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Employers in the UAE who hire domestic workers under their personal sponsorship can terminate an employment contract before its expiry, but they must have valid legal grounds and comply with the requirements of the UAE Domestic Workers Law.

The matter is governed by Federal Decree-Law No. 9 of 2022 Concerning Domestic Workers, as amended by Federal Decree-Law No. 21 of 2023, together with Cabinet Resolution No. 106 of 2022, which sets out the executive regulations.

Under Article 20(1) of the law, either the employer or the domestic worker may terminate the employment agreement unilaterally if the other party breaches the obligations specified under Articles 11 and 12. The employer's responsibilities include paying the agreed wages, providing suitable accommodation and medical care, and treating the worker with dignity. The worker, in turn, is required to perform the agreed duties with due care, follow lawful instructions and safeguard the employer's property.

Consequently, an employer who is dissatisfied with a domestic worker's performance may have grounds for termination if the circumstances establish a breach of the worker's legal or contractual obligations. However, mere dissatisfaction or a difference in expectations does not automatically justify unilateral termination. The nature of the breach and the supporting evidence must be considered.

Article 7 also allows an employment agreement to be terminated before its expiry with the consent of both parties. This provides an alternative where the employer and worker mutually agree to end the employment relationship.

Financial obligations following termination depend on the circumstances. Under Article 20(2), where an employer terminates the agreement for a reason not attributable to the worker, the employer must pay all outstanding dues and provide a return ticket to the worker's home country. The employer must also settle any unpaid wages and other contractual entitlements.

Where a dispute arises over termination or the parties cannot reach an amicable settlement, the matter may be referred to the Ministry of Human Resources and Emiratisation (MOHRE). Under Article 23 of the law and the applicable executive regulations, the Ministry will attempt to resolve the dispute. If an amicable settlement cannot be reached within the prescribed period, the matter may be referred to the competent court.

Before proceeding with termination, employers should review the employment agreement, retain records of any performance-related concerns and establish the grounds for their decision. They must also settle outstanding wages and other entitlements and complete the necessary work permit and residence sponsorship cancellation formalities.

An employer's right to terminate a domestic worker's contract before its expiry is therefore not unconditional. The decision must be supported by a recognised legal ground or mutual agreement, with the worker's statutory rights and financial entitlements protected throughout the process.

Several public employees and military recruits in the UAE have been referred to the Military Criminal Court over allegations of manipulating national service records, securing exemptions through deception and abusing official positions to help individuals avoid their military obligations.

The Military Attorney General ordered the referral following investigations into alleged attempts to falsify official data, government documents and medical reports to enable certain recruits to bypass prescribed procedures. The Military Prosecution has brought charges against the defendants according to their alleged individual roles in the conduct under investigation.

The case highlights the legal framework governing national and reserve service in the UAE, the consequences of fraudulent exemptions and the role of the military judiciary in dealing with offences connected with these obligations.

The allegations have yet to be established in court, and the defendants will have the opportunity to contest the charges.

UAE's National Service Legal Framework

National service in the UAE is governed by Federal Law No. 6 of 2014 on National and Reserve Service, together with its subsequent amendments and implementing regulations. The legislation establishes compulsory service requirements for eligible male UAE citizens and provides a framework for recruitment, medical fitness, exemptions, postponements and reserve obligations. Female citizens may also undertake national service voluntarily under the applicable arrangements.

The National and Reserve Service Authority oversees the administration of the system and coordinates with the relevant government and military institutions.

The law requires eligible citizens to complete the prescribed recruitment procedures and fulfil their service obligations unless they qualify for a legally recognised exemption or postponement. Medical fitness is an important part of this process, with assessments conducted through the authorised procedures.

Exemptions and postponements are subject to statutory conditions and approval by the competent authorities. Applicants cannot independently secure an exemption merely by producing a medical report or other supporting document. The information must be verified and accepted through the prescribed process.

Penalties For Evading National Service

Article 36 of Federal Law No. 6 of 2014 addresses offences involving failure to comply with recruitment requirements and fraudulent attempts to avoid national service.

Under Article 36(1), a person who, without a legitimate excuse, fails to report to the competent recruitment authorities, complete recruitment procedures or join the prescribed training programme may face imprisonment. The penalties increase according to repeated instances of non-compliance.

More serious consequences apply under Article 36(4). A person liable for national service who evades or attempts to evade the obligation through fraud, deliberately inflicts injuries to appear medically unfit or submits documents containing false information may face temporary imprisonment and a fine of between Dh500,000 and Dh1 million, or either punishment. The provision applies where the conduct results in an unjustified exclusion, exemption, postponement or avoidance of service.

Importantly, a criminal conviction does not necessarily extinguish the individual's national service obligation. The law allows the person to be enrolled for service even after exceeding the prescribed age.

The law also contains separate provisions dealing with failure to respond to reserve service call-ups. The applicable punishment depends on the circumstances and the nature of the failure.

Why Public Employees May Also Face Investigation

The present case involves not only recruits allegedly seeking to avoid service but also public employees suspected of using their official positions to facilitate improper exemptions and manipulate service records.

Their potential criminal responsibility must be assessed separately from that of individuals legally required to undertake national service. Article 36(4) specifically addresses fraudulent evasion by persons subject to the service obligation. Officials who allegedly facilitate such conduct may face charges under the applicable provisions governing their particular actions, including relevant offences involving official authority, falsification or participation in criminal conduct.

The precise charges and penalties depend on the evidence and the legal provisions applied to each defendant. Merely holding a government position does not establish criminal liability, just as an administrative irregularity does not automatically amount to deliberate fraud.

How Military Courts Function in the UAE

The UAE has a specialised military justice system that operates separately from the ordinary criminal court structure. Its jurisdiction is determined by the relevant legislation and extends to military offences and other matters specifically assigned to it by law.

For national service offences, Article 39 of Federal Law No. 6 of 2014 expressly gives military justice exclusive jurisdiction over the offences covered by the legislation. This is the statutory basis for referring cases involving alleged violations of national and reserve service requirements to the military judiciary.

The military justice system has its own prosecutorial authority. The Military Prosecution investigates offences falling within its jurisdiction, examines evidence, identifies the individuals allegedly involved and determines the charges to be brought before the competent military court.

The Military Attorney General heads the military prosecutorial authority. An order referring defendants to the Military Criminal Court means that the prosecution has decided to place the allegations before the judicial authority for adjudication. It is not a declaration that the accused are guilty.

The court examines the charges and the evidence presented by the prosecution, considers the defence arguments and determines whether the legal elements of the alleged offences have been established.

It is important to distinguish this jurisdiction from that of ordinary criminal courts. The UAE's civilian criminal courts generally deal with offences under the country's general criminal legislation. Military jurisdiction, however, applies where a specific law assigns the matter to the military judiciary. Consequently, not every criminal allegation against a civilian government employee falls within military court jurisdiction.

Rights of Defendants and the Trial Process

A military trial remains a judicial proceeding in which criminal responsibility must be established in accordance with the law. The accused are entitled to challenge the allegations, contest documentary and other evidence and present their defence through the applicable procedures.

In cases involving alleged manipulation of national service records, the court may need to examine the authenticity of medical reports, the accuracy of official documents, the circumstances in which records were altered and the extent of each defendant's involvement.

The distinction between an intentional act of falsification and an administrative mistake may be important when determining criminal responsibility. The prosecution must establish the allegations against each defendant rather than treating all those involved as equally responsible.

The constitutional principle of presumption of innocence also applies. Article 28 of the UAE Constitution protects the position that an accused person is presumed innocent until proved guilty in a lawful trial. The right to legal defence is another fundamental safeguard.

Protecting the Integrity of National Service

The accuracy of recruitment records, medical assessments, exemption decisions and certificates of service completion is essential to the functioning of the national service system. Deliberate manipulation can undermine the fairness of the process by allowing certain individuals to avoid obligations imposed on others.

