TRW & Co · Employment law
Emiratisation in the UAE: Targets, Nafis and Penalties in 2026
The Emiratisation targets private sector companies with 50 or more staff must meet require a 2% annual rise in Emiratis in skilled roles, checked each half-year, towards a 10% increase by the end of 2026. Shortfalls cost AED 10,000 a month per unfilled role from July 2026. Smaller firms in 14 activities have their own quotas.
Key pointFake Emiratisation now carries fines of AED 100,000 to AED 1,000,000 per worker involved under the 2024 Labour Law amendments, so a genuine hire that leaves early is a far smaller risk than a paper hire that looks compliant.
At a glance
Two percent each year
Companies with 50 or more employees must raise Emiratis in skilled roles by 2% a year, assessed as 1% at each half-year checkpoint.
Contribution from July 2026
MoHRE set a contribution of AED 10,000 per month for each position unfilled against the first-half 2026 target, collected from 1 July 2026.
Smaller companies included
Companies with 20 to 49 employees in 14 activities had to hire one Emirati in 2024 and another in 2025, with contributions for misses.
Emirati minimum wage
Official guidance sets a minimum monthly wage of AED 6,000 for Emiratis in the private sector from 1 January 2026.
Heavy fake-hiring fines
Fictitious employment attracts fines of AED 100,000 to AED 1,000,000 per worker involved, repayment of benefits and possible criminal proceedings.
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The short answer: Emiratisation targets private sector employers face in 2026
As of October 2026, the Emiratisation targets private sector companies with 50 or more employees must meet require a 2% annual increase in UAE nationals in skilled roles, split into 1% for each half of the year, building to the overall 10% increase the programme set for the end of 2026. The first-half 2026 deadline was 30 June; the second-half target falls due at the end of the year.
Companies that miss their numbers pay a monthly financial contribution for every unfilled position. MoHRE announced that from 1 July 2026, shortfalls against the first-half 2026 target attract AED 10,000 per month (AED 120,000 a year) for each Emirati not hired. Smaller companies with 20 to 49 employees in 14 designated activities have had separate hiring obligations since 2024.
This guide explains who is covered, how the numbers are calculated, the penalties for "fake" Emiratisation and a practical plan for the last quarter of 2026 and beyond.
The legal framework and who administers it
Emiratisation is administered by the Ministry of Human Resources and Emiratisation (MoHRE) under the Labour Law and a series of cabinet and ministerial resolutions. The government's page on employing Emiratis in the private sector, updated by MoHRE in October 2026, lists the instruments in force, including resolutions on targets for companies with 20 to 49 workers, monitoring and contributions, compliance rules, administrative penalties and the Emiratisation Partners Club.
Nafis, the federal programme launched as one of the Projects of the 50, supports the targets with salary support, training and a jobs platform that connects employers with Emirati candidates. Nafis benefits are a significant part of the cost equation and are lost if a hire is not genuine.
The targets attach to establishments registered with MoHRE. Entities whose employees are registered only with a free-zone authority, and employers in the DIFC and ADGM, should check their position with MoHRE rather than assume they are inside or outside the scheme.
Who is covered and what each group must do
| Company size | Obligation | Consequence of a shortfall |
|---|---|---|
| 50 or more employees | 2% annual increase in Emiratis in skilled roles, 1% per half-year, towards a 10% overall increase by the end of 2026 | Monthly contribution per unfilled position; MoHRE set AED 10,000 per month for first-half 2026 shortfalls, collected from 1 July 2026 |
| 20 to 49 employees in 14 designated activities | Hire at least one Emirati in 2024 and a second in 2025, and retain them | Contributions of AED 96,000 (collected from January 2025) and AED 108,000 (collected from January 2026) for missed hires |
| Fewer than 20 employees | No general quota, but Emirati hires must still comply with the wage, contract and pension rules | Penalties for non-compliance with those rules and for any fake hiring |
The 14 activities for smaller companies are broad: information and communications; financial and insurance; real estate; professional, scientific and technical; administrative and support services; education; healthcare and social work; arts and entertainment; mining and quarrying; manufacturing; construction; wholesale and retail trade; transportation and warehousing; and hospitality. Most service and trading businesses fall within at least one.
