UAE Staff Secondment and Outsourcing 2026: Who Actually Employs the Person Doing Your Work

A working 2026 guide to getting people working for a UAE company without directly employing all of them. It separates the three arrangements founders confuse constantly, direct employment, secondment from another entity, and outsourced or supplied manpower, and shows why the work permit decides all of them, because Article 6 of Federal Decree-Law No. 33 of 2021 provides that work may not be practised in the State and that no employer may employ anyone without a permit from the Ministry. It covers what Article 11 actually says about an employer outsourcing some of its original works to another employer and why the words unless the parties agree otherwise are what moves the liability, who carries the labour law obligations in each arrangement including notice under Article 43 and end of service under Article 51, the Wages Protection System consequence of paying somebody you do not employ, what to ask a manpower supplier before you sign, and the practical founder case of engaging a contractor who is on a spouse's visa or holds their own licence, which is usually the clean route.
UAE Staff Secondment and Outsourcing 2026: Who Actually Employs the Person Doing Your Work

Expert-reviewed by BusinessDubai Business Setup Advisors. Written with guidance from licensed UAE company-formation consultants with 10+ years of experience, and fact-checked against official government sources before publishing. Last reviewed August 27, 2026.

One question decides more UAE employment exposure than any other, and almost nobody asks it before the person starts work.

Whose work permit is that person on?

Not who pays them. Not who manages them. Not whose office they sit in. Article 6 of Federal Decree-Law No. 33 of 2021 provides that work may not be practised in the State and that an employer may not recruit or employ any worker except after obtaining a work permit from the Ministry [1]. The permit names an employer and an occupation. It is the instrument that authorises the work at all.

So a person sitting in your office, doing your work, on somebody else's permit is not a clever cost saving. It is a live position somebody will eventually have to explain, and the explanation lands on your establishment file rather than on theirs.

Since 2013, BusinessDubai.ae has set up UAE companies, run their work permits and unwound arrangements built without asking that question first. This guide covers the three ways people actually work for a UAE company, who carries which obligation, and the one route that is usually clean for a founder who needs a person for three months.

What are the three ways a person can work for you?

Short answer: direct employment, secondment from another entity that employs them, and outsourced or supplied manpower. They are three different legal positions and founders routinely describe all three as hiring.

What matters is not what it is called. It is where the employment relationship sits and which company holds the permit.

ArrangementWho employs the personWho holds the work permitWhat you contract for
Direct employmentYouYouThe person's time under a registered contract
Secondment from another entityThe other entityThe other entityThe person's services, supplied by their employer
Outsourced works or supplied manpowerThe supplierThe supplierAn outcome, delivered by the supplier's own workers
Independent contractor with their own licenceNobody, they trade on their own accountTheir own licence supports their own residenceA scope of work under a commercial contract

Read the second column again. In three of those four rows you are not the employer, so you do not hold the permit, register the contract, or owe notice or end of service. That is the point of the arrangement and also where it fails, because a great many are documented as row two or row three and then operated as row one.

Common Mistake: Deciding the arrangement by what you want it to cost rather than by how it will run. If you set the person's hours, direct their daily work and treat them exactly as you treat your own staff, the paperwork saying they belong to somebody else is doing less work than you think. Choose the structure that describes the reality, then hold yourself to it.

Not sure which of those four your current arrangement actually is? Check your eligibility→

Why does the work permit decide everything?

Short answer: because the permit, not the residence visa and not the payment, is what authorises the work, and it names one employer and one occupation.

The most consequential misunderstanding in UAE employment is that residence and the right to work are the same instrument. They are not. Residence lets a person live here. A work permit lets a specific employer employ that specific person in a specific role. Our guide to work permits versus business licences sets out how the three documents interact. Two limbs of Article 6 do most of the work here [1].

No work without a permit. Work may not be practised in the State and an employer may not recruit or employ any worker except after obtaining a work permit from the Ministry [1]. There is no smallness exemption, no short-project exemption, and no exemption because the person already lives here on somebody else's file.