The alleged involvement of public employees also raises questions about the responsibility of officials entrusted with maintaining government records and administering statutory procedures.

The Military Attorney General has emphasised that national service is a duty, an honour and a responsibility towards the country. Safeguarding the integrity of the system, the authority said, is necessary to uphold fairness and equality and prevent the exploitation of official positions.

The proceedings will determine whether the alleged conduct amounts to criminal offences and what responsibility, if any, can be attributed to each defendant. Until the court reaches its decision, the allegations remain accusations rather than established findings.

The UAE Federal Tax Authority (FTA) has urged businesses and other entities covered by the country's e-Invoicing System to meet the prescribed implementation deadlines, warning that delays could attract administrative penalties of Dh5,000 for each month or part of a month of non-compliance.

Businesses and other entities with annual revenues of Dh50 million or more were required to appoint an Accredited Service Provider (ASP) by October 30, 2026, and must implement the e-Invoicing System by January 1, 2027.

The FTA said early preparation was essential to ensure a smooth transition and avoid penalties. It encouraged affected businesses to begin the necessary procedures well before the deadlines, including selecting a suitable accredited service provider, entering into an agreement and completing the required technical integration.

Entities must also follow the prescribed procedures through EmaraTax, the FTA's digital tax services platform, as part of the process of joining and activating the system.

For businesses and other persons with annual revenues below Dh50 million, the deadlines are later. They must appoint an Accredited Service Provider by March 31, 2027, and implement the e-Invoicing System no later than July 1, 2027.

Under the applicable legislation, a penalty of Dh5,000 applies for every month or part of a month of delay in implementing the system. The same penalty applies where an entity fails to appoint an accredited service provider within the prescribed timeframe. The measure is intended to encourage timely compliance as the UAE advances its digital transformation of tax administration and business processes.

The FTA said the system had undergone testing during a pilot phase ahead of mandatory implementation. The exercise assessed the effectiveness of technical integration, the user experience and the preparedness of the participating parties to meet the system's operational requirements.

The authority has also adopted a phased approach and maintained communication with stakeholders in both the public and private sectors to help ensure that businesses are ready before their respective implementation deadlines.

To facilitate the transition, the FTA said it had introduced flexible implementation arrangements and simplified procedures aimed at minimising disruption to business operations while supporting compliance with the regulatory framework.

As part of its awareness programme, the authority has been conducting in-person events across the UAE alongside virtual information sessions. These initiatives are designed to explain which businesses and entities fall within the scope of the system, the applicable implementation requirements, the process of connecting to the platform and the steps required for activation through EmaraTax.

In September 2026, the FTA organised an expanded joint meeting in Dubai, bringing together accredited e-Invoicing service providers, businesses and other entities covered by the system, as well as authority officials and specialists.

The meeting gave participants an opportunity to engage with accredited service providers and assess which would be suitable for their operational requirements. It also provided guidance on the legal and regulatory framework, the procedures for joining the system and the practical steps involved in implementation.

The gathering was intended to strengthen coordination between businesses and service providers and support an orderly transition to the new digital invoicing framework. The FTA described e-invoicing as an important development in improving compliance through secure, efficient and standardised digital processes.

The authority has called on all persons subject to the system to familiarise themselves with the relevant legislation, requirements, procedures and guidance well ahead of their respective deadlines. Further information and implementation guidance are available on the FTA's official website under its e-Invoicing section.

Submitting a court memorandum containing offensive or insulting language can potentially expose an individual to criminal proceedings in the UAE. However, the law also recognises the right of litigants to present their cases and defend their legal interests without automatically facing defamation charges over statements made during judicial proceedings.

Article 429 of Federal Decree-Law No. 31 of 2021, promulgating the Crimes and Penalties Law, provides that no crime is committed in respect of libel or slander included in the oral or written defence of litigants before courts or investigating authorities, provided the statements remain within the limits of the right of defence.

This protection is particularly relevant in disputes where parties exchange allegations concerning financial responsibilities, personal conduct or family matters. However, it does not give litigants unrestricted freedom to use offensive language or make irrelevant personal attacks in their submissions.

In a case where a woman described her former husband as 'very stingy' in a memorandum submitted to court, the question of criminal liability would depend on the circumstances and whether the expression fell within the legitimate scope of her defence.

The former husband may approach the authorities and lodge a criminal complaint, but filing a complaint does not establish that an offence has been committed. The court must consider the language used, its context and its connection with the issues being decided.

Article 43 of Federal Decree-Law No. 34 of 2021, concerning Countering Rumours and Cybercrimes, also provides for imprisonment and/or a fine ranging from Dh250,000 to Dh500,000 for insulting another person or attributing a quality to them that could expose them to punishment or public contempt through an information network, information technology equipment or an information system.

However, the application of this provision requires examination of the manner in which the alleged offence was committed. The electronic submission of a court memorandum does not, by itself, establish criminal liability under the Cybercrime Law.

Ultimately, Article 429 provides an important safeguard for litigants exercising their right of defence. Nevertheless, parties should ensure that their court submissions remain focused on relevant facts, legal arguments and issues in dispute, rather than unnecessary personal criticism.

The publication of a photograph or video on social media may appear harmless to the person sharing it, particularly when the footage is recorded in a public place. However, under UAE law, filming another person and circulating the footage without permission can have serious legal consequences, especially when the publication intrudes on privacy, damages reputation or exposes the individual to ridicule or public contempt.

A recent ruling by the Abu Dhabi Family, Civil and Administrative Cases Court illustrates the financial consequences of such conduct. The court ordered an individual to pay Dh20,000 in compensation after finding that he had filmed another person without consent and subsequently published the footage on TikTok and Snapchat, accompanied by comments that affected the complainant's reputation and personal and professional life.

The decision is significant because it demonstrates that the consequences of unauthorised filming and online publication are not necessarily confined to criminal punishment. A person responsible for violating another individual's privacy may also face a separate civil claim for compensation covering the harm caused by the conduct.

The complainant had sought Dh450,000, claiming material, moral, psychological and social damages, including loss of income. The court, however, awarded Dh20,000 after assessing the circumstances and the evidence presented. A previous criminal conviction, under which the defendant had been fined Dh50,000 and his mobile phone confiscated, had already established the criminal responsibility arising from the incident. The conviction was upheld on appeal.

The case brings into focus several important aspects of UAE legislation, particularly the provisions governing cybercrime, personal privacy, defamation and compensation for moral damage. It also raises a practical question for social media users: where does the freedom to record and share content end, and where does the legal right to privacy begin?

Unauthorised Filming Can Constitute a Criminal Offence

The principal legislation governing such conduct is Federal Decree-Law No. 34 of 2021 on Countering Rumours and Cybercrimes. The law, which came into effect on January 2, 2022, addresses the misuse of information technology to invade privacy, expose personal information and damage another person's reputation.

Article 44 is particularly relevant to unauthorised filming and publication. It criminalises the use of information networks, information technology or information systems with the intention of invading another person's privacy or the sanctity of their private or family life, without consent, except in circumstances authorised by law.

The provision specifically covers recording, transmitting, broadcasting or disclosing conversations and audio or visual material. It also includes taking photographs of third parties in public or private places, transferring or publishing electronic photographs, and publishing news, images, scenes, comments or information, even when the material is true and genuine, if this is done with the intention of harming the individual.

A person convicted under Article 44 can face imprisonment for at least six months and a fine ranging from Dh150,000 to Dh500,000, or either of these penalties.

An important feature of this provision is that the protection is not restricted to private premises. The law expressly refers to photographs taken in both public and private places. Consequently, the argument that an individual was filmed in a public setting does not, by itself, provide a defence against an allegation of unlawful recording or publication.

However, the circumstances and intention behind the conduct remain important. Not every incidental appearance in a photograph or video automatically amounts to a criminal offence. The statutory requirements, including the intention to invade privacy or harm the individual, must be considered in the context of the evidence.