Because Emiratisation targets private sector businesses face differ by size and activity, MoHRE has not, at the time of writing, published on the official page a separate 2026 headcount for the 20 to 49 group equivalent to the 2024 and 2025 steps. Companies in that bracket should check their MoHRE dashboard and any new ministerial resolution before planning 2027 headcount.
How the Emiratisation targets private sector companies must meet are calculated
For larger companies, the percentage applies to skilled roles, not the total workforce. MoHRE classifies jobs by skill level, and only Emiratis in roles at the skilled levels count. A company with 200 skilled employees therefore needs two additional Emiratis for each 1% step, on top of those already employed.
The count is taken from MoHRE records, so an Emirati must hold a valid MoHRE work permit, a MoHRE-compliant contract, be paid through the Wage Protection System and be registered with the pension authority. Government guidance requires pension registration within a month of permit issue.
Since 1 January 2026, the minimum monthly wage for Emiratis in the private sector is AED 6,000 according to the official guidance. A role paid below that, or an Emirati paid less than peers in the same position, creates compliance risk even where the headcount looks right.
Retention counts as much as recruitment. An Emirati who leaves in November reduces your count at the year-end checkpoint, so build a buffer above the strict target and track resignations monthly rather than only at the June and December deadlines.
Hiring versus paying the contribution
Some companies treat the contribution as a cost of doing business. That is a short-sighted reading of the Emiratisation targets private sector rules. The contribution has risen every year, it does not reduce next period's target, and the shortfall carries forward into a larger gap as the percentage climbs.
A genuine hire, by contrast, may qualify for Nafis salary support, builds the count for future checkpoints and can help with government procurement through the Partners Club. When modelling the decision, compare the full contribution for the year with the net cost of a properly supported Emirati hire, including training and retention, rather than salary alone.
A practical compliance plan
A company that will be measured against the Emiratisation targets private sector rules impose should run the exercise as a workforce project with a named owner, not a last-minute recruitment drive.
- Confirm your category. Check headcount, licensed activity and MoHRE registration for each entity in the group. Targets apply per establishment, so a group may have several different obligations.
- Calculate the gap. Count skilled roles, existing Emirati staff in skilled roles and the number of additional hires needed for each half-year deadline, with a buffer for attrition.
- Map the roles. Identify genuine skilled positions that can be filled by Emirati candidates, including graduate and development roles, rather than creating new nominal posts.
- Recruit through Nafis and other channels. Post vacancies on the Nafis platform and assess eligibility for salary support and training programmes before making offers.
- Onboard correctly. Issue the national work permit and MoHRE contract, set pay at or above the Emirati minimum wage, pay through WPS and register with the pension authority within the required period.
- Track and retain. Monitor the Emirati count monthly, run retention and development plans, and report changes that affect Nafis eligibility.
- Document good faith. Keep records of job adverts, interviews and offers, so that you can show genuine efforts if a target is missed and a contribution or instalment plan is discussed with MoHRE.
Penalties for missed targets and fake Emiratisation
Missing a target triggers the financial contribution, which MoHRE has increased year on year since the scheme began. Contributions are calculated per unfilled position, so a large company several hires short can face a significant annual cost. MoHRE has allowed payment in instalments in some cases.
Fake Emiratisation is treated far more seriously. MoHRE describes manipulating targets and fictitious hiring as serious labour market violations, detected through digital monitoring and field inspections. The 2024 amendments to the Labour Law introduced fines in the range of AED 100,000 to AED 1,000,000 for fictitious employment, multiplied by the number of workers involved, together with an obligation to repay government benefits received through the scheme. A criminal case can be opened at MoHRE's request.
Earlier cabinet resolutions also list administrative penalties for related conduct, including evading targets by reducing headcount or reclassifying employees, and fraud to obtain Nafis benefits.
