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We've Been Fined for Missing Emiratisation Targets

“We've been fined for missing Emiratisation targets, and we need to understand our actual options.”

Emiratisation targets are a mainland-only federal workforce policy requiring qualifying private companies to grow the share of UAE nationals in skilled roles, and missing the target triggers an automatic monthly financial penalty rather than a discretionary one.

This is an employer-side problem, and it's one where the geography matters immediately: Emiratisation targets apply only to mainland companies of a qualifying size. If your business is in DIFC or ADGM, this specific penalty shouldn't apply to you at all, and confirming that is often the first useful step. LEXNOVA can help you describe your situation and connect with a lawyer who handles Emiratisation compliance and MOHRE fine disputes — every match is reviewed by a person.

LAST REVIEWED 21 SEPTEMBER 2026

WHERE THIS IS HANDLED

MOHRE, including its Emiratisation compliance and fine-appeal channels.

How the answer changes by jurisdiction

  • Dubai mainland

    Emiratisation targets apply to qualifying mainland companies — MOHRE guidance sets a target of 2% annual growth in skilled Emirati roles for companies with 50 or more employees, cumulative to 10% across 2022–2026. Missing the target for the relevant period triggers the monthly penalty.

  • Abu Dhabi mainland

    The same federal framework applies identically to qualifying Abu Dhabi mainland companies — this is not a Dubai-specific policy, and Abu Dhabi mainland employers face the same targets and penalty structure.

  • DIFC

    MOHRE's Emiratisation guidance does not expressly name DIFC as covered, and DIFC has its own employment law and courts; the federal employment law itself contains no free-zone carve-out. A DIFC-registered company should confirm its specific position directly rather than assume either way, but the general position is that this obligation targets mainland companies.

  • ADGM

    The same position as DIFC applies — Emiratisation targets are built around the mainland regime, and ADGM companies fall outside their express scope, though confirming your company's specific position is worth doing rather than assuming.

WHAT YOU CAN DO NEXT

STEP 01

Confirm the fine is correctly calculated and correctly applies to you

Check your company's headcount band, its mainland status, and MOHRE's stated basis for the fine against your own records. Errors in headcount classification or in which reporting period is being penalised do happen and are worth checking before assuming the fine is right as issued.

STEP 02

Understand how the penalty escalates

The fine is charged per unfilled skilled role, per month, and the per-role monthly rate has increased year over year — MOHRE's guidance puts the 2025 annual rate at AED 108,000 and the 2026 rate at AED 120,000 per unfilled role (AED 10,000 per month). This is a recurring, not one-off, cost until the target is met or the position is filled.

STEP 03

Check whether you're in the 50+ employee band or a smaller qualifying band

Companies with 50 or more employees follow the 2% annual growth target. Companies in the 20–49 employee band are understood to follow a different, fixed mechanism, though the specific fine figures for that band are not consistently confirmed across official sources — verify your company's exact obligation directly with MOHRE rather than relying on secondary guidance.

STEP 04

Look into NAFIS and genuine hiring progress as the real fix

The underlying way to stop the fine recurring is to make genuine progress against the target, and MOHRE's NAFIS programme offers support — including salary support schemes — for hiring and retaining Emirati talent, which can materially change the economics of compliance versus paying the fine repeatedly.

STEP 05

Ask about appeal or instalment options rather than assuming the fine is final

MOHRE has channels for querying or appealing a fine and, in some circumstances, arranging payment over time — this is worth raising promptly rather than simply paying or ignoring the notice.

STEP 06

Get specialist advice if 'fictitious Emiratisation' concerns come up

Hiring Emirati nationals into roles that don't reflect genuine employment, sometimes called fictitious Emiratisation, is treated as a serious compliance breach in its own right, separate from an ordinary missed-target fine, and carries its own risk — if this is anywhere near your situation, get advice before making any change to your workforce records.

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FAQ

MOHRE's guidance is built around the mainland framework and doesn't expressly name DIFC or ADGM as covered, consistent with DIFC and ADGM having their own employment laws and courts — the federal employment law itself contains no free-zone carve-out. It's still worth confirming your company's specific position directly rather than assuming either way.

MOHRE's guidance sets 2% annual growth in skilled Emirati roles for mainland companies with 50 or more employees, building cumulatively to 10% across the 2022–2026 period — it isn't a flat 10% target applied all at once.

MOHRE's guidance puts the fine at AED 10,000 per month per unfilled skilled role in 2026 — AED 120,000 for the year if the role stays unfilled — up from an AED 108,000 annual rate in 2025. The rate has increased year over year.

It's a recurring monthly charge for as long as the target position remains unfilled, not a single fixed fine — which is exactly why addressing the underlying hiring gap tends to be more cost-effective than treating the fine as a cost of doing business.

Companies with 20 to 49 employees are understood to fall under a separate, fixed mechanism rather than the 2% annual growth model, but the specific fine figures circulating for that band vary and aren't consistently MOHRE-sourced — confirm your company's exact obligation directly with MOHRE.

Yes, MOHRE has channels for querying and appealing a fine, and it's worth checking your headcount classification, mainland status and the specific reporting period cited before assuming the fine as issued is correct.

NAFIS is the national programme supporting Emiratisation, including salary support and other incentives for hiring and retaining UAE nationals — using it can materially change the cost of meeting your target compared with repeatedly paying the fine.

MOHRE has previously offered instalment arrangements in some circumstances — this is worth asking about directly rather than assuming full immediate payment is the only option.

This turns on MOHRE's own classification of roles, and it's worth confirming exactly how your company's positions are classified, since the target and fine only apply to roles that fall within the skilled category as MOHRE defines it.

It refers to hiring Emirati nationals into roles that don't reflect genuine, substantive employment, purely to appear compliant — MOHRE treats this as a serious breach in its own right, with its own consequences separate from an ordinary missed-target fine.

It's calculated per unfilled skilled role, per month, which means a company short by several roles faces a proportionally larger monthly charge than one short by a single role.

Filling the target roles is generally what reduces or stops the ongoing charge, since the fine is tied to unfilled positions rather than being a fixed annual cost regardless of hiring progress — confirm the exact timing and mechanics with MOHRE for your specific case.

Don't assume either way. The federal employment law contains no free-zone carve-out — it applies to private-sector employers across the State, and DIFC and ADGM have their own employment laws and courts — so the position for any specific free zone is worth confirming directly rather than assuming it mirrors DIFC and ADGM.

Both — a lawyer can help confirm whether the fine is correctly calculated and correctly applies to you, pursue an appeal where warranted, and advise on structuring genuine compliance, particularly where a fictitious Emiratisation concern is anywhere near the picture.

MOHRE's framework is cumulative — the 2% annual growth is meant to build toward 10% across the whole 2022–2026 period, not a target that resets independently each year.

Verify the fine's basis against your own headcount and mainland status records, check whether an appeal or instalment route is available, and look at whether genuine hiring progress — including through NAFIS support — would be more cost-effective than continuing to absorb the monthly charge.

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