The distinction is particularly important for people who regularly record and upload videos of public encounters, workplace incidents, disputes or interactions with strangers. The fact that a recording can be made using a mobile phone does not mean that it can lawfully be circulated without regard to the rights of the people appearing in it.

Online Insults and Defamation Carry Separate Legal Consequences

Privacy violations are not the only legal risks associated with publishing videos on social media. The comments, captions and descriptions accompanying the footage can independently attract criminal liability if they amount to insult, defamation or slander.

Article 43 of the Cybercrimes Law addresses the use of information networks and information technology to insult another person or attribute a characteristic to them that could expose them to punishment or public contempt.

The prescribed punishment is imprisonment and/or a fine ranging from Dh250,000 to Dh500,000. The law also provides for an aggravated offence when the conduct is directed against a public official or a person entrusted with a public service in connection with the performance of their duties.

This provision is particularly relevant to social media publications because a statement does not have to appear in a newspaper or conventional media outlet to attract legal scrutiny. A TikTok video, Snapchat story, Instagram post, online comment or other electronic publication can become the subject of criminal proceedings if its content satisfies the legal requirements.

The Crimes and Penalties Law, Federal Decree-Law No. 31 of 2021, also contains provisions dealing with defamation, slander and violations of private and family life. Article 431 addresses the unlawful recording of private conversations, photographing individuals in private places and publishing information, photographs or comments concerning their private or family lives, even where the information is true.

These provisions demonstrate an important distinction in UAE law: the truth of published material does not automatically make its disclosure lawful. An individual may still face legal consequences if the manner of obtaining or publishing the information violates another person's protected privacy.

At the same time, not every negative comment amounts to criminal defamation. The nature of the statement, its context, the person against whom it is directed and the applicable statutory requirements are relevant when determining whether an offence has occurred.

Civil Liability Extends Beyond Criminal Punishment

A criminal conviction does not necessarily bring an online privacy dispute to an end. The affected individual may pursue a separate civil claim seeking compensation for the harm caused by the unlawful conduct.

The UAE's Civil Transactions Law provides the legal foundation for such claims. Federal Decree-Law No. 25 of 2025 promulgating the new Civil Transactions Law came into force on June 1, 2026, replacing the previous Civil Transactions Law of 1985.

Article 246 establishes the general principle that a person who causes harm to another is obliged to compensate the injured party. The provisions also clarify that civil liability does not prejudice criminal liability when the conditions for both are satisfied.

This means that an individual responsible for unlawfully recording and circulating another person's video may face criminal proceedings as well as a civil claim for damages.

Article 254 is particularly significant because it expressly recognises moral harm as a basis for civil liability. It identifies infringements of another person's freedom, honour, reputation, social standing or financial status as forms of moral damage.

This recognition is important in cases involving online humiliation and reputational injury. An individual does not necessarily have to demonstrate a direct financial loss to establish that a legally recognisable injury has occurred. Damage to dignity, reputation and social standing can itself justify compensation.

Article 255 further provides that compensation must be assessed according to the extent of the loss suffered and the loss of profit, provided that the loss of profit is a natural consequence of the harmful act.

The court therefore has to consider both the nature of the injury and the evidence supporting the amount claimed.

Why the Court Awarded Dh20,000 Instead of Dh450,000

The Abu Dhabi ruling illustrates the difference between establishing liability and proving the amount of compensation.

The complainant sought Dh450,000, claiming that the unauthorised recording and publication had caused material, moral, psychological and social harm. He also alleged that the incident had affected his professional activities and income.

However, the court awarded Dh20,000 after considering the circumstances of the case and the nature of the damage established before it.

A significant factor was the earlier criminal conviction against the defendant. The criminal court had imposed a Dh50,000 fine and ordered the confiscation of his mobile phone. The conviction was subsequently upheld on appeal.

The criminal judgment provided an important evidential foundation for the civil proceedings. Under the applicable principles governing the relationship between criminal and civil cases, a final criminal judgment establishing the commission of an offence and its attribution to the accused can have binding effect on the civil court in respect of those established matters.

This does not mean that the civil court must automatically accept every amount claimed by the injured party. The existence of wrongdoing and the extent of compensable damage are separate questions.

In this case, the court recognised the harm caused to the complainant's privacy, reputation and psychological well-being but did not accept the full compensation sought.

The distinction is important for anyone considering a civil claim arising from online abuse. A criminal conviction may establish the defendant's responsibility for the underlying act, but the claimant must still provide an adequate basis for the compensation sought.

For example, a claim for lost income may require financial records, evidence of cancelled contracts, loss of business opportunities or other documentation demonstrating a direct connection between the publication and the alleged financial consequences.

A general assertion that a person's reputation or professional activities have suffered may not, by itself, establish the amount of financial loss claimed.

The ruling therefore reinforces the principle that compensation is determined by the harm proved before the court rather than simply by the figure requested in the lawsuit.

One of the important legal aspects of the Abu Dhabi case is the relationship between criminal proceedings and civil compensation claims.

Where the same conduct gives rise to both criminal and civil liability, the two proceedings serve different purposes. Criminal proceedings determine whether an offence has been committed and what punishment should follow. Civil proceedings focus on compensating the person who has suffered legally recognised harm.

A final criminal judgment can therefore play a decisive role in subsequent civil litigation. Where it establishes that the defendant committed the act and identifies the person responsible, the civil court is generally bound by those findings within their legally defined scope.

However, the civil court retains the responsibility of determining the extent of the damage and the appropriate compensation.

This distinction is particularly relevant in online privacy cases, where the victim may suffer several forms of harm. These could include embarrassment, emotional distress, damage to professional standing, loss of business opportunities and disruption to family or social relationships.

Evidence such as screenshots, recordings, publication dates, comments, messages, witness statements and financial records may help establish the nature and extent of the damage.

Does Filming Someone in Public Automatically Require Consent?

The question of consent is particularly relevant in an age when mobile phones and social media have made recording public encounters commonplace.

People routinely film events, public gatherings, road incidents, workplace interactions and disputes. However, the legal position is more complicated than simply determining whether the recording took place in a public or private location.

Article 44 of the Cybercrimes Law expressly includes photographing third parties in public as well as private places. The provision must nevertheless be read as a whole, including its requirement concerning the intention to invade privacy or the sanctity of private or family life.

There are also legally recognised circumstances in which photography or publication may be permitted, including certain forms of public-interest activity and authorised coverage.

The Copyright and Neighbouring Rights Law, Federal Decree-Law No. 38 of 2021, contains additional provisions relevant to the use of photographs and recordings. Article 45 generally restricts the retention, display or publication of photographs and audio or video recordings made under an agreement without the person's authorisation, subject to specified exceptions.

These include certain publicly occurring incidents, government events and activities organised for the public in public places, and publication permitted by competent authorities in the public interest. The provision also requires consideration of whether publication would offend the person's honour or reputation.

The practical implication is that being visible in a public place does not automatically give another person unrestricted permission to record, manipulate or publish footage in any context. Equally, consent requirements and exceptions must be assessed according to the circumstances rather than treated as an absolute prohibition on public photography.

What Should Individuals Do When Their Videos are Published Without Permission?

People who discover that their photographs or videos have been circulated online without authorisation should preserve the available evidence before taking steps to have the material removed.

Screenshots of the original publication, the account details of the person responsible, links to the content, accompanying comments and any subsequent circulation may be relevant to a complaint or legal claim.

Where the publication contains insulting or defamatory material, evidence of its impact may also be important. This could include communications from employers, clients or business associates, records of cancelled commercial arrangements and other documents demonstrating reputational or financial consequences.

An affected individual may consider reporting the matter to the competent authorities and seeking legal advice on the appropriate criminal and civil remedies. The circumstances will determine which provisions apply and whether a separate compensation claim is justified.

