Guest Articles

1. Policies, Procedures and Workforce Readiness

A review of HR employment policies should extend beyond updating documents. Employers should ensure that policies are distributed and supported by regular training. Key areas include disciplinary procedures, grievance processes, anti-harassment policies, leave management, flexible working and data protection. Effective communication and training reduce legal risk and create consistency across the workforce.

2. Working Time, Rest Periods and Burnout Prevention

A final quarter audit of key governance areas should include a specific focus on employee welfare, particularly working time, rest periods and burnout prevention. The UAE Labour Law contains clear rules governing working time and, as a general rule, employees are not permitted to work more than eight hours per day or 48 hours per week unless an exemption applies. The law requires at least one weekly rest day and employees should benefit from adequate rest periods between working days. Industries which operate using shift patterns, such as hospitality, retail, healthcare and construction, should review shift patterns carefully to ensure compliance, particularly during peak periods. Employers should also monitor overtime, manager workloads and annual leave utilisation to minimise burnout, support employee wellbeing and maintain productivity.

3. Rehiring Talent and Compensation review

As businesses move from the quieter summer period into the final quarter, this is often the season when employers reassess headcount, review budgets and consider remuneration for the year ahead. For organisations that reduced headcount earlier in the year, particularly in sectors that rely on tourism and events, Q4 may also present an opportunity to reconnect with former employees who possess institutional knowledge and proven performance records. Forward-thinking recruitment initiatives may include practical incentives for re-engagement, such as recognition of previous service, waiving probation periods where appropriate, accelerated promotion pathways, retention bonuses and competitive compensation packages. At the same time, employers should use annual compensation reviews to ensure that salary increments,

bonus arrangements and changes to allowances are clearly documented and communicated. Any change to an employee’s compensation should be recorded carefully, as basic salary is relevant to the calculation of end-of-service gratuity and may also affect the value of final severance payments. Disputes often arise where increases, allowances, discretionary bonuses or revised remuneration structures are agreed informally, inconsistently reflected in payroll, or not properly captured in employment contracts or amendment letters. Rehiring and compensation strategies should therefore be documented carefully and reflected accurately in employment contracts, offer letters and payroll records, particularly in relation to recognition of earlier service, seniority, basic salary, allowances, bonus eligibility and any conditions attached to variable pay.

4. Emiratisation: Compliance and Retention

Emiratisation remains a strategic and regulatory priority in the UAE private sector. Employers should assess whether they are on track to meet applicable Emiratisation targets before year-end, particularly where the business falls within the mandatory quota regime. Private sector companies with 50 or more employees are generally required to increase the number of UAE nationals in skilled roles by 2% annually, with an overall target of 10% Emiratisation by the end of 2026. Smaller employers with 20 to 49 employees operating in specified sectors should also check whether they are subject to the requirement to recruit and retain UAE nationals. Failure to meet the applicable targets can lead to significant financial contributions, including monthly amounts payable for each unfilled Emirati position, which increase annually. Employers should also be mindful that attempted circumvention, including “fake Emiratisation”, can attract further enforcement action and reputational risk.

In practical terms, employers should use the Nafis platform not only as a recruitment tool, but also as part of a wider workforce planning and retention strategy. Nafis can assist businesses in identifying UAE national candidates across different specialisations and may support employers through initiatives linked to training, salary support and private sector integration. A focused Q4 review should therefore consider whether the organisation has an accurate headcount calculation, whether qualifying UAE national employees are properly registered and retained, whether replacement plans are in place if UAE national employees resign and whether the business has sufficient evidence to demonstrate genuine employment, meaningful duties and payroll compliance.

5. Wage Protection System Compliance

Recent developments in Wage Protection System (WPS) compliance highlight the importance of payroll accuracy and timeliness. Ministerial Resolution No. 340 of 2026 concerning the Wage Protection System came into effect on 1 June 2026 and introduced a stricter framework for private sector employers registered with MOHRE. Under the Resolution, wages for the previous calendar month are due on the first day of each month and any payment made after that date is treated as delayed. Employers should regularly audit payroll processes, confirm salary transfer

arrangements through WPS or other MOHRE-approved systems, and ensure that internal finance and HR teams are aligned. Delays can lead to operational disruption, regulatory consequences and employee relations concerns, including electronic notifications, suspension of new work permits, administrative blocks on the company portal and potential escalation for repeated non-compliance. WPS compliance should therefore form part of every year-end legal health check.

Key Takeaways for HR Managers and Business Leaders

The final quarter should be viewed as more than a race to achieve business targets. It is an opportunity to strengthen governance, reinforce workplace culture and ensure compliance before entering a new year. By reviewing policies, validating working time arrangements, implementing strategic rehiring initiatives, focusing on Emiratisation retention and maintaining payroll compliance, employers can position themselves for a successful and legally compliant year-end.

Author: Thenji Moyo, Partner at Gateley Middle East