Employment law in ADGM

Employment in ADGM is governed by the ADGM Employment Regulations 2024. The Employment Affairs Office issued guidance on them dated 18 February 2025, under section 71(2) of those Regulations[ADGM EAO — Employment guidance].

The warning: a great deal of material online — including some still-published PDFs — describes the 2019 Regulations. Those have been superseded. If a page quotes a figure for gratuity, notice or leave without naming the 2024 Regulations, treat it as unverified until you have checked.

The operative text is published in ADGM's official rulebook[ADGM Legislation], alongside subordinate rules including the Employment Regulations (Temporary Work Permit) Rules 2024.

Enforcement sits with the Registration Authority's Employment Affairs Office[ADGM Registration Authority], and 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] — so a modest employment claim does not go to Small Claims.

This is the question people arrive with, usually because they know DIFC and are assuming ADGM matches it. It does not.

DIFC replaced gratuity with DEWS, a compulsory funded workplace savings scheme.

ADGM kept gratuity as the default. Section 61 of the Employment Regulations 2024 provides for an end of service gratuity where the employee has completed at least one year of continuous service[ADGM — Employment Affairs Office].

ADGM then permits — but does not require — an alternative. Employers may give all employees the option of participating in a pension or savings scheme as an alternative to receiving an end of service gratuity. Employees must confirm their choice in writing, and an employee who chooses the scheme will not be entitled to any end of service gratuity unless otherwise agreed by the employer[ADGM EAO — Employment guidance].

So the structure is opt-in and employer-led, not mandatory. For an employer with significant headcount that is a material difference from DIFC in both cash flow and administration, and it is worth modelling deliberately rather than assuming either model.

Probation and gratuity

An employee whose employment terminates during probation is not eligible for end of service gratuity — though the employer must give one month's notice. Once probation completes, that period counts towards the gratuity calculation[ADGM EAO — Employment guidance].

This part is mandatory, and it is federal in origin rather than an ADGM invention.

Employers must register UAE national employees, and GCC national employees (excluding UAE), with the relevant federal pension authority — for example the General Pension and Social Security Authority — within 30 calendar days of the first day of employment[ADGM EAO — Employment guidance].

Such employees are not eligible for end of service gratuity unless they hold written approval from the applicable pension authority not to participate in the scheme, a copy of which must be provided to the employer before or within 30 calendar days of their first day[ADGM EAO — Employment guidance].

ADGM's Registration Authority issued a circular on this obligation effective 19 February 2024[ADGM EAO — Employment guidance], which suggests compliance was not universal. If you employ UAE or GCC nationals, this is a live and checkable obligation with a short deadline.

An employee's working time should not exceed 48 hours in a 7 calendar day period, unless the employee consents in writing and receives the required rest[ADGM EAO — Employment guidance].

The framework is recognisably the European working-time model — a weekly cap with an individual written opt-out, plus daily and weekly rest entitlements — which will be familiar to anyone who has managed staff under UK rules.

The reference provisions are sections 15 (maximum weekly working time) and following of the Employment Regulations 2024[ADGM EAO — Employment guidance]. Read them in the rulebook before designing shift patterns or on-call arrangements.

Sick leave. An employee is entitled to sick leave not exceeding 60 working days in aggregate in any 12-month period, notifying the employer and providing a certificate from a registered medical practitioner if required. Pay is tiered: full pay for the first 10 working days, half pay for the next 20, and no pay for the remaining 30[ADGM EAO — Employment guidance].

Maternity leave. A female employee is entitled to 65 working days. Pay is full daily wage for the first 33 working days and half the daily wage for the next 32, subject to a continuous-employment condition for maternity pay. National holidays falling on a working day within the maternity leave period are treated as additional leave and extend it[ADGM EAO — Employment guidance].

Vacation leave is provided for under section 21, and employees on probation may take it subject to the employer's approval[ADGM EAO — Employment guidance].

We have set out the figures ADGM's own guidance states. For entitlements not listed here — notice periods, paternity leave, overtime and termination compensation limits — go to the Regulations in the rulebook[ADGM Legislation] rather than to a summary, this one included.

A probationary period should not exceed six months, and an employer may engage an employee without one[ADGM EAO — Employment guidance].

During probation an employee is entitled to vacation leave (subject to approval), sick leave (though not sick pay), and special leave for Hajj pilgrimage. They are not entitled to paid maternity or paternity leave.

Employment may be terminated during probation without cause, and the employee is then not eligible for end of service gratuity — but the employer must provide one month's notice[ADGM EAO — Employment guidance].

Once probation completes, the period counts towards gratuity and other entitlements. Reference: section 8 of the Employment Regulations 2024.

Your contracts are ADGM contracts. A template drafted for the UAE mainland applies the wrong law — ADGM is exempt from the federal labour law and MOHRE resolutions[ADGM EAO — Employment guidance]. A template drafted for DIFC applies a different centre's code and assumes DEWS.

Decide the gratuity question deliberately. Default gratuity, or offer a savings scheme with written employee consent. Either is available; drifting into one without deciding is how liabilities accrue unnoticed.

Diarise the 30-day pension enrolment for any UAE or GCC national hire.

Know where a dispute goes. The Employment Division of the ADGM Court of First Instance, with exclusive jurisdiction regardless of value[ADGM Courts — Divisions Rules], and employment claims are filed at 2% of the value of the claim with a minimum of USD 100[ADGM Courts — Fees].

This page is a summary of ADGM's own guidance, not advice. Employment disputes turn on facts and drafting — take proper advice before terminating anyone.