It is also important to recognise that deleting an original post does not necessarily eliminate legal responsibility for its earlier publication. Copies may have circulated, and the conduct may already have caused damage.

Social Media Users Cannot Ignore Their Legal Responsibilities

The Abu Dhabi ruling comes at a time when social media platforms have become powerful tools for communication, public commentary and the sharing of information. However, the ability to record and distribute content instantly also creates significant responsibilities for users.

The UAE's legal framework approaches online privacy violations through several complementary areas of law. The Cybercrimes Law addresses the unlawful use of digital platforms to invade privacy and damage reputations, the Crimes and Penalties Law provides additional protection against defamation and violations of private life, while the Civil Transactions Law establishes the basis for compensation when another person suffers harm.

The Dh20,000 award is not a standard compensation amount for every unauthorised video or photograph. Each dispute will depend on its own facts, the nature of the publication, the evidence of wrongdoing and the damage established before the court.

Nevertheless, the ruling sends an important message: recording someone without consent and sharing the footage in a manner that infringes their privacy or damages their reputation can have consequences beyond the removal of a social media post.

For individuals, influencers, content creators and businesses operating in the UAE, understanding these legal boundaries is increasingly important. What may begin as an ordinary social media upload can develop into a criminal case and a substantial civil liability claim.

Meta Platforms has reached settlements with two plaintiffs whose social media addiction claims were due to go to trial in Los Angeles next week, avoiding a potentially high-profile courtroom battle involving the company’s chief executive, Mark Zuckerberg.

Judge Carolyn Kuhl of the California Superior Court in Los Angeles County said the court had been informed the previous night that a settlement had been reached with the plaintiff identified in court documents as K.D.B. Meta had earlier settled with the other plaintiff scheduled to face trial, referred to as S.J.

The agreements mean Zuckerberg will no longer be required to testify in the proceedings.

“We will continue to defend ourselves in court, and we stand by our record,” a Meta spokesperson said in a statement, referring to the safeguards the company has introduced to protect teenagers using its platforms.

Emily Jeffcott, a trial counsel for K.D.B. representing Morgan & Morgan, said the firm remained committed to improving child safety on social media platforms and holding technology companies accountable.

“We remain committed to improving safety for kids on social media apps and holding tech companies accountable, and we are pleased to have brought this matter to a just resolution on behalf of our client,” Jeffcott said.

Following the settlements, Snap Inc. is the only defendant remaining in the trial.

Opening arguments are scheduled to begin next week unless Snap reaches an agreement with the plaintiffs. S.J. is a resident of Dolton, Illinois, while K.D.B. is from Richland, Mississippi.

The settlement with Meta represents the latest development in a growing wave of litigation over alleged social media addiction in California. The lawsuits accuse technology companies of designing platforms and features that encourage excessive use, particularly among children and teenagers, and contribute to mental health problems.

In August, Meta agreed to pay up to $18 billion to resolve claims brought by state attorneys general in proceedings before the US District Court for the Northern District of California. The agreement required the company to introduce additional safeguards governing the operation of platforms including Facebook and Instagram.

Meta had avoided another trial in July after R.K.C. dropped his case against the company following settlements with Google and TikTok. P.M-Y also dismissed her case in August, two months before her scheduled trial, after reaching a settlement with TikTok.

The litigation has already produced a significant jury verdict. In the first bellwether trial, K.G.M. secured a $4.2 million judgment against Meta and a further $1.8 million judgment against Google.

The cases form part of coordinated proceedings known as Social Media Cases JCCP, California Superior Court, case number 5255.

Franchising plays an important role in the international business sector for companies wishing to establish or expand their presence in the United Arab Emirates. It has become popular among businesses in sectors such as restaurants, retail, hospitality, healthcare, education and professional services, allowing them to establish a recognised brand in new markets with relatively limited investment.

However, whilst franchising offers many benefits, it can also create a complex relationship between the two parties. The franchisor wants to ensure that its brand maintains consistent standards and generates regular income. Meanwhile, the franchisee will have invested heavily in the business, including staff, premises, equipment and marketing, and will want to ensure that it receives the appropriate level of support and protection, as well as a reasonable opportunity to recover its investment.

Issues can arise between the two parties over matters such as royalties, sales, supply arrangements, territorial rights, operational standards and termination. These can lead to substantial commercial disputes if the franchisor and franchisee cannot reach an agreement. Disagreements may also arise over how the parties have interpreted the contract.

Unlike some other jurisdictions, there is currently no standalone federal law governing franchise relationships in the UAE. Instead, general contractual principles, commercial laws, intellectual property protection, competition laws and any relevant legislation governing registered commercial agencies may apply.

Depending on how the franchisor and franchisee have structured their relationship, they may have different rights and remedies available to them.

1. Misrepresentation and Investment Issues

Some franchise disputes arise before the first outlet opens. The franchisee may invest heavily in the franchise based on financial projections, market analysis and assurances provided by the franchisor. Problems can arise if the business does not perform as expected.

There are often disputes over sales, profitability, market potential, set-up costs and the level of support provided. The franchisee may argue that key information was not disclosed or that the financial projections were misleading. The franchisor may argue that the projections were indicative and that the franchisee is responsible for managing its own business.

Although there is no general statutory requirement to provide information in the form of a franchise disclosure document, rules are still in place to prevent either party from misrepresenting key information.

The new Federal Decree-Law No. 25 of 2025, which replaced the previous Civil Transactions Law, introduces more detailed provisions. Articles 121 and 122 outline the requirement for parties to act in good faith and disclose key information. If they fail to do so, they may be held liable and, in appropriate circumstances, may also seek termination of the agreement.

This is particularly relevant to franchise relationships, as one party may have significantly more information about the business than the other.

2. Royalties, Marketing and Financial Issues

Financial disagreements are among the most common causes of disputes between franchisees and franchisors. Most franchise agreements include an initial fee, ongoing royalties and, sometimes, a contribution to a central marketing fund.

Royalties are commonly paid as a percentage of gross sales, although some agreements provide for fixed royalties or a minimum monthly payment. Disputes can arise over what constitutes gross revenue, discounts, refunds, online sales, delivery platform fees and when payments should be made.

The franchisee may argue that certain sales should not be included in royalty calculations, such as transactions made through third-party websites. The franchisor may argue that all sales generated through the franchise should be included.

Marketing can also cause disputes. The franchisee may have concerns about how centrally collected funds are spent, whether the franchisor has provided adequate marketing and whether the franchisee is receiving a fair share of the benefits.

The franchise agreement should include details of accounting standards, reporting deadlines, inspection rights and dispute procedures. If the franchisee does not provide accurate information about its revenue, the franchisor may seek unpaid royalties. It may also be entitled to claim interest, where applicable, contractual penalties and any other available remedies.

3. Territory and Competition

Territorial issues can often cause disputes, particularly when the franchisee has invested heavily in developing a market.

The franchise agreement may state that the franchisee has exclusive rights to operate in an emirate, city or specific area. Problems can arise if the franchisor opens another outlet in the same area, appoints another franchisee or sells products online to customers within the protected territory.

Often, the issue relates to the meaning of exclusivity. Does it mean that the franchisor cannot open any company-owned outlets? Does it include deliveries, e-commerce, institutional clients or sales within shopping centres? Does exclusivity cover the entire emirate or just a specific trading area?

These matters should be carefully outlined in the franchise agreement. The franchisee may feel that appointing another operator breaches its investment rights, whilst the franchisor may argue that the agreement reserved certain distribution channels or locations.

If the relationship falls under Federal Law No. 3 of 2022 on the Regulation of Commercial Agencies, this can become a key consideration. The law sets out the statutory requirements for qualifying registered commercial agencies, including exclusivity. It is important to determine whether the agreement qualifies as a registered commercial agency. This will depend on the legal status of the franchisor and franchisee, the nature of the appointment and the applicable registration requirements. Registered commercial agencies can have significantly different legal consequences.

