Author
Omar Sami
Attorney at Law (Germany) I Legal and Tax Consultant (UAE) I Managing Partner
October 2026 – Employment Law – Compliance
According to media reports, the Ministry of Human Resources and Emiratisation (MoHRE) detected 377 cases of fake Emiratisation at 266 private companies in the first half of 2026 and has taken legal action. Companies involved reportedly face fines of up to AED 500,000. At the same time, the ministry is increasingly relying on AI-assisted inspections to monitor compliance.
Fake Emiratisation describes a situation where a company meets the mandatory Emiratisation quota on paper only: UAE nationals are registered or hired without any genuine employment relationship. For private companies in the UAE this is a compliance risk that has risen noticeably with the current enforcement drive.
This article explains what counts as fake Emiratisation, what the latest figures mean, which sanctions are in play, and what steps companies should take now.
Background: Emiratisation in the Private Sector
Private companies in the UAE must gradually increase the share of Emirati employees in skilled roles. Under the published requirements, companies with at least 50 employees must raise this share by 2 per cent a year, targeting 10 per cent by the end of 2026. Compliance is checked at fixed reference dates, including 30 June. The employment of Emirati professionals in the private sector is supported through the government programme Nafis.
Expansion of the Emiratisation targets (Companies with 20 to 49 workers)
Since 2024, private sector companies with a workforce of 20 to 49 workers were required to hire at least one UAE citizen by end of 2024. Additionally, they were required to hire one more Emirati by end of 2025.
What Counts as Fake Emiratisation?
The term covers situations where the quota appears to be met without Emirati staff actually being employed. Typical examples include:
- UAE nationals are registered as employees but perform no actual work
- Salaries are shown on paper only, or flow back to the company or third parties
- The actual role or pay differs materially from what has been reported
- Positions are filled only for the inspection date and abandoned afterwards
- Intermediaries offer quota compliance as a ready-made package for a fee
The Latest Figures: 377 Cases at 266 Companies
On 22 September 2026 it was reported that MoHRE had identified 377 cases of fake Emiratisation at 266 private companies in the first half of 2026. Legal action has been taken against the companies concerned.
| Key figure | Detail |
|---|---|
| Period | First half of 2026 |
| Cases identified | 377 |
| Private companies affected | 266 |
| Responsible authority | Ministry of Human Resources and Emiratisation (MoHRE) |
| Action taken | Legal action against the companies concerned |
What Penalties Apply?
According to media reports on the current enforcement drive, companies engaging in fake Emiratisation face fines of up to AED 500,000. In earlier enforcement rounds, fines of between AED 20,000 and AED 100,000 per case were reported.
| Penalty framework | Detail |
|---|---|
| Maximum currently reported | Up to AED 500,000 |
| Reported in earlier enforcement rounds | AED 20,000 to AED 100,000 per case |
| Further measures | Legal action by MoHRE; further sanctions depending on the case |
Note: The amounts stated are based on media reports. The applicable legal provisions and MoHRE’s decision in each individual case are decisive. The specific penalty framework should be checked before any decision is taken.
Further Consequences and Stricter Monitoring
Beyond fines, companies should factor in the following risks:
- In serious cases, referral to the judicial authorities cannot be ruled out
- Loss of benefits and incentives that depend on proper Emiratisation
- Reputational risk with clients, banks and authorities
MoHRE is reportedly making increasing use of AI-assisted inspections. Companies should therefore assume that discrepancies between reported employment and actual practice are more likely to be detected than before.
What Companies Should Do Now
- Review your records. Compare every Emirati employee in your filings with the actual employment: position, duties, place of work and pay.
- Evidence genuine employment. Keep employment contracts, job descriptions, payslips and proof of actual work well organised and ready.
- Check salary payments. Make sure salaries are paid in full and traceably through the Wage Protection System (WPS), with no money flowing back.
- Review service providers and recruiters. Examine agreements with recruiters and advisers who offer Emiratisation as a package, and end risky arrangements.
- Introduce internal policies. Define clear responsibilities, review steps before each reference date and an internal channel for raising concerns.
- Take advice early if authorities make contact. Respond to MoHRE enquiries or notices within the deadline and have your position reviewed legally before you submit a response.
Frequently Asked Questions
Does the Emiratisation quota also apply to free zone companies?
The quota rules are aimed primarily at private companies within MoHRE’s remit. Free zones such as DIFC and ADGM often have their own employment frameworks. Whether and to what extent your company is covered depends on its location and licence and should be checked case by case.
Is the company still liable if a recruiter arranged the Emiratisation?
Responsibility for the accuracy of the reported employment relationships lies with the company. Using a recruiter does not generally change that, although it may be relevant to claims against the recruiter in an individual case.
Is it enough to meet the quota on the reference date?
No. What matters is that the employment is genuine and lasting. Positions that are filled only on the inspection date are a typical warning sign.
What is Nafis?
Nafis is the UAE government programme that supports the employment of Emirati professionals in the private sector.
How TME Legal Can Help
TME Legal advises companies in the UAE on employment-law compliance in connection with Emiratisation. Our services in this area include:
- Reviewing Emiratisation status and the underlying employment evidence
- Reviewing employment contracts, payroll records and salary payment processes
- Assessing agreements with recruiters and service providers
- Developing internal compliance policies and review procedures
- Supporting you with MoHRE enquiries, inspections and proceedings
If you would like to discuss your company’s Emiratisation compliance, we would be glad to help.
This article is for general information only and does not constitute legal advice. It is based on public reports as at September 2026; MoHRE’s requirements and enforcement practice continue to evolve. Please contact TME Legal for advice tailored to your individual situation.
