semi-skilled roles do not count towards the base.
1.2Verify the current target percentage and the assessment date before relying on any figure. The trajectory has moved and the published targets step up annually.
2. Tracking
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MOHRE assesses compliance from its own data. Penalties accrue monthly per unfilled position without anyone filing anything. A company that has drifted out of compliance typically finds out when the charge appears, not before.
The target applies to skilled positions at MOHRE levels 1 to 5 — legislators, managers, professionals and technicians. Companies computing against total headcount reach the wrong number in both directions. Map every role to a level and keep the mapping current.
Each additional skilled non-Emirati hire increases the base and therefore the number of Emiratis required. A fast-growing company can fall out of compliance without losing a single Emirati employee. Model the target against the hiring plan, not against today’s headcount.
Federal Decree-Law 9 of 2024 introduced penalties of AED 100,000 to AED 1,000,000 per fictitious hire, and inspectors can pull bank records to verify salaries were actually received and retained. Arrangements that create a record without genuine employment are detectable and are being prosecuted.
An Emirati employed below the applicable minimum salary may not count towards the quota, and non-compliance can lead to suspension of new work permits at the establishment file. Confirm the current minimum before making the offer, not after.
Meeting a target once is a recruitment problem. Holding it is a retention problem, and Emirati turnover in the private sector is where most programmes fail. Onboarding, development and a visible progression path do more for the number than another recruitment campaign.
Emirati employees participate in the pension system with employer and employee contributions, on a basis revised for those hired from October 2023. This is a real cost that does not apply to expatriate staff and should be in the hiring model from the start.
Banking, insurance and financial services carry additional sector-specific requirements beyond the general trajectory. Confirm what applies to your activity rather than assuming the general position is the whole obligation.
The regime attaches to mainland establishments. Free zone, DIFC and ADGM entities are generally not subject to it — which is a genuine cost difference that belongs in the jurisdiction decision at incorporation.
The single most useful control is a monthly recalculation of skilled headcount, rate and gap. Companies that check annually discover a shortfall they have no time to fix and a penalty that has already accrued.
Nafis registration, an accurate establishment profile and current vacancies are the mechanics of the system. A company that has not registered cannot demonstrate effort and cannot access the support available.
The percentage trajectory increases annually and the penalty per position rises each year. Any figure in this document is a snapshot. Confirm the current target, assessment date and penalty rate with MOHRE at the start of each year.
Where a target is genuinely difficult to meet for a specialist role, a record of advertising through Nafis, candidates considered and offers made is materially better than nothing. It does not remove the penalty, but it distinguishes a company trying from one that is not.
A company three positions short for a year faces a six-figure charge. That number belongs in the financial plan alongside the cost of the hires that would avoid it — and the hires are usually cheaper.
Reflects UAE requirements current as of {{DATE OF USE}}. Emiratisation targets, assessment dates, penalty rates, minimum salary thresholds and sector-specific requirements all change annually — confirm every figure with MOHRE or the Nafis platform before relying on it, and take advice on any arrangement that is not a straightforward direct hire.
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.