There are also competition-related considerations. Federal Decree-Law No. 36 of 2023 governs anti-competitive agreements and the abuse of a dominant position. Exclusive purchasing arrangements, territorial restrictions and other vertical agreements may need to be examined under this framework. The franchisor cannot assume that all restrictions included in the franchise agreement are automatically acceptable.

4. Standards, Supply and Quality Control

Standardisation across all outlets is fundamental to a franchise. Customers expect the same products, quality of service and overall experience, regardless of which outlet they visit. The franchisor will therefore often set standards that the franchisee must meet. These may include requirements relating to staff training, food preparation, premises, uniforms, equipment and quality control.

However, disputes can arise if the franchisee considers these standards too strict. The franchisor may require the franchisee to purchase ingredients, equipment or branded items from approved suppliers. The franchisee may argue that it can source items of the same quality locally at a lower cost.

Problems can also arise when there are supply interruptions. If an approved supplier is unable to provide the necessary items, the franchisee may struggle to meet sales targets or maintain operational standards. The franchisor may nevertheless insist that the franchisee follows the approved sourcing requirements to protect the brand.

There may also be disputes over refurbishment, technology upgrades and amendments to operating manuals. The franchisee may feel that it is being asked to spend substantial amounts of money upgrading its outlet, particularly if the franchise agreement does not clearly specify who is responsible for the costs.

The agreement should outline which standards are essential to the brand and which changes may require additional expenditure. It should also include details of inspection rights, timeframes for rectifying issues, approved suppliers and responsibility for supply disruptions.

The franchisor must exercise its inspection rights in good faith, while the franchisee cannot simply disregard legitimate quality requirements.

5. Intellectual Property

Intellectual property plays a key role in franchising. The franchisee pays for the right to use an established brand, trademarks, systems, operating manuals and know-how. Disputes can arise over the ownership, use and protection of these intellectual property rights.

The principal protection for trademarks is provided by Federal Decree-Law No. 36 of 2021. However, copyright and industrial property legislation may also protect relevant business documents and materials.

Common issues include the unauthorised use of trademarks, modifications to logos, misleading advertising, disclosure of confidential information and the use of proprietary business methods.

The franchisee may also have concerns about whether the franchisor has obtained sufficient protection for its trademarks in the UAE. If the brand is not registered or has not received adequate protection, this can create uncertainty for the franchisee, particularly if it has invested in building its reputation.

Once the relationship has ended, a former franchisee may wish to continue using the branding. This may include signage, packaging and social media accounts. The franchisee may argue that it needs time to clear its stock and fulfil existing commitments. The franchisor, however, may consider such continued use an infringement of its intellectual property rights.

Well-drafted agreements should include details of trademark ownership, the duration of the licence, permitted uses, quality control, confidentiality, infringement and the steps that must be taken immediately after the relationship ends.

6. Termination, Renewal and Compensation

Termination is often the most financially significant stage of a franchise dispute. The franchisor may wish to terminate the agreement because of non-payment of royalties, poor performance, repeated breaches of the agreement, reputational damage or failure to meet expansion targets.

The franchisee may dispute the decision, particularly if it believes the breach is minor, has already been rectified or resulted from the franchisor's failure to provide the agreed contractual support.

Disputes can also arise if the franchisee wants to exit the agreement early. This may be due to poor financial performance, increased costs, changes in the market or disagreements over management. However, simply deciding to leave the relationship does not automatically give the franchisee the right to terminate the agreement without consequences.

Unregistered franchise arrangements will mainly be governed by the agreement, subject to applicable UAE legal principles, including the requirement to act in good faith and not abuse contractual rights.

If the relationship constitutes a registered commercial agency, Federal Law No. 3 of 2022 will apply. It sets out specific rules relating to expiry, early termination and non-renewal, including notice requirements and compensation, where applicable.

Article 26 allows the parties to agree to arbitration for disputes relating to commercial agencies. Article 24 also provides for a role for the Commercial Agencies Committee in resolving disputes. It is important to consider the applicable dispute resolution procedures before initiating proceedings.

7. Customer Complaints

A franchise dispute may not be confined to the franchisor and franchisee. Poor product quality, misleading advertising, defective products, inadequate services or failures to meet customer data obligations may expose the business to regulatory action and consumer complaints.

Federal Law No. 15 of 2020 governs consumer protection in relation to goods and services supplied within the UAE. Its scope includes relevant activities carried out by commercial agents. It outlines obligations concerning product quality, price transparency, consumer rights and supplier responsibilities.

Disputes can arise if the franchisor believes that a problem resulted from the franchisee's failure to follow the correct procedures, while the franchisee argues that it was caused by centrally supplied products or faulty equipment.

The franchise agreement should outline who is responsible for product recalls, handling customer complaints, refunds, warranties, regulatory inspections and compensation claims. However, contractual arrangements between the parties do not remove their statutory obligations towards consumers.

8. Dispute Resolution

The method of resolving a dispute can affect how quickly it is settled. UAE franchise agreements commonly include a dispute resolution clause providing for proceedings before the courts or arbitration under Federal Law No. 6 of 2018.

International franchisors may prefer arbitration because it offers flexibility in choosing the language, location and decision-makers. UAE-based franchisees may prefer local courts, particularly if the dispute relates to local operations or assets.

There are also separate legal and judicial systems in place in the Dubai International Financial Centre and Abu Dhabi Global Market. If the agreement is connected to either of these jurisdictions, the parties should consider the applicable requirements.

With the introduction of the new Civil Transactions Law, it is important to consider its provisions. Article 120 sets out principles for interpreting contractual terms, including considerations of justice and good faith. Article 221 also provides that contractual obligations must be performed in good faith.

These provisions may become relevant to long-term franchise agreements, particularly where disputes concern unclear obligations, changing market conditions or the exercise of contractual discretion. The relevant transitional provisions should also be considered if the agreement was entered into before June 1, 2026.

Avoiding Disputes

Most franchise disputes do not arise from a single event. They often develop through an accumulation of disagreements over financial obligations, commercial expectations, operational control and the allocation of risk.

The franchisor will want to maintain brand consistency without imposing obligations that are commercially unrealistic or inadequately defined. The franchisee must understand the financial and operational commitments it is accepting, as well as the limitations relating to territorial rights and intellectual property licences.

Clear contractual terms covering royalties, marketing, inspection rights, supply arrangements, performance targets, renewal and post-termination obligations can substantially reduce uncertainty. Both parties should maintain accurate financial records, inspection reports, correspondence and evidence of contractual performance.

As there is no specific franchise law in the UAE, considerable importance must be attached to how franchise agreements are structured. With the introduction of the new Civil Transactions Law in June 2026, reviewing existing contractual arrangements is particularly important.

Ultimately, a successful franchise relationship depends on a realistic allocation of commercial risk, transparent financial arrangements and a legal framework that enables both parties to protect their legitimate interests without undermining the business they have built together.

Social media and messaging platforms have made it easier than ever to express opinions, share experiences and raise complaints. A disagreement that might once have remained a private conversation can now reach hundreds or thousands of people within minutes. But cross the line from legitimate criticism into a criminal offence? In the UAE, the answer depends on the language used, the context and the provisions of the applicable law.

The UAE takes offences involving personal dignity and reputation seriously. A communication does not escape legal scrutiny simply because it was made during a personal disagreement, sent through a messaging application or published as part of a commercial complaint. The central question is whether the words and circumstances satisfy the requirements of an offence under the applicable legislation. Understanding that distinction is essential before making or forwarding potentially damaging statements.

The Legal Framework Governing Online Defamation

The principal legislation dealing with digital insult and defamation is Federal Decree-Law No. 34 of 2021 on Countering Rumours and Cybercrimes. Article 43 addresses the use of an information network, information technology means or an information system to insult another person or attribute a quality to them that could expose them to punishment or public contempt.