Contracts, probation and exits for Emirati staff
Emirati employees are covered by the same Labour Law as other private-sector staff, with pension coverage replacing end-of-service gratuity. An exit therefore follows the normal rules on notice, investigation and final pay, but it also changes your Emiratisation count the day the permit is cancelled.
Before terminating an Emirati employee, check the effect on the next checkpoint and on any Nafis support, and make sure the reason and process would stand up to scrutiny. A dismissal that looks like a way of replacing a genuine hire with a cheaper nominal one will attract attention.
Incentives for strong performers
The other side of the scheme is the Emiratisation Partners Club. MoHRE has said that companies with outstanding results can receive discounts of up to 80% on MoHRE service fees and priority access to government procurement opportunities. For companies that bid for public contracts, strong Emiratisation performance is therefore a commercial asset, not just a compliance cost.
Responding to a MoHRE notice or inspection
MoHRE monitors compliance through its systems and through field inspections. If you receive a notice about a shortfall or a suspected violation, gather the employment file for each Emirati employee: permit, contract, WPS payments, pension registration, attendance and evidence of actual work. Respond within the time given, with a factual explanation and, if a shortfall is real, a recruitment plan.
Where fictitious employment is alleged, take advice before responding. The 2024 amendments allow a case to be closed before judgment by paying at least half of the minimum fine and returning all financial incentives received, which can be the right outcome where an arrangement was set up by a former manager or an agency without proper oversight.
Illustrative scenario: a mid-sized consultancy
This scenario is illustrative only; the parties are generic. A Dubai mainland engineering consultancy has 150 employees, 120 of them in skilled roles, and three Emirati engineers. In early 2026 it calculates that each 1% step requires roughly one or two more Emiratis in skilled roles, and that one of its existing Emirati engineers has accepted a government job starting in September.
Rather than hire at the last minute, the firm posts two graduate engineer roles on Nafis in March, checks eligibility for salary support, and pairs each hire with a senior mentor. It also opens a role in its procurement team, where an Emirati candidate with relevant experience applies directly.
By 30 June it meets the first-half target with a margin of one hire, which covers the September departure. It keeps a file of every advert, interview and offer. The lesson: the Emiratisation targets private sector employers struggle with most are rarely about the headline percentage; they are about attrition, timing and documentation.
Common mistakes
Counting the wrong roles
The percentage for larger companies applies to skilled roles, and only Emiratis in skilled positions count towards the target. Employers sometimes count Emirati staff in administrative or support roles that MoHRE classifies at a lower skill level, and discover the shortfall only when the contribution is calculated. Map each role against MoHRE's classification early in the year, and check that job titles and duties in the MoHRE contract reflect the real work. Where a role is reclassified, document why, because reclassification to dodge targets is itself a listed violation.
Hiring on paper only
Paying an Emirati to stay at home, or recording a hire with no real job, is fake Emiratisation. It exposes the company to fines that, after the 2024 amendments, can reach AED 1,000,000 per worker involved, plus repayment of Nafis support. MoHRE uses data matching, attendance checks and inspections to find these arrangements. Agencies offering "ready-made" Emiratisation should be treated with suspicion; the liability sits with the employer.
Ignoring the smaller-company rules
Businesses with 20 to 49 employees sometimes assume Emiratisation only affects large employers. If the company operates in one of the 14 designated activities, it has had hiring obligations since 2024, with contributions collected from January 2025 and January 2026 for missed hires. Groups with several small entities need to assess each one separately.
Treating the deadline as the plan
Recruiting in the last weeks before 30 June or 31 December leaves no room for failed offers, notice periods or resignations. Build a rolling plan with recruitment starting at least a quarter ahead of each checkpoint, and keep a buffer above the strict number.
Group and cross-border considerations
Emiratisation targets private sector groups face are set per UAE establishment, not per group. International groups often run UAE headcount from London, Singapore, Riyadh or Dhaka. Saudi Arabia's Nitaqat and other GCC nationalisation schemes work on different bases, so a single regional policy rarely fits. Plan UAE Emiratisation entity by entity, and align it with global grading so that Emirati hires have real career paths.
