Sponsoring employees through an ADGM company

This is the thing that most often surprises employers who have hired elsewhere in the UAE.

Immigration is federal. Entry permits, residence visas, medical testing and Emirates ID are national processes[UAE Gov — Residence visas], administered by the federal authorities[ICP], identical whether your entity is in ADGM or a mainland office.

Employment is ADGM's. ADGM is generally exempt from the UAE Federal Labour Law (Federal Decree-Law No. 47 of 2021) and MOHRE resolutions, and employment is governed by the ADGM Employment Regulations 2024[ADGM EAO — Employment guidance].

So a contract template written for the UAE mainland applies the wrong employment law to a correctly sponsored employee. That is a common and expensive error — see ADGM employment law.

1. The entity must be able to employ. An operating company can; an SPV cannot[ADGM — SPVs].
2. Establishment card — the prerequisite for sponsoring anyone.
3. Quota, which generally follows the space the entity occupies. See office space.
4. Entry permit and status change for the individual.
5. Medical fitness testing and Emirates ID, part of the federal residence process for those aged 18 and over[UAE Gov — Residence visas].
6. The employment contract under the ADGM Employment Regulations 2024, which applies from day one regardless of where the visa process has reached.

From ADGM's Employment Affairs Office guidance[ADGM EAO — Employment guidance]:

• End-of-service gratuity is the default under section 61. A pension or savings scheme may be offered as an alternative, which the employee must accept in writing — and taking it displaces gratuity. There is no compulsory DEWS-style fund in ADGM.
• Pension enrolment within 30 calendar days for UAE and GCC national employees, with the relevant federal pension authority. Those employees are not eligible for gratuity unless they hold written approval not to participate.
• Working time should not exceed 48 hours in a 7 calendar day period unless the employee consents in writing and receives the required rest.
• Probation should not exceed six months. Termination during probation requires one month's notice and carries no gratuity entitlement.
• Leave — sick leave up to 60 working days in a 12-month period on a tiered pay basis, and 65 working days of maternity leave.

Disputes go to the Employment Division of the ADGM Court of First Instance, which has exclusive jurisdiction over employment claims regardless of value[ADGM Courts — Divisions Rules].

A residence visa and a work permit are different instruments, and the permit is the ADGM-side obligation. ADGM's guidance sets out three employee situations, each needing a different application through AccessADGM[ADGM RA — Al Reem guidance note].

1. Employees your ADGM entity sponsors

Where the employee holds a valid visa under the ADGM entity, the employer applies for the Work Permit service for visa sponsored employees[ADGM RA — Al Reem guidance note]. This is the ordinary case, and the one every provider quotes for.

2. Employees on a visa from another jurisdiction

Where an employee holds an employment visa from elsewhere, the employer must obtain a temporary work permit through AccessADGM for all part time employees[ADGM RA — Al Reem guidance note].

This covers the person already sponsored by another UAE entity who works for you part-time. Their existing visa does not authorise the ADGM work — the permit does.

3. Non-sponsored employees, including Golden Visa holders

Here is the one that gets missed. For employees who are UAE or GCC nationals, sponsored by parents or spouses, or long-term visa holders including Golden and Green visas, the employer must obtain a Full time non-sponsored employee Work Permit through AccessADGM[ADGM RA — Al Reem guidance note].

Read that twice if you are hiring someone on a Golden Visa, a UAE national, or someone on a spouse's sponsorship. The instinct is that because you are not sponsoring their residence, there is nothing to file. That is wrong. The employer still has a permit obligation, it is a distinct application type, and skipping it means employing someone without the permit ADGM requires.

The same applies to a founder on a Golden Visa employing themselves through their own company. The residence is already handled; the work permit is not.

If employees are transferring into ADGM with a business rather than being hired fresh, the employment paperwork is rebuilt rather than carried across.

ADGM's guidance sets out the steps[ADGM RA — Al Reem guidance note]: prepare a new form of employment contract as per the ADGM Employment Regulations, provide it for employees' review, and sign new contracts with each employee.

That is a per-employee signature exercise rather than a bulk novation, and it needs scheduling. Employees are entitled to review the new terms, and some will have questions — particularly about accrued entitlements.

End of service

ADGM addresses the accrued gratuity directly: pay out end of service dues under employment contracts under onshore laws where required, noting that there is a possibility of transferring accumulated end of service to the new employment contract[ADGM RA — Al Reem guidance note].

So there are two routes — settle the accrued liability in cash at transfer, or carry it forward into the ADGM contract. Which applies depends on the circumstances, and possibility is ADGM's word rather than a guarantee. Establish it per employee before anyone signs, because getting it wrong creates a liability that surfaces years later at termination. See ADGM employment law.

• Plan quota before premises. Sponsorship capacity generally follows space, so a hiring plan that outruns the office is a problem discovered late.
• Use ADGM contracts. Not mainland templates, and not DIFC ones — DIFC assumes DEWS, which ADGM does not have.
• Decide the gratuity question deliberately at the point of hiring rather than drifting into a default and accruing an unplanned liability.
• Diarise the 30-day pension enrolment for UAE and GCC nationals. ADGM issued a circular on this obligation, which suggests compliance has not been universal[ADGM EAO — Employment guidance].
• Keep the entity in good standing — licence renewal and the separate data protection renewal[ADGM RA — Schedule of Fees]. Sponsorship depends on a valid licence.

Per-person visa costs, processing times and quota ratios. These are federal, revised periodically, and differ by category and circumstance. We do not publish them because a stale immigration figure wastes real time and money.

The authoritative sources are the UAE government portal[UAE Gov — Residence visas] and ICP[ICP]; a provider handling your sponsorship will give current figures for your case.