The prescribed penalty is imprisonment and/or a fine ranging from AED 250,000 to AED 500,000. The law also identifies an aggravating circumstance where the offence is committed against a public official or a person entrusted with a public service during, or because of, the performance of their duties.

Other provisions of the Crimes and Penalties Law may also be relevant. Articles 425 and 426 of Federal Law by Decree No. 31 of 2021 deal with libel and slander, while Article 427 sets out penalties for specified circumstances involving telephone communications, direct statements and written communications. The precise provision depends on the nature of the alleged conduct and the circumstances in which it occurred. These offences have distinct statutory elements and should not be treated as interchangeable.

What Conduct May Create Criminal Exposure?

A critical comment, disagreement or expression of dissatisfaction does not automatically amount to a criminal offence. The assessment depends on the language used, the context in which it appears, the method of communication and whether the legal requirements of the relevant offence are satisfied.

Examples of conduct that may attract legal scrutiny include publishing allegations that could expose an identifiable person to punishment or public contempt, posting insulting or degrading remarks about an individual on social media, sending abusive electronic messages, or circulating potentially defamatory allegations in online groups and digital communities.

The distinction becomes clearer when considered in everyday situations. A customer who describes a delayed delivery or unsatisfactory service is not necessarily committing an offence. The position may be different if the same person makes unsupported allegations of criminal conduct against a named employee or uses language intended to personally degrade them. Similarly, raising a workplace grievance through an employer's established procedures is different from publicly targeting a manager or colleague with insulting remarks.

Can a Private WhatsApp Message Lead to Criminal Liability?

One common misunderstanding is that a statement can amount to defamation only if it is published publicly. Article 43, however, refers broadly to the use of information networks, information technology means and information systems. Its wording does not expressly restrict the offence to material accessible to the general public.

A private WhatsApp message, direct message or communication shared within a closed group should not, therefore, be assumed to fall outside the law. The number of recipients and the circumstances of the communication may be relevant when assessing the allegation, but privacy alone does not settle the question of criminal liability. The applicable legal provision must be considered alongside the actual content and context of the exchange.

Online Reviews and Business Complaints

The issue has particular relevance for businesses, franchise operators, hospitality companies and service providers, for whom online reviews can influence customer confidence and commercial reputation. Customers must be able to describe their experiences and raise genuine concerns, and a negative review is not, by itself, a criminal offence.

The legal distinction lies between reporting an unsatisfactory experience and publishing personal insults or allegations that may expose an individual to criminal liability. Describing a delayed delivery or poor customer service is materially different from making an unsupported accusation of criminal behaviour against an identifiable employee.

Businesses also need to exercise restraint when responding to online criticism. Threatening customers or engaging in personal attacks can turn a manageable complaint into a more complicated dispute. A better approach is to preserve the relevant communication, examine the substance of the complaint and respond through appropriate commercial or legal channels.

The Importance of Digital Evidence

In cases involving online communications, the available electronic material may play an important role in establishing what was said, how it was communicated and who was involved. Relevant evidence may include screenshots of posts, comments and reviews, complete WhatsApp conversations and other electronic messages, email correspondence, website publications and available account or publication records.

A screenshot, however, may not tell the whole story. Its authenticity, completeness, source and surrounding context can all become relevant. Wherever possible, the original communication and the complete conversation should be preserved, together with relevant account and publication details. Both complainants and those responding to allegations should avoid selectively editing, deleting or altering material that may later be required.

Removing a post or message does not necessarily eliminate evidence that has already been preserved. Nor does deletion, by itself, remove potential criminal liability arising from the original communication.

What Should a Person Do After a Complaint?

Anyone who receives notice of a criminal complaint relating to an online communication should first establish precisely what is being alleged. This includes identifying the disputed post or message, the date and circumstances of publication, the person concerned and the legal provision being invoked. Relevant messages, emails and publication records should be preserved rather than deleted or modified.

A proper legal assessment should then examine whether the alleged conduct falls within the relevant offence, whether the content meets the statutory requirements and whether the electronic evidence is authentic and complete. Any applicable legal exceptions or defences, together with the appropriate procedural steps during an investigation or subsequent proceedings, must also be considered.

Responding emotionally, making further accusations or attempting to remove relevant material without understanding the legal implications can complicate matters. Seeking legal advice at an early stage can help establish the nature of the allegation, protect relevant evidence and determine an appropriate course of action.

Conclusion

The UAE's legal framework places considerable importance on protecting personal dignity and reputation, including in the digital environment. Article 43 of the Cybercrime Law provides for substantial criminal penalties for specified forms of online insult and damaging attribution. Depending on the circumstances, provisions of the Crimes and Penalties Law may also apply.

Individuals should consider the legal implications before publishing or forwarding statements that could damage another person's reputation. Businesses, meanwhile, need clear procedures for handling customer complaints and responding to online criticism. In an environment where a message can be circulated widely within seconds, responsible digital communication is not simply a matter of professional courtesy. It is an important part of managing legal and reputational risk in the UAE.

Employers in the United Arab Emirates have the authority to establish internal workplace rules governing employee conduct, disciplinary penalties, promotions and rewards. However, this authority is not unlimited. The rules must comply with the UAE Labour Law and its Executive Regulations, and employers cannot introduce workplace policies that undermine the statutory rights of employees.

The legal framework governing these arrangements is primarily set out in Federal Decree-Law No. 33 of 2021 on the Regulation of Labour Relations, as amended, and Cabinet Resolution No. 1 of 2022 concerning its Executive Regulations. Together, these provisions establish the obligations of employers in organising workplace operations, communicating internal policies and ensuring that disciplinary measures are imposed through fair and legally compliant procedures.

A significant requirement under the legislation is that establishments employing 50 or more workers must establish formal regulations covering work instructions, disciplinary penalties, promotions, bonuses and procedures for terminating employment relationships. These regulations must also be communicated to employees in a language they understand.

The Legal Authority to Establish Internal Workplace Rules

Article 13 of Federal Decree-Law No. 33 of 2021 sets out the obligations of employers, including the responsibility to establish rules governing the organisation of work. These include regulations covering work instructions, disciplinary sanctions, promotions, rewards and other internal policies.

The provision gives employers the flexibility to introduce workplace procedures suited to the nature and operational requirements of their businesses. Such policies can address employee responsibilities, workplace discipline, performance expectations, career progression and incentive arrangements.

However, the authority to establish internal regulations must be exercised within the boundaries of the applicable labour legislation. An employer cannot use an internal policy to introduce conditions that contradict the law, reduce statutory employee entitlements or circumvent the protections available under the employment framework.

Article 14 of Cabinet Resolution No. 1 of 2022 provides further details on how these regulations must be formulated and implemented.

Mandatory Regulations for Establishments With 50 or More Workers

Under Article 14 of the Executive Regulations, establishments employing 50 or more workers are required to establish regulations organising workplace operations. These must cover work instructions, disciplinary penalties, promotions, bonuses and procedures for terminating the employment relationship.

The regulations must satisfy several legal requirements:

First, the employer must ensure that the internal rules do not contradict the provisions of the Labour Law, its Executive Regulations or other applicable legislation.

Second, the disciplinary regulations must clearly identify the penalties that may be imposed on employees who commit workplace violations. They must also specify the circumstances, conditions and procedures governing the imposition of such penalties.

Third, workplace instructions must address essential operational matters, including daily working hours, weekly rest days and official holidays. They must also incorporate the necessary measures and precautions to prevent workplace injuries and fire hazards.

Fourth, regulations governing promotions and bonuses must establish the relevant eligibility criteria, standards and conditions. This is intended to provide employees with clarity about the basis on which career advancement and financial incentives are awarded.

The employer must also communicate these regulations to employees through any available means and ensure that they understand the provisions in a language they can comprehend. Merely preparing an internal policy document without making employees aware of its contents would not satisfy this communication requirement.