Recruitment and mediation are themselves licensed. Article 6 also provides that the activity of recruiting or mediating to recruit or employ workers may not be carried out without a licence from the Ministry, and prohibits an employer from charging the worker recruitment fees and costs, directly or indirectly [1]. That second limb is worth remembering when a supplier's pricing looks unusually good.

Above the permit sits the company file. The establishment card is the company's immigration registration and gates every residence visa the company issues, which is why an unpermitted person on your premises is an exposure against the file everything else depends on. Our establishment card guide covers that link, and our free zone company setup and mainland company setup pages cover which regime a structure sits under.

Real Talk: This bites harder than founders expect because the consequence is not usually a fine you pay and forget. Employment and immigration compliance interact with your ability to obtain new permits, and a flagged establishment file stops hiring at exactly the moment you are growing. Our WPS payroll guide works through that mechanism, because it is the same file in both cases.

The permit categories MOHRE issues beyond the standard employment permit, with their conditions, quotas and fees, are set and updated by MOHRE. We do not list them here, because a stale category is worse than none. Confirm the correct permit for your arrangement with MOHRE directly [2].

What does Article 11 actually say about outsourcing?

Short answer: an employer may outsource some of its original works to another employer, and the other employer is then solely responsible for the entitlements of its own workers who perform those works, unless the parties agree otherwise.

This is the provision people reach for when they want a lawful structure for supplied labour, and it is worth reading in the exact words rather than in summary. Article 11 of Federal Decree-Law No. 33 of 2021 provides that the employer may outsource some of the original works, or any part of them, to another employer, in which case the other employer is solely responsible for all entitlements of its workers who perform such works accrued under the decree-law, unless the parties agree otherwise [1].

Three things follow, and only the first is widely understood.

Both sides are employers. Article 11 describes works passing from one employer to another. It does not describe a person floating free of any employer, and it creates no route by which somebody with no permit can lawfully do your work. The supplier has to be a real employer with real permits for the people it sends.

The default allocation favours you. As drafted, the entitlements of the supplier's workers are the supplier's problem. Wages, leave, notice and end of service sit on the company that employs them. That is the commercial logic of outsourcing.

The last five words move all of it. Unless the parties agree otherwise. That is a contract term, drafted by whoever wrote the agreement in front of you. A supply agreement can allocate cost back to you, indemnify the supplier against its own workers' claims, or make you responsible for entitlements you assumed were priced into the rate. Nobody will ring you to point that out.

Pro Tip: Read the liability and indemnity clauses of a manpower or outsourcing agreement before you read the rate card. The rate is the number you are comparing and the indemnity is the number you will actually pay. If a supplier's price is materially below the market and its agreement pushes worker entitlements onto the customer, those two facts are the same fact.

Be honest about the first clause too. Article 11 is about outsourcing works, meaning a defined scope of activity, not about renting a chair-filler and calling it a service. An agreement describing a deliverable, a specification and an acceptance standard is an outsourcing agreement. One describing a named individual, your working hours and your reporting line is employment with a different letterhead.

Who carries the labour law obligations in each arrangement?

Short answer: whoever employs the person, which in a properly built secondment or outsourcing arrangement is not you, subject to whatever the agreement says instead.

Here is the obligation set mapped across the arrangements. Article numbers are from Federal Decree-Law No. 33 of 2021 [1].

ObligationDirect employmentSecondmentOutsourced or supplied
Work permit from the Ministry, Article 6YouTheir employerThe supplier
Registered employment contractYouTheir employerThe supplier
Probation rules, Article 9YouTheir employerThe supplier
Annual leave of 30 days, Article 29YouTheir employerThe supplier
Sick leave of up to 90 days, Article 31YouTheir employerThe supplier
Notice of 30 to 90 days, Article 43YouTheir employerThe supplier
End of service under Article 51YouTheir employerSupplier, per the Article 11 default
Wage payment through WPSYouTheir employerThe supplier
Worker file kept 2 years after exit, Article 13YouTheir employerThe supplier
Health and safety on your premisesYouYou, in practiceYou, in practice

Two rows are where the money is.