Secondees and intra-group transfers also affect counts and visa arrangements. Our cross-border workforce planning team coordinates headcount, work permits and immigration status across entities.
Checklist for the rest of 2026
Use this list to prepare for the year-end checkpoint and for whatever Emiratisation targets private sector employers are set for 2027 and beyond.
- Confirm each entity's MoHRE category and headcount.
- Recalculate your second-half 2026 target, with a buffer for attrition.
- Check that every Emirati employee is paid at least the Emirati minimum wage through WPS and registered for pension.
- Review job classifications against MoHRE skill levels.
- Use Nafis for recruitment and check salary-support eligibility.
- Keep evidence of genuine recruitment efforts.
- Watch for MoHRE announcements on targets beyond 2026.
TRW & Co advises on Emiratisation compliance, audits workforce data through our immigration and HR compliance audits, and tracks rule changes in our labour law amendments briefing. Where an exit affects your count, see our guide to termination of employment. To plan your next checkpoint, contact TRW & Co.
Frequently asked questions
01What is the Emiratisation target for 2026?
For private companies with 50 or more employees, the target is a 2% annual increase in UAE nationals in skilled roles, assessed as 1% by 30 June and a further 1% by the end of the year. This is the final year of the programme step that builds to a 10% overall increase by the end of 2026. Companies with 20 to 49 employees in designated activities have separate obligations; check MoHRE for their 2026 position.
02What is the penalty for not meeting Emiratisation targets?
Companies that miss their target pay a financial contribution for each unfilled position. MoHRE announced that from 1 July 2026, shortfalls against the first-half 2026 target attract AED 10,000 per month, or AED 120,000 a year, per Emirati not hired. For companies with 20 to 49 employees, the contributions for missed 2024 and 2025 hires were AED 96,000 and AED 108,000 respectively. Fake Emiratisation is penalised separately and far more heavily.
03Do Emiratisation rules apply to free zone companies?
The targets attach to establishments registered with MoHRE. Many free-zone employers register their staff only with the free-zone authority, and the DIFC and ADGM operate their own employment regimes, so the position varies. Do not assume either way: confirm with MoHRE whether each of your entities is covered, especially if any of them holds a mainland licence or MoHRE establishment card.
04What is fake Emiratisation and how is it penalised?
Fake Emiratisation means recording Emirati employees who do not genuinely work, or manipulating records to appear compliant, often to obtain Nafis support or avoid contributions. Following the 2024 Labour Law amendments, fictitious employment attracts fines of AED 100,000 to AED 1,000,000, multiplied by the number of workers involved, plus repayment of benefits received. MoHRE can also request a criminal case.
05What is the minimum salary for Emiratis in the private sector?
Official government guidance states that the minimum monthly wage for UAE nationals in the private sector is AED 6,000, effective from 1 January 2026. Employers must also pay Emiratis no less than colleagues in the same role, pay through the Wage Protection System and register them with the pension authority. Paying below the minimum puts both the hire and the target count at risk.
06How does Nafis help employers?
Nafis is the federal programme supporting Emirati employment in the private sector. It runs a jobs platform where employers can find Emirati candidates and offers support schemes, including salary support and training, subject to eligibility rules. Employers must not deduct salary because an employee receives government support, and must report changes affecting eligibility. Benefits are clawed back if a hire proves to be fictitious.
Sources and official materials
- Employing Emiratis in the private sector — Official targets, contributions, minimum wage and penalty resolutions
- Ministry of Human Resources and Emiratisation — Regulator administering targets and contributions
- Federal Decree-Law No. 33 of 2021 and its amendments — Labour Law including penalties for fictitious employment
- Projects of the 50: second set — Background to the Nafis programme
General information only, current as at 27 October 2026. It is not legal advice and does not create a lawyer–client relationship. UAE law differs between the onshore jurisdiction, the DIFC, ADGM and the free zones, and changes frequently; check current official sources and take advice on the facts of your matter.