What Disciplinary Penalties Can Employers Impose?

While employers have the right to maintain workplace discipline, the types of disciplinary sanctions they can impose are restricted by Article 39 of the Labour Law.

The legislation identifies seven permissible categories of disciplinary penalties for employees who violate the Labour Law, its Executive Regulations or the decisions issued in implementation of the legislation.

These include a written caution, a written warning and deductions from wages not exceeding the equivalent of five days' wages per month.

An employer may also suspend an employee from work for a period not exceeding 14 days, without payment of wages for the suspension period.

Other permissible measures include withholding a periodic increment for a period not exceeding one year, where the establishment operates a system of periodic increments, and withholding promotion for a period not exceeding two years in establishments that have an established promotion system.

The final disciplinary measure is dismissal from service, while preserving the employee's entitlement to end-of-service gratuity.

These provisions mean that employers cannot independently introduce additional forms of disciplinary punishment outside the categories permitted by law. Internal regulations must identify the applicable sanctions and explain the circumstances in which they may be imposed.

The severity of the penalty must also correspond to the seriousness of the violation. Employers cannot treat every workplace breach as equally serious or impose disproportionate sanctions without considering the circumstances.

Conditions and Procedures for Imposing Disciplinary Sanctions

Article 24 of Cabinet Resolution No. 1 of 2022 establishes specific safeguards governing the imposition of disciplinary penalties.

Under this provision, the penalty must be proportionate to the nature and seriousness of the violation. Several factors must be considered when determining the appropriate sanction.

These include the extent to which the violation affects the confidentiality of work-related information, its impact on the health and safety of employees, the financial consequences for the establishment and any damage to its reputation.

The employer must also consider whether the employee abused the authority entrusted to him or her, the employee's previous record of different types of violations and whether the incident involves any criminal or moral element.

Importantly, an employer cannot impose a disciplinary penalty without following the prescribed investigation procedure.

The employee must first be notified in writing of the violation alleged against him or her. The employee must then be given an opportunity to explain the circumstances, present a defence and respond to the allegations.

The employee's statements and defence must be documented in a report, which must be placed in the employee's personal file. The disciplinary penalty, if imposed, must also be recorded as part of the report.

The employer must subsequently notify the employee in writing of the nature and extent of the penalty, the reasons for imposing it and the consequences of repeating the violation.

These requirements are intended to ensure that disciplinary action is based on an established violation rather than an arbitrary decision by the employer.

Time Limits for Disciplinary Action

The Executive Regulations also prescribe time limits within which employers must initiate and conclude disciplinary proceedings.

An employee cannot be accused of a disciplinary violation more than 30 days after the employer discovers the incident.

Similarly, a disciplinary penalty cannot be imposed if more than 60 days have elapsed from the date on which the investigation was completed and the violation was established.

These time limits are important because they prevent employers from keeping allegations unresolved indefinitely or imposing disciplinary measures long after an incident has been investigated.

Employers should therefore ensure that workplace investigations are conducted promptly and that any disciplinary decision is taken within the statutory period.

Employees Have The Right to Challenge Disciplinary Decisions

The legislation also provides employees with the right to challenge disciplinary penalties imposed by their employers.

Under Article 24 of Cabinet Resolution No. 1 of 2022, an employee may submit a grievance to the establishment's management against any disciplinary penalty. The grievance must be accompanied by the decision or penalty being challenged.

The employer is required to notify the employee of the outcome of the grievance. Importantly, an employee must not suffer any adverse treatment merely for exercising the right to challenge a disciplinary decision.

This internal grievance mechanism does not take away the employee's right to pursue a labour complaint or claim through the appropriate legal channels.

For establishments employing 50 or more workers, the Executive Regulations impose an additional obligation. Employers must make their complaints and grievance procedures accessible to employees, either by displaying the relevant rules in a prominent place or through another appropriate means.

The procedure must clearly state that employees are entitled to submit complaints or grievances to the employer or its representative. It must also provide for written responses within a specified timeframe.

This requirement makes it important for larger establishments to maintain an accessible and properly documented employee grievance mechanism.

How Employers Can Structure Promotion And Reward Systems

Apart from disciplinary measures, the Labour Law recognises the employer's authority to establish systems governing promotions, periodic increments and bonuses.

Under Article 14 of the Executive Regulations, establishments with 50 or more workers must ensure that their promotion and reward regulations clearly identify the applicable standards and eligibility criteria.

Employers may develop performance-based incentive arrangements, promotion criteria and bonus structures according to their operational requirements. These may take into account individual performance, productivity, professional qualifications, experience, responsibilities and other relevant considerations.

However, the criteria must be clearly established and communicated to employees. Where a periodic increment or promotion system exists, disciplinary decisions involving the withholding of these benefits must also remain within the limits prescribed by Article 39 of the Labour Law.

For instance, the deprivation of a periodic increment cannot exceed one year, while the deprivation of promotion cannot exceed two years.

The legislation therefore allows employers to develop their own reward and career progression systems, while placing limits on how these benefits may be withheld as disciplinary measures.

Can Employers Introduce Their Own Rules Without Restrictions?

Although employers have considerable flexibility in establishing internal workplace policies, their authority is subject to statutory restrictions.

Article 41 of the Labour Law specifically provides that an employee cannot be subjected to disciplinary action for conduct outside the workplace unless that conduct is related to the employee's work.

The same provision prohibits imposing more than one disciplinary sanction for a single violation under Article 39.

Consequently, an employer cannot impose multiple disciplinary penalties for the same incident merely by describing the measures under different headings in its internal regulations.

Similarly, internal policies cannot override statutory requirements relating to working hours, weekly rest days, official holidays, wages, employee entitlements or other protections established under the Labour Law.

The employer's disciplinary authority must also be exercised through the investigation and notification procedures prescribed by the Executive Regulations.

These restrictions apply regardless of whether the internal policy has been formally approved by management or communicated to employees.

The Importance of Clear and Legally Compliant Workplace Policies

Internal workplace regulations serve an important purpose in establishing a transparent working environment. They help employers communicate operational expectations, maintain discipline, establish performance standards and provide employees with a clear understanding of their rights and responsibilities.

For businesses employing 50 or more workers, preparing these regulations is a specific statutory requirement under Article 14 of Cabinet Resolution No. 1 of 2022. Employers must ensure that their policies cover all the prescribed areas and are communicated to employees in a language they understand.

Even where an establishment employs fewer than 50 workers, the general obligations under Article 13 of the Labour Law and the statutory restrictions governing disciplinary action continue to apply. The 50-worker threshold does not give smaller businesses permission to disregard the legal framework governing employee discipline.

Ultimately, the UAE Labour Law seeks to balance the employer's legitimate need to manage business operations with the employee's right to fair treatment and protection against arbitrary disciplinary action.

Employers may establish their own workplace rules, including systems for penalties, promotions and rewards, but those rules must operate within the limits of the law. Clear policies, proportionate disciplinary measures, proper investigations and accessible grievance procedures are essential to ensuring that internal workplace regulations remain legally compliant.

The UAE has introduced greater flexibility into the rules governing share transfers in private joint-stock companies, opening up additional options for shareholders seeking to exit investments, bring in strategic partners or reorganise their ownership structures.

Ministerial Decision No. 83 of 2026, issued on April 5, 2026, sets out circumstances in which the statutory restriction period may be shortened to six or seven months, or waived altogether. The Decision follows amendments made by Federal Decree-Law No. 20 of 2025 to Federal Decree-Law No. 32 of 2021 on Commercial Companies.

The changes are intended to make investment and corporate restructuring more practical, but they do not give shareholders a general right to sell their holdings before the normal restriction period expires. Eligibility depends on the nature of the proposed transaction, the classification of the shares involved and compliance with the applicable regulatory and procedural requirements.