Notice under Article 43. The agreed notice period must be not less than 30 days and not more than 90 days [1]. In a direct hire that is your cost. In a supply arrangement it belongs to the supplier, which has priced its own notice exposure into your rate and will protect it with a minimum term or an early-termination charge. You have not removed the notice cost. You have converted it into a commercial term, which is a benefit only if that term is shorter or cheaper.

End of service under Article 51. Gratuity accrues at 21 days of basic wage per year for the first five years and 30 days per year after that, on the last basic wage, capped at two years' wage [1]. In a supply arrangement it sits with the supplier under the Article 11 default [1]. This is the most commonly cited reason for using supplied labour and it is real, but the supplier is amortising the same accrual into its rate. You are buying certainty and cash-flow smoothing, not a free lunch.

Our UAE labour law guide for employers works through every one of those provisions with the numbers, and our end of service gratuity guide works the calculation variants. This guide stops at who owes them.

Quick Math: Compare on total annual cost, not on the headline rate. For a direct hire the recurring load is the wage, the permit and visa cycle, the Article 51 accrual and the Article 43 notice exposure. For a supplied worker it is the rate plus the minimum term plus whatever the indemnity clause hands back to you. Put both on one page over three years, not one. A supply rate that looks expensive in month one is often the cheaper number by month thirty, and sometimes the reverse.

Want the difference between a real hire and a supplied worker priced properly before you commit? Talk to a setup expert→

What does secondment actually mean, and what does it not?

Short answer: the person stays employed by, and permitted to, their original entity while working for yours. Nothing about your convenience changes the fact that they are not your employee.

Secondment is useful and common, particularly across a group. A parent company sends a finance manager to the new UAE subsidiary for eighteen months. A regional office lends an engineer to a project. The employment relationship, the contract, the permit and the payroll stay where they were, and a written agreement covers what your entity gets, what it pays and how it ends. What secondment does not do is create a permission that did not exist.

It does not move the permit. If the permit is held by their original employer, the arrangement has to be one that employer and the relevant authority can support. If the work requires a permit naming your company, then you need that permit, and the label on the agreement does not substitute for it. This is the point on which to speak to MOHRE about your specific facts rather than to a template [2].

It does not convert a group into one employer. A parent and a subsidiary are separate legal persons with separate establishment files, permits and quotas.

It does not make the person cheaper by default. The seconding entity carries the wage, the accruals and the permit, and it will recharge them. Cross-charges between related entities also have a tax dimension in the UAE now, which is a conversation for your accountant.

Common Mistake: Treating a secondment as informal because the two companies have the same owner. Write the agreement: who pays what, whose policies apply, who carries insurance, what happens if the person resigns mid-secondment, and on what notice either side can end it. The reason is not that you distrust the other entity. It is that in eighteen months the facts will be contested by somebody who was not in the room, quite possibly an auditor or a bank.

If your group is being built now rather than already in place, the structure decision comes before the staffing one. Our free zone versus mainland versus offshore comparison sets out where each vehicle can and cannot employ, and our offshore company formation page covers the one that cannot employ or sponsor anybody, which surprises people who intended to staff it.

Where does supplied or outsourced manpower go wrong?

Short answer: in the supplier's own compliance, which becomes your problem the moment its people are on your premises doing your work.

Supplied manpower is a normal way to resource a UAE business, particularly for facilities, security, hospitality, logistics, construction support and seasonal peaks. The structure is fine. The failure is almost always at the supplier end, and almost always visible in advance if anybody looks. Ask these before you sign, and ask for evidence rather than assurance.

Is the supplier licensed for this activity? Recruitment and mediation to recruit or employ workers requires a Ministry licence under Article 6 [1]. A supplier whose licence does not cover the activity it is selling you is a supplier whose entire arrangement rests on nothing. Our recruitment agency guide covers what that side of the market requires.

Does it hold current permits for the specific people? Not for its workforce generally. For the named individuals who will be on your site, and is it paying them through WPS. A supplier not current on its own wage payments can lose the ability to obtain permits, at which point your resourcing plan is exposed to somebody else's payroll month.

