UAE private sector employees should prepare for MoHRE inspections
The Ministry of Human Resources & Emiratisation (MoHRE) has ramped up its programme of on-site inspections, both in frequency and scope, across the UAE’s private sector.
In 2023, the MoHRE conducted over 430,000 office inspections and flagged over 75,000 violations. The number of inspections rose to 668,000 in 2024. In the first half of 2025, the MoHRE conducted around 285,000 inspection visits and over 5,400 employers were found to be in breach of local regulations.
The MoHRE said these violations were primarily centred on non-compliance with wage payments, ‘fake Emiratisation’, failure to engage in the licensed activity, and registering workers without a genuine employment relationship.
The level of scrutiny has also increased. Employers are now being asked to provide evidence of who is working on site and in what capacity, including employee lists, employment contracts, annual leave records and proof of wage payments.
It is becoming clear that compliance is no longer just about ensuring you have the right paperwork, it is also necessary to demonstrate that employment relationships are genuine, that working conditions meet all the legal requirements and that employment is properly aligned with the licensed activity.
The UAE has been promoting efforts to integrate Emirati citizens into the private sector, a key pillar of its broader economic strategy aimed at building a more balanced labour market and achieving sustainable development.
The Nafis programme was introduced in September 2021 to ensure that Emiratis employees should increase to at least 10% of the private sector workforce over a five-year period. Employers in the UAE with at least 50 members of staff were required to meet a 4% target by the end of 2023, 6% by the end of 2024, 8% by the end of 2025 and 10% by the end of 2026.
In 2023, the government further expanded the Emiratisation campaign by directing that businesses employing between 20 and 49 people should have at least one Emirati staff member by the end of 2024, and two by the end of 2025.
The number of Emirati citizens working in the private sector reached 100,000 in May 2024 and rose to over 156,000 in October 2025. The MoHRE’s inspections are the main mechanism to ensure that the roles offered to Emirati’s are real, properly documented and legally compliant.
One of the main drivers of the MoHRE’s enhanced inspection programme is that it is increasingly data driven – inspections are often triggered by patterns and risk indicators, rather than random checks. The MoHRE’s Smart Inspection System (SIS) uses a risk matrix to analyse company data, classify establishments by risk level and sets priorities for inspectors.
In June 2025, the MoHRE said that SIS had detected around 1,800 employers who were not effectively practicing their licensed activities despite having registered workers without a genuine employment relationship. This resulted in fines totalling more than AED34 million (c. USD9.25 million), along with restrictions such as suspending new work permits.
What to look out for and how to be prepared?
Private sector employers in the UAE need to be aware that both the frequency and scope of the MoHRE’s programme of on-site inspections has risen. Businesses now need to verify who their active employees are, whether they are working physically on the premises or remotely, and whether their job titles and duties reflect the actual role being performed.
Employment contracts now matter more than ever because they are the baseline record for what the business states about the employment relationship. Salary slips or any other evidence confirming that salary was paid are also essential to evidence that wages are being paid correctly and on time through the correct channels, while leave records are a clear indicator of whether statutory entitlements of paid annual leave, sick leave and other leave entitlements are being provided to employees.
To prepare for the MoHRE inspections, employers must therefore ensure that they have clear documentation on their employees from the Ministry of Labour, that they maintain employment contracts and amendments, that they retain payslips to demonstrate wages are paid for the right amounts and at the right times, especially for those where the Wage Protection System (WPS) applies, and that they show leave approvals and balances in a way that is easy to follow and understand.
To help navigate these complex requirements, we list below some of the documents that employers are frequently asked for:
- Company trade licence.
- Establishment card.
- VAT certificate.
- Evidence of employee time attendance (sign in/out).
- Evidence that employees are working – email and teams exchange may be required.
- Labour card / MOHRE contract copy.
- Visibility of leave and absences records.
- Evidence of final settlement calculation and proof of payment for past employees.
- Evidence of General Pension & Social Security Authority (GPSSA) registration and contribution payments for Emirati nationals.
It should be noted that MoHRE inspectors may request to speak with Emirati nationals to ensure that the employment relationship is genuine, that working conditions meet all the legal requirements and that employment is properly aligned with the licensed activity. In the case of any work-related injuries, they may also request to speak with the injured employee.
