Using workers supplied by another company does not transfer the exposure. **The people are on someone else’s permit but working at your site**, and if their wages go unpaid, their permits are invalid, or the supplier is unlicensed, it becomes your problem — commercially, reputationally, and sometimes legally.
Outsourced Labour
Manpower supply, agency workers and contractors on site
Using workers supplied by another company does not transfer the exposure. The people are on someone else’s permit but working at your site, and if their wages go unpaid, their permits are invalid, or the supplier is unlicensed, it becomes your problem — commercially, reputationally, and sometimes legally.
| Item | Detail |
|---|---|
| Client | [COMPANY NAME], [licence] [NUMBER] |
| Supplier | [NAME], licence [NUMBER] |
| Licensed for manpower supply? | [Y/N] — a specific activity, not general contracting |
| Workers supplied | [NUMBER] |
| Roles | [DESCRIBE] |
| Site | [ADDRESS] |
| Period | [DATE] to [DATE] |
| Charge | AED [AMOUNT] per [worker per month] |
| Employer of the workers | The Supplier |
| Reviewed | [DATE] |
1. Before Engaging a Supplier
| # | Check | Why | Done |
|---|---|---|---|
| 1 | Licensed specifically for manpower supply | A general contracting licence does not cover it | [Y/N] |
| 2 | Workers hold valid permits with the Supplier | Your site, your exposure | [Y/N] |
| 3 | Permit job titles match the work being done | A mismatch is a contravention | [Y/N] |
| 4 | Supplier pays wages through WPS | Ask for evidence, not assurance | [Y/N] |
| 5 | Workers have health insurance | Mandatory | [Y/N] |
| 6 | Supplier does not charge the workers any fee | Unlawful — and it happens | [Y/N] |
| 7 | Supplier does not hold worker passports | Prohibited | [Y/N] |
| 8 | Accommodation, where provided, meets requirements | Reputational as well as legal | [Y/N] |
| 9 | Work injury and public liability insurance in force | Evidence, not a promise | [Y/N] |
| 10 | Supplier’s own compliance record checked | Bans and penalties | [Y/N] |
| 11 | Right to audit agreed | Section 4 | [Y/N] |
| 12 | Charge is arm’s length if the Supplier is connected | Transfer pricing | [Y/N] |
1.1Check 6 is the one nobody asks. Workers recruited overseas are sometimes charged fees by agents in their home country — unlawful here, invisible to the client, and precisely the practice a client’s own standards should be checking for.
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The workers are on someone else’s permit but working at your site under your direction. If wages go unpaid, permits are invalid or the supplier is unlicensed, the consequences reach you commercially and reputationally, and sometimes legally.
It is a distinct activity. A general contracting or services licence does not cover supplying labour, and engaging an unlicensed supplier puts the whole arrangement outside the permitted framework.
A supplier confirming that it pays its workers is worth little. Evidence of actual WPS submission and payment for the workers on your site is checkable, and requesting it quarterly changes behaviour.
Charging recruitment or permit fees to workers and retaining passports are both unlawful, both invisible in documentation, and both obvious to the workers themselves. Ask them, through someone who speaks their language. It is the only check that finds this.
You control the site, the work and the conditions. A worker injured on your premises is your incident to prevent, report and investigate regardless of who employs them, and the midday ban applies at your site.
Raise concerns with the supplier and let them act. Disciplining, dismissing or selecting individuals yourself is how a supply arrangement becomes an employment relationship in substance, at which point the permit position is wrong.
Setting pay, appraising, giving company email and titles, and long-term exclusive engagement all point one way. Where several apply, the person is effectively working for an entity that does not hold their permit.
Paying for more workers than are actually on site is common and is discovered only by counting. It is also the check that reveals when workers have quietly left without being replaced.
Worker accommodation standards are both a legal and a reputational matter, and a client is judged by the conditions of the people working on its site. An annual inspection is not intrusive; it is due diligence.
A supplier with permit bans or wage penalties will pass those problems to you as an interruption of supply. Check before engaging and periodically after.
An indemnity against claims that you are the employer is worth having, but an indemnity from an insolvent supplier is worth nothing and it does not answer a regulatory finding or a reputational problem.
And they are on your site. The commercial claim is between you and the supplier; the human and reputational consequence is immediate and visible. Monitor the supplier’s stability, not just its paperwork.
Where the manpower supplier is a group company, the charge is a related party transaction requiring arm’s length pricing and documentation, and for a free zone supplier it may be non-qualifying revenue.
Unpaid wages reported by workers on your site is the most serious thing in this document. Raise it, require evidence, and escalate. Treating it as the supplier’s problem to resolve in due course is not an adequate response.
Reflects UAE law current as of {{DATE OF USE}}. Manpower supply licensing, permit requirements, WPS rules, the prohibition on charging workers fees, passport retention rules, accommodation standards and safety obligations all change — confirm with MOHRE before engaging a labour supplier.
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.