Who is charged the recruitment cost? Article 6 prohibits an employer from charging the worker recruitment and employment fees, directly or indirectly [1]. A rate only achievable because the worker funds it is not an advantage you want attached to your name.

What does the agreement say about entitlements? Article 11 makes the supplier solely responsible unless the parties agree otherwise [1]. Find that clause and read what it does.

What happens on termination and replacement? Minimum term, notice, replacement standards, and what you owe if the person leaves in week three.

Real Talk: Companies get burned here because supplied labour is bought by whoever owns the operational problem, at speed, under pressure, and the agreement is signed to solve this week. Nobody reads the indemnity when the site opens on Monday. The highest-return habit is to vet one supplier once, properly, and reuse it, rather than repeating an unvetted decision every time capacity is short.

One risk has nothing to do with paperwork. Health and safety obligations attach to the place of work in practice regardless of who signs the payslip, which is why that row in the table above reads as you in every column. It is the row most often left unassigned.

What is the WPS consequence of paying someone you do not employ?

Short answer: their wage is owed by their employer, so it belongs in their employer's salary file, and money you pay them directly sits outside the system on both sides.

The Wages Protection System is how the UAE verifies that registered employers pay registered employees the wages in their registered contracts. Our WPS payroll guide covers how a file is built and why it rejects. What matters here is narrower. If a person is employed by another entity and you pay them directly, three things are true at once.

Their employer's file is wrong, or it is right and yours is a mystery. If the supplier or seconding entity is paying the contracted wage through WPS, your payment is an unexplained additional flow. If it is not paying it because you are, its salary file understates what its worker actually received, which is exactly the mismatch the system was built to see.

You have a payment with no employment relationship behind it. Your accounts show a recurring payment to an individual that is not payroll, not a supplier invoice and not supported by any contract with that person. That is a question at your audit, at your bank, and in a Corporate Tax review of deductibility.

The person has no claim against you. They cannot enforce a wage against a company that never employed them, and they cannot easily enforce the portion you paid privately against their actual employer. When it ends badly, both companies are in the argument.

The clean version is short. Supplier's worker: you pay the supplier against an invoice and the supplier pays them through its own WPS file. Your worker: you employ, permit and pay them through yours. Independent contractor: you pay their company against an invoice and there is no wage in the picture at all.

Pro Tip: The test for whether a payment is clean is whether it survives being described in one sentence to a compliance officer. "We pay our supplier monthly against an invoice for facilities staff" survives. "We pay him directly because he is on his brother's company visa" does not, and you find out at the point you least want to.

Our post-setup services team runs work permits, MOHRE contracts and WPS payroll as an ongoing function, which is the version that does not depend on somebody remembering.

Should you use a contractor on a spouse visa or their own licence?

Short answer: yes, and for most founders with a short-term or specialist need this is the cleanest route available, because it removes the permit question instead of working around it.

This is the case founders actually face. You need a designer for eight weeks, a bookkeeper for two days a month, a developer for one build. You do not want an employee, a permit, a visa quota and a gratuity accrual for that. The instinct is to pay somebody cash and move on. The better answer is usually already in the room.

Who they areCan they invoice you?What you need to see
Holds their own trade licenceYes, within their licence activitiesTrade licence showing the activity
Holds a freelance or self-employment permitYes, within the permit's scopeThe permit, and its scope
On a spouse or family visa with their own licence or permitYesResidence plus their licence or permit
On a spouse or family visa with nothing elseNoNothing to see, because nothing authorises it
Employed by another UAE company, moonlightingNo, not to you privatelyTheir employer's written position

Row three is the most misunderstood status in the country. Being on a spouse's visa makes a person resident. It does not authorise them to earn. Their own licence or permit does, and a spouse visa is the most flexible base from which to get one, because they are already resident and not tied to an employer. A great many capable people in Dubai are exactly one licence away from being able to invoice you legitimately.

