Force majeure and UAE labor law in the Iran conflict: Guidelines for employers

The employment impact of a war-driven security situation rarely ends with the event itself. It typically leads to workplace access restrictions, staff safety concerns, transport disruption, and sudden changes to work organization. In this context, MOHRE publicly recommended remote work for private-sector employers wherever feasible for 1–3 March 2026.

Employers may instinctively label such disruption as force majeure and assume that performance and pay obligations are automatically suspended. Under UAE law, that is risky. Employment relationships remain governed primarily by Federal Decree-Law No. 33 of 2021 and Cabinet Resolution No. 1 of 2022. These rules tend to preserve employer obligations and push employers toward continuity measures such as remote work and structured leave rather than automatic suspension.

Force majeure under UAE law is rooted in the Civil Code and turns on impossibility, not mere inconvenience. The key provision is Article 273, which provides that where force majeure makes performance impossible in a bilateral contract, the corresponding obligation ceases and the contract is automatically rescinded. Partial or temporary impossibility may have more limited effects.

This approach is reinforced by Article 287, which excludes liability where loss is caused by matters beyond a party’s control, including force majeure; Article 386, which limits damages where performance becomes impossible for reasons outside the obligor’s control; and Article 472, under which a right is extinguished if performance becomes impossible for such reasons.

A useful comparison is the recent flooding disruption in Dubai 2024. That event likewise showed that an external event beyond the parties’ control does not automatically suspend all obligations as a matter of law. Rather, the legal question remains whether performance became genuinely impossible, wholly or partly, or whether work could still continue through remote arrangements, relocation, or operational reorganization. In this respect, both conflict-related disruptions and severe flooding illustrate the same principle under UAE law: force majeure is assessed on the basis of actual impossibility, rather than mere substantial operational difficulty.

In a conflict scenario, war, attacks, airspace restrictions, or site closures may qualify as external causes beyond the parties’ control. But the legal question remains specific: what exactly became impossible, for whom, and for how long? If on-site attendance is prevented, there may be temporary impossibility of physical performance. If work can continue remotely or from another location, performance may still be possible. That distinction is critical.

For employers, the labour-law analysis begins with wage and work-enablement obligations. Under the Executive Regulations, if an employer does not enable an employee to work, the employer generally remains obliged to pay the agreed wage. This remains important even where the reason is outside the employer’s will.

That means Civil Code force majeure concepts do not automatically override labour-law duties. Articles 273, 287, 386 and 472 may help classify the event and frame liability issues, but they do not by themselves entitle an employer to suspend wages.

The Executive Regulations also recognize remote work as a lawful work model. In practice, that makes remote work the first compliance tool in a crisis. They also contain an Emergency Situations mechanism under which remote work, leave, unpaid leave, or wage reduction may be used in formally declared emergency situations. Employers should therefore treat any pay-impacting measure as legally sensitive and not as an ad hoc response to conflict headlines.

Documentation is legal risk control. Employers should keep a clear evidence pack including the internal decision timeline, official guidance relied on, records of closures or access restrictions, remote-work implementation, and employee communications.

That material is essential both for labour-law compliance and for any later reliance on Articles 273, 287, 386 or 472. Employers should be able to show not just that a regional conflict existed, but that a specific external event made performance impossible in whole or in part, and that reasonable alternatives were assessed first.

This means that the employer is obliged to prove the existence of force majeure and the resulting impossibility of performance. Only if the employer fulfills its documentation and evidence obligations can it be exonerated from its obligation to pay wages. This is particularly the case if the government issues a warning of military attacks, the population is urged not to leave their homes, and remote work is not possible. It should be noted here that the employer’s obligation to pay wages only ceases to apply for the individual periods during which it is impossible to perform work.

During periods in which the government has not issued a warning of danger to public safety, the employee is obliged to offer his or her services. If the employee decides not to come to work on his or her own responsibility, he or she is not fulfilling his or her obligation to perform work. Consequently, he or she is then not entitled to payment of wages.

The Iran conflict creates a credible basis for force majeure language in general legal terms. Under the UAE Civil Code, Articles 273, 287, 386 and 472 recognize that obligations may cease, rights may be extinguished, and liability may be excluded where performance becomes impossible due to causes beyond a party’s control.

In employment matters, however, those principles do not automatically suspend employer obligations. UAE labour law remains the primary framework, and wage risk will often remain with the employer where work is not enabled, even if the cause is external. The safest approach is therefore to protect safety, enable work where possible, document decisions carefully, and treat any pay-impacting measure as requiring a clear legal basis.