Sham Emiratisation is now treated as fraud, not paperwork
Dubai Courts have classified hiring Emiratis on paper only to meet quotas as a crime against public funds, exposing owners and managers to criminal liability rather than an administrative fine.
Photo: Blogtrepreneur (CC BY 2.0)
Dubai Courts have held that “sham employment” — placing an Emirati on the payroll to satisfy a quota without a real job behind it — is a crime against public funds rather than an administrative infraction, prosecutable as fraud. Judge Hamda Ahli of the court's labour division described it as a misuse of state resources and a betrayal of public trust.
The position is codified. Federal Decree-Law No. 9 of 2024 and Cabinet Resolution No. 43 of 2025 list sham employment, quota non-compliance, falsified documents and withholding Emirati wages or benefits as grave breaches. Penalties run from suspension of government support and repayment of misused funds through to fines and, for repeat offenders, suspension or cancellation of the licence.
Where forgery or fraud is proven, owners and managers face personal criminal liability, including the possibility of imprisonment. That is a different risk category from a quota fine absorbed by the company.
The defence is evidence: a real job description, real duties, real attendance and real output, documented as a matter of routine rather than assembled after an inspection.
What it means for employers
- Keep documented duties, attendance and output for every Emirati hire, not just a payroll entry.
- Audit Nafis-subsidised roles internally before an inspection does it for you.
- Brief owners and managers that liability here is personal, not only corporate.
Related pages
Summarised by the Horizon GCC team. Original reporting: Gulf News
This briefing is general information, not legal advice. Confirm current requirements with the relevant authority before acting.
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