The cheapest genuine route into that position is a Dubai e-Trader licence, from around AED 1,370 a year, which permits service activities for expat holders but cannot sponsor a residence visa or employ anybody [3]. For somebody who already holds residence through a spouse and simply needs to invoice, both limits are irrelevant, which is why it fits so well. Our e-Trader licence guide covers what it does and does not permit.

The freelance or self-employment permit is the other clean option, and it opens a residence path of its own. The ICP Green Visa freelance route is self-sponsored for five years and requires a Ministry-issued freelance or self-employment permit, a bachelor's degree, specialised diploma or equivalent, and annual income of not less than AED 360,000 in each of the two previous years, not an average across them [4]. Our Green Visa guide covers all three routes, and our freelance versus company setup comparison covers when a contractor should stop freelancing and incorporate.

Quick Math: A contractor with their own licence invoicing you for an eight-week project costs the invoice and nothing else: no permit, no visa quota, no Article 43 notice, no Article 51 accrual, no WPS line. A direct hire for the same eight weeks costs the wage plus a permit and visa cycle you will unwind almost immediately. Unless the work is genuinely ongoing and core, the contractor is cheaper and considerably faster.

The contractor route stops working when the work becomes permanent, full time and directed by you day to day. At that point you are describing an employee and the honest move is to hire one. Our guide to hiring employees in Dubai covers the permit and contract sequence, and our visa quotas in free zones guide covers how many people your licence and premises will let you employ, which decides the timing more often than budget does.

What should be in the agreement before anyone starts?

Short answer: the scope, the permit position, the entitlements clause, the term and the exit, in that order.

Whether you are documenting a secondment, an outsourcing arrangement or a contractor engagement, the same five points do the work. Only the answer changes.

PointSecondmentOutsourced or suppliedIndependent contractor
ScopeNamed person, role, duration, whose policies applyDefined works, specification, service levelsDeliverables, milestones, acceptance
Permit positionConfirmed with the seconding entity and MOHRE [2]Supplier warrants licence and current permits [1]Their licence or permit, evidenced
EntitlementsStays with the seconding employerSupplier, per the Article 11 default, unless varied [1]Not applicable, no employment relationship
Term and chargesRecharge basis, review pointsRate, minimum term, replacement standardsFee, payment terms, expenses
ExitNotice either way, early return, handoverNotice, wind-down, transfer of work in progressCompletion, termination for convenience, IP

Insist on one clause in all three columns: a warranty that everybody the other side puts on your site is lawfully permitted and paid. Keep the evidence pack with the agreement, because reconstructing it two years later, after the operations manager has left, is the part nobody budgets for.

Where does this actually get caught?

Short answer: in five places, and four of them are decided before the person starts rather than when the arrangement ends.

Failure pointWhat actually goes wrongWhere it surfaces
A person working on nobody's permitThe work is not authorised under Article 6 [1]An inspection, a claim, or a later permit application
Direct payment to another company's employeeWage flows outside the WPS position on both sidesAn audit, a bank review, a tax deductibility question
Agreement that varies the Article 11 defaultEntitlements you assumed were priced in come back [1]A worker claim months after the person left
Supplier with the wrong licence or lapsed permitsThe whole arrangement rests on nothing [1]The moment anybody asks for evidence
Secondment operated as employmentDocumented structure and lived reality divergeA dispute, where the lived reality gets examined

Real Talk: Almost none of these start as an attempt to avoid anything. They start as a favour, a stopgap, or a supplier chosen at speed in a busy quarter. The person who created the exposure is usually not the person who resolves it, and the gap between those two moments is typically a year or more. That is why the cheapest control is one question asked in writing of everybody who works on your premises: whose permit are you on, and can I see it.

Our visa cancellation guide covers the order in which permits and visas have to be unwound when an arrangement ends, because doing it out of sequence stalls. Overstay and status violations accrue at AED 50 per person per day, flat rather than escalating, and paying does not resolve the violation, because ICP requires that status is adjusted or the person leaves the UAE [5]. Our overstay fines guide covers the grace periods, which differ enormously by permit type.