The Revised Share-Transfer Restriction Framework

Article 266 of the UAE Commercial Companies Law generally prohibits the transfer of shares in a private joint-stock company before publication of its balance sheet and profit and loss account for at least one financial year, calculated from the company's registration in the Commercial Register.

The 2025 legislative amendments replaced the previous two-year restriction with a one-year period and empowered the Minister of Economy and Tourism to alter that period or grant exemptions in specified circumstances.

Ministerial Decision No. 83 of 2026 gives effect to this authority by establishing alternative routes for early transfers, taking account of different investment arrangements and commercial requirements.

A separate statutory exemption applies to private joint-stock companies that offer securities through private placement and are listed on a UAE securities market. Such companies are outside the restriction period under Article 266(4), rather than merely qualifying for one of the reductions introduced by the new Decision. Other private joint-stock companies remain subject to the general rule unless they meet the conditions for a reduction or exemption.

When Can Shares Be Transferred After Seven Months?

Article 3(1)(a) of Ministerial Decision No. 83 of 2026 allows the restriction period to be reduced to seven months where the company has published two consecutive quarterly financial statements, reviewed by its duly licensed external auditor, following its registration in the Commercial Register.

The requirement for consecutive statements is important. Preparing internal management accounts or obtaining an auditor's review for only one reporting period would not, by itself, meet the prescribed test. The company must be able to demonstrate that both quarterly statements have been reviewed and published in accordance with the Decision.

For example, a company incorporated in January 2026 seeking to facilitate an early shareholder exit would need to establish that the required quarterly reporting had been completed and published before relying on this provision. The timing of incorporation alone would not establish eligibility.

The provision effectively links earlier access to share liquidity with financial transparency. Companies that anticipate changes in their shareholder structure during their first year should therefore put appropriate accounting, audit and publication arrangements in place from the outset.

Who Qualifies for the Six-Month Transfer Period?

The Decision identifies two separate circumstances in which the restriction period may be reduced to six months. The first concerns companies that approve multiple classes of shares and allocate qualifying classes to Professional Investors outside private subscription arrangements.

Under Article 3(1)(b), the shorter period applies only to the relevant qualifying share classes. It does not automatically extend to the company's other shares or to shareholders holding a different class.

Accordingly, where founders hold ordinary shares while a separate class has been allocated to Professional Investors, the founders cannot claim the six-month period simply because the company has introduced a qualifying investor class. The treatment of each class must be considered separately.

The second route relates to employee share incentive programmes. Article 3(1)(c) allows shares forming part of an adopted employee incentive programme to benefit from the six-month restriction period.

This provision could be significant for businesses seeking to retain senior executives and key employees through equity-based remuneration. It offers greater flexibility in structuring employee participation, although the reduced period is confined to shares covered by the approved programme. Other shares held by the same individuals do not automatically qualify.

The distinction is central to the new framework: eligibility is determined by the relevant share class or incentive arrangement, not simply by the identity or status of the shareholder.

Transaction-Specific Exemptions: When Does the Lock-Up Not Apply?

In addition to shortening the restriction period, Article 3(2) provides for exemptions in specified transaction scenarios. These include the entry of a strategic partner acquiring at least 10 per cent ownership, transfers involving tag-along and drag-along rights under the company's Articles of Association, capital restructuring through the creation of multiple share classes, and enforcement of a registered share pledge pursuant to a final court judgment.

The Decision also allows exemptions in special circumstances through a specific ministerial decision issued in coordination with the competent authority.

The strategic investor provision may be particularly useful to companies seeking external capital or a commercial partner during their initial years of operation. A company proposing to admit an investor who will acquire 15 per cent of its shares, for example, may be able to seek an exemption, provided the transaction meets the applicable conditions and receives the required approval.

However, the exemption should not be interpreted as permission for every existing shareholder to sell shares during the restriction period. Its application is confined to the shares involved in the qualifying transaction.

A similar distinction applies to tag-along and drag-along arrangements. The relevant rights must be reflected in the company's Articles of Association, and the transfer must involve one or more strategic partners as part of the same transaction. A contractual right contained only in a separate shareholders' agreement may not, on its own, establish eligibility under this exemption.

Companies should therefore examine their constitutional documents before entering into a transaction that depends on these provisions. The distinction between contractual transfer rights and the statutory conditions for an exemption could have a direct bearing on whether an early transfer can proceed.

Documentation and Approvals Required Before a Transfer

For companies seeking to rely on the Decision, establishing eligibility will require more than demonstrating that a particular transaction falls within one of the recognised categories. The supporting corporate records and documents must also reflect the proposed arrangement and satisfy the applicable requirements.

Depending on the route being pursued, companies should review their financial statements, shareholder register, Articles of Association, share-class records and relevant corporate approvals. In a proposed strategic investment, the transaction documents should clearly identify the shares to be transferred and establish the investor's resulting ownership percentage. Where different share classes are involved, the company's constitutional documents and shareholder records should support the classification and allocation of the relevant shares.

Existing contractual restrictions, shareholder consent provisions and other regulatory requirements also need to be considered. An exemption from the statutory restriction does not necessarily remove separate restrictions arising under the company's Articles of Association, shareholders' agreements or other applicable rules.

Article 4 requires the relevant decision on a reduction or exemption to be issued by the Ministry in coordination with the competent authority. Shareholders should not, therefore, assume that satisfying the commercial conditions alone gives them permission to complete an early transfer. The required approval remains an important part of the process.

Completion Notifications and Consequences of Non-Compliance

The Decision also imposes procedural obligations after approval has been granted. Under Article 4, the company must notify the Ministry and the competent authority within 10 working days of completing the procedures relating to the reduction or exemption. This includes updating the Commercial Register and the relevant particulars.

The Ministry may extend the period once, in coordination with the competent authority, where justified reasons are provided.

A further provision carries particular significance for transaction planning. Article 4(4) states that the Ministry's approval will be deemed null and void if the prescribed procedures are not completed.

This creates a risk even where a proposed transaction meets the substantive eligibility requirements. Failure to complete the necessary registration and notification formalities within the prescribed period could result in the loss of the approval.

Companies should consequently factor regulatory notifications, registration formalities and documentary requirements into their transaction timetable. Treating these steps as routine administrative work to be completed after the transfer could expose shareholders and investors to avoidable uncertainty.

Practical Implications for Shareholders and Investors

The 2026 framework marks an important development in the regulation of private joint-stock companies in the UAE. By allowing shorter restriction periods and exemptions for specified transactions, it provides additional scope for strategic investment, employee participation and corporate restructuring while retaining regulatory oversight.

The distinction between a reduced restriction period and a transaction-specific exemption remains particularly important. A six-month period available to a qualifying share class does not release other shareholders from the applicable restriction. Equally, the admission of a strategic investor does not create a general entitlement for unrelated shareholders to dispose of their holdings.

The Decision also repeals previous ministerial decisions dealing with the restriction period, including Ministerial Resolution No. 50 of 2025. Companies considering early share transfers should therefore assess their position under the current framework rather than rely on earlier approvals or assumptions about the applicable period.

Conclusion

Ministerial Decision No. 83 of 2026 gives UAE private joint-stock companies additional scope to facilitate early share transfers, attract strategic investors and undertake corporate restructuring. Its provisions offer practical alternatives to the general restriction period, particularly where companies have established appropriate financial reporting arrangements or are pursuing qualifying investment and employee incentive structures.

However, the exceptions are neither automatic nor available to every shareholder. Eligibility must be assessed against the particular shares involved, the nature of the transaction and the applicable approval and registration requirements.

For companies and investors considering an early transfer, the key question is not simply whether six or seven months have passed since registration. They must also establish that the proposed transaction meets the statutory conditions and can be properly approved, documented and registered.

The effectiveness of the new framework will ultimately depend on how carefully companies approach these transfers. Financial disclosure, sound corporate governance and timely regulatory compliance will remain central to making use of the additional flexibility.