Real Client Stories

Real examples from businesses we have helped set up. Names have been changed for privacy.

Hussein, who inherited a supplier's liability in a clause he never read

Hussein ran a facilities business and took on twelve supplied cleaning staff through a manpower agreement signed in a hurry before a contract start date. The Article 11 default would have left the supplier solely responsible for its workers' entitlements, but the agreement varied it, as Article 11 permits [1]. When the supplier ran into difficulty, a portion of the accrued entitlements for those twelve people came back to Hussein's company under an indemnity he had never priced.

The lesson was not that supplied labour is dangerous. It is a normal and useful structure. The lesson was that the rate card and the indemnity clause are the same negotiation, and he had negotiated only one of them.

His comment: "I compared four suppliers on the hourly rate to two decimal places. Nobody compared the agreements, and the agreement is where the money was."

Marta, who paid a contractor directly for eleven months

Marta needed a part-time bookkeeper and engaged a woman resident on her husband's visa with no licence or permit of her own, paying her monthly by bank transfer. It ran for eleven months without incident and looked like the sensible answer to a small problem.

It surfaced at the company's first proper audit and again during a bank review, because eleven identical monthly payments to an individual that are neither payroll nor a supplier invoice are exactly the pattern both processes exist to notice. The fix was straightforward. The bookkeeper obtained her own service licence at a little over AED 1,370 a year [3] and invoiced from that point, and the relationship continued unchanged in every respect that mattered.

Her comment: "The solution cost less than one month of what I was already paying her. I spent eleven months avoiding a problem that took an afternoon to solve."

Ravi, whose group secondment was never written down

Ravi's parent company in Singapore sent an operations manager to the new Dubai entity for what was meant to be six months and became two years. Nothing was documented, because both companies had the same shareholder and it did not feel like a transaction. The wage stayed on the Singapore payroll and the Dubai entity paid nothing towards it.

The arrangement was defensible. The absence of any record of it was not, and it was tested three times: at the Dubai entity's audit, when its bank asked why a senior operational role appeared in the organisation chart and nowhere in the payroll, and when the manager later questioned which entity he had been working for. All three conversations needed the same document.

His comment: "We treated the group as one company because that is how we think about it. Three separate institutions made it very clear that it is not."

Get the arrangement built before the person starts

The summary for a founder is a sequence, not a rule.

Decide what the work actually is. If it is an ongoing role, hire the person, permit them properly and price the Article 43 notice and Article 51 accrual honestly [1]. If it is a defined scope, outsource it to a licensed supplier and read the entitlements clause before the rate card, because Article 11 gives you a favourable default the agreement in front of you may already have varied [1]. If it is temporary or specialist, engage a contractor who holds their own licence or freelance permit, which can cost as little as an AED 1,370 e-Trader licence on their side [3].

What never works is a person doing your work on nobody's permit, or on somebody else's permit for work that permit does not describe. That is not a documentation gap. Article 6 makes the permit the thing that authorises the work at all [1].

Since 2013, BusinessDubai.ae has set up UAE companies and run the permits, contracts and payroll behind them, including the arrangements that had to be rebuilt after they were built the fast way. We will tell you which of the four structures your situation actually is and what it costs across three years rather than one. Our post-setup services team then runs the permits, the MOHRE contracts and the WPS payroll as a standing function, and our business setup in Sharjah page covers one of the routes employers use when headcount cost is the binding constraint.

Get a free consultation→

Frequently Asked Questions

Can someone work for my UAE company on another company's work permit?

Not as a way of avoiding a permit your arrangement requires. Article 6 provides that work may not be practised in the State and that no employer may employ any worker without a permit from the Ministry [1]. If they are supplied to you by their own employer under a lawful outsourcing or secondment arrangement, they work on that employer's permit for that employer's works. Confirm the correct permit for your facts with MOHRE [2].

What is the difference between secondment and outsourcing?

Secondment supplies a named person from the entity that employs them, while the employment, permit and payroll stay where they were. Outsourcing under Article 11 passes a defined scope of works to another employer, which performs it using its own workers [1]. One is about a person, the other about a scope.

What does Article 11 of the UAE labour law say?

That an employer may outsource some of the original works, or any part of them, to another employer, and that the other employer is then solely responsible for all entitlements of its workers performing those works under the decree-law, unless the parties agree otherwise [1].

Does Article 11 mean I have no liability for supplied workers?

By default the supplier carries the entitlements of its own workers [1]. But Article 11 expressly allows the parties to agree otherwise, and supply agreements frequently do exactly that through indemnities and allocation clauses [1]. Read the agreement, not just the article.

Who pays end of service gratuity for a supplied worker?

Their employer, which in a supply arrangement is the supplier, under the Article 11 default [1]. Gratuity accrues at 21 days of basic wage per year for the first five years and 30 days per year after that, on the last basic wage [1]. If your agreement varies the default, that allocation changes.

Who gives notice to a seconded employee?

Their employer. The Article 43 band of not less than 30 and not more than 90 days applies to the employment relationship, which sits with the seconding entity rather than with you [1]. Your secondment agreement separately sets out how the secondment itself ends.

Can I pay a supplied worker directly?

You should not. Their wage is owed by their employer and belongs in that employer's WPS salary file. Paying them directly creates an unexplained payment on your side and a mismatch on theirs, and gives the person no claim against you.

Do supplied workers go into my WPS file?

No, because they are not your employees. They belong in their employer's file, and you pay the supplier against an invoice. Our WPS payroll guide covers what does belong in your own file.

Can I use a manpower supply company instead of employing staff?

Yes, and it is a normal structure, particularly for facilities, security, hospitality, logistics and seasonal peaks. Check the supplier holds the right licence, because Article 6 requires a Ministry licence to carry out recruitment or mediation to recruit or employ workers [1].

How do I check whether a manpower supplier is legitimate?

Ask for the trade licence covering the activity, current work permits for the named individuals going to your site, confirmation that it pays them through WPS, and the entitlements clause. Ask for evidence rather than assurance, and keep the pack with the contract.

Can a supplier charge its workers the recruitment cost?

No. Article 6 prohibits an employer from charging the worker the fees and costs of recruitment and employment, directly or indirectly [1]. A rate only achievable because the worker funds it is not an advantage you want attached to your company.

Can I hire a freelancer who is on their spouse's visa?

Only if they hold their own licence or freelance permit. A spouse's visa makes a person resident, which is not the same as authorised to earn. It is the most flexible base from which to obtain a licence, because they are already resident and not tied to an employer.

What licence does a contractor need to invoice me?

Either a trade licence covering the service they provide, or a freelance or self-employment permit within its scope. The cheapest genuine route in Dubai is an e-Trader licence from around AED 1,370 a year for service activities, though an expat holder generally cannot sell physical products, sponsor a visa or employ anyone [3].

Is it cheaper to use a contractor than to hire someone?

For temporary or specialist work, usually yes. A contractor with their own licence costs you the invoice and nothing else: no permit, no visa quota, no Article 43 notice, no Article 51 accrual [1]. For ongoing, full-time, directed work, an employee is both the honest description and usually the cheaper one.

Can I second an employee from my overseas parent company to my UAE entity?

Commonly yes, and it is a standard group arrangement, but confirm the permit position for your specific facts rather than assuming it, and document it in writing even when both entities have the same shareholder [2].

What happens if someone works for me with no permit at all?

The work is not authorised, because Article 6 makes the permit the instrument that permits the work [1]. Penalties and enforcement are set by MOHRE and should be confirmed with MOHRE directly [2]. The consequence that changes behaviour is the effect on your establishment file, and therefore on your ability to obtain further permits.

Do free zone companies have to worry about any of this?

Yes. The federal decree-law is the reference for mainland employers and most free zone companies. DIFC and ADGM run their own employment regimes with different numbers, so check the zone's own law if you are hiring there. Our ADGM versus DIFC comparison covers where they diverge.

Can an offshore company second or employ staff?

No. Offshore vehicles do not trade inside the UAE and do not sponsor residence visas, so there is no employment layer to work with. Our offshore company formation page covers what they are actually for.

Does using supplied labour affect my Emiratisation position?

Emiratisation obligations sit outside the labour decree-law and are enforced separately, with their own targets and calculation basis. Do not assume resourcing through a supplier changes your position either way. Our Emiratisation guide covers the current framework.

Who is responsible for health and safety of supplied workers on my site?

In practice you are, because the obligation attaches to the place of work regardless of who signs the payslip. This is the one row where the answer is you across every arrangement, and it is the one most often left unassigned in the agreement.

Can I convert a supplied worker into my own employee?

Usually yes, subject to your agreement with the supplier, which often carries a transfer fee or a restriction. Check that clause before you make anybody an offer, because finding it afterwards turns a good hire into an argument.

What is the biggest mistake companies make with supplied and seconded staff?

Not asking whose permit the person is on before they start. Everything else in this guide is a consequence of that question going unasked, and it takes one sentence and one document to answer.

Related reading: UAE Labour Law Guide for Employers, UAE WPS Payroll Guide, Work Permit vs Business Licence

References

[1] Ministry of Human Resources and Emiratisation. Federal Decree-Law No. 33 of 2021 Regarding the Regulation of Employment Relationships and its amendments, in force 2 February 2022. Provisions relied on: Article 6 (no work in the State and no recruitment or employment of any worker without a work permit from the Ministry, a Ministry licence required to carry out recruitment or mediation, and a prohibition on charging the worker recruitment fees directly or indirectly), Article 9 (probation), Article 11 (an employer may outsource some of the original works or any part of them to another employer, in which case the other employer is solely responsible for all entitlements of its workers performing those works, unless the parties agree otherwise), Article 13 (worker files kept not less than two years after exit), Article 29 (30 days annual leave), Article 31 (up to 90 days sick leave), Article 43 (notice of not less than 30 and not more than 90 days) and Article 51 (end of service of 21 days basic wage per year for the first five years and 30 days per year thereafter, on the last basic wage, capped at two years' wage). Federal Decree-Law No. 33 of 2021 (PDF)

[2] Ministry of Human Resources and Emiratisation. Laws and regulations index for private sector employment. Work permit categories and their conditions, establishment quotas, fees, penalties and compliance windows are set and updated by MOHRE and should be confirmed with MOHRE directly rather than from any secondary source. MOHRE laws and regulations

[3] BusinessDubai.ae analysis of Dubai Department of Economy and Tourism e-Trader licence conditions: indicative annual cost from AED 1,370, the restriction preventing expat holders from selling physical products, and the inability of the licence to sponsor residence visas or employ staff. e-Trader licence guide

[4] Federal Authority for Identity, Citizenship, Customs and Port Security (ICP). UAE Green Residency, freelance and self-employment route: a Ministry-issued freelance or self-employment permit, a bachelor's degree, specialised diploma or equivalent, and annual income of not less than AED 360,000 in each of the two previous years. Self-sponsored, five years. ICP Green Residency

[5] Federal Authority for Identity, Citizenship, Customs and Port Security (ICP). Payment of visa or residence violation fine at AED 50 per person per day flat, plus an AED 100 smart services fee, and the requirement that status be adjusted or the individual leave the UAE after payment. ICP visa and residence violation fines

[6] The Official Platform of the UAE Government. Employment laws and regulations in the private sector, covering wage payment obligations and the electronic wage transfer arrangements alongside Federal Decree-Law No. 33 of 2021. u.ae employment laws

[7] BusinessDubai.ae. Internal data from UAE company formation, work permit and payroll administration since 2013, including secondment and manpower supply arrangements rebuilt for clients, supplier vetting failures, and direct payments to individuals employed elsewhere. businessdubai.ae

General information about published law and our own published pricing, not legal advice. Work permit categories, quotas, fees and penalties are set and updated by MOHRE; confirm your specific arrangement with MOHRE before you rely on it.

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