Article 60 UAE Labour Law: Work Permit Fines & Penalties

Introduction
Written by: GetMyAccounting Editorial Team | Reviewed by: Vipul Gupta, Accounting & Tax Consultant | Last updated: 8 October 2026 | 11 min read
A company may recruit employees, issue working papers and bring them to the UAE, but have no job waiting for them after arrival. Another company may register people on paper only. Both situations deserve attention, but they should not be treated as the same offence without examining the facts.
Article 60 of the UAE Labour Law covers several employment violations, with separate provisions for fictitious employment. This guide explains the distinctions, penalties and checks that employers and employees can consider.
What Are the Penalties According to Article 60 of the UAE Labour Law?
Quick Answer
Under Article 60, there are penalties in the form of a fine of between AED 100,000 and AED 1,000,000 for certain violations, such as unauthorised employment, recruiting employees but failing to offer employment and misuse of an employment permit. Article 60(2) deals with fictitious employment aimed at evading labour-market regulations. Fines may be multiplied, and incentives may have to be returned. The settlement process for an Article 60(2) violation depends on specific conditions.
This guide discusses UAE private-sector employment contracts under Federal Decree-Law No. 33 of 2021, as amended. The law does not apply to federal and local government employees, armed forces, police and security forces, or domestic workers. DIFC and ADGM employment laws are independent. Check the relevant authority before acting.
Content of Article 60
The wording of Article 60 is affected by Federal Decree-Law No. 9 of 2024, which amended some provisions of Federal Decree-Law No. 33 of 2021. The article distinguishes offences concerning employment and work-permit conditions in clause (1) from fictitious employment in clause (2), while related provisions address the criminal procedure for clause (2).
For the legal provisions discussed below, refer to Federal Decree-Law No. 33 of 2021, as amended, including Article 60 and the related penalty provisions. The consolidated law is also available in MOHRE's published text.
| Provision | Conduct covered | Fine range |
|---|---|---|
| Article 60(1)(A) | Employing a worker who is not authorised to work for that employer | AED 100,000-1,000,000 |
| Article 60(1)(B) | Recruiting or employing a worker and leaving them without work | AED 100,000-1,000,000 |
| Article 60(1)(C) | Using work permits for purposes other than those for which they were issued | AED 100,000-1,000,000 |
| Article 60(1)(D) | Closing or suspending operations without required measures to settle workers' rights | AED 100,000-1,000,000 |
| Article 60(1)(E) and (F) | Unlawful juvenile employment, including a guardian or custodian agreeing to it | AED 100,000-1,000,000 |
| Article 60(2) | Circumventing labour-market rules by appointing workers fictitiously | AED 100,000-1,000,000, multiplied by the number of fictitious workers |
This is a statutory range. The relevant offence, number of workers involved and decision of the competent authority are important in determining the particular situation.
Can an Employer Hire a Worker Who Lacks a Work Permit?
Under Article 60(1)(A), the employer hires a worker who does not have authorisation to work for that employer. The issue is more precise than simply asking whether the person has a residence visa.
Consider the permit holder, establishment that employs the worker, permit category and permitted employment before work begins. If another establishment is involved, check the necessary approval rather than relying only on an oral agreement.
Example Situation: Worker Registered Somewhere Else
An employer asks a person registered with another organisation to begin working immediately. The employer assumes that the existing residence permit is enough.
HR should check whether the work authorisation permits the person to work at this employer's firm before assigning any tasks.
What Should an Employer Do When It Hires Workers but Does Not Give Them Any Work?
Article 60(1)(B) concerns employing a worker and not giving that worker any work. The employment background, commitments made and overall circumstances must be examined. The firm should obtain advice where a project is delayed or business circumstances have changed.
Scenario Example: Employees Arrive but There Are No Jobs
An employer recruits five employees from India using the employer's work permits. The employees pay amounts described as recruitment or permit fees. When they arrive, there is no actual work.
Depending on the facts, Article 60(1)(B) may be relevant because employees were recruited and left without work; Article 60(1)(C) may be relevant if permits were misused for another purpose; and Article 6(4) may be relevant to costs incurred in recruitment and employment.
This scenario outlines potential provisions, not a legal decision. It is not enough by itself to conclude that fictitious employment exists under Article 60(2).
When Does It Constitute Misuse of a Work Permit for Other Purposes?
Article 60(1)(C) refers to using work permits for purposes other than those for which they were issued. Employers should compare the approved arrangement with the actual situation, including the employing establishment and purpose of the permit.
A permit file may appear complete while the actual arrangement raises concerns. Where duties, deployment or employing entity change, check the permit conditions and approvals.
How Is Fictitious Employment Different?
Article 60(2) addresses an employer circumventing labour-market laws, regulations or decisions by appointing one or more workers fictitiously. The focus is an employment arrangement used to bypass those rules, rather than treating every worker who has not received work as fictitiously employed.
| Question | Article 60(1)(B) | Article 60(2) |
|---|---|---|
| Main issue | Recruiting or employing someone and leaving them without work | Fictitious appointments used to circumvent labour-market rules |
| What needs examination? | Recruitment, employment commitments and whether work was provided | Whether the appointment was fictitious and how it bypassed applicable rules |
| Separate settlement route under Article 60(4)? | Do not assume it applies | Specifically addressed by that provision |
| Is it limited to Emiratisation? | No | No; the provision concerns labour-market rules generally |
Government Incentive Issues
When statutory criteria for a financial incentive or advantage have been met, Article 60(2) specifies that the court shall order the employer to refund the relevant financial incentives to the government authority.
The employer cannot claim the refunded financial incentives back from the employee.
Are Fictitious Employment Cases Settled?
According to Article 60(3), a criminal case involving an Article 60(2) offence can be brought only when requested by the Minister or the Minister's representative. Article 60(4) contains an alternative arrangement for dealing with the offence.
Under this arrangement:
- The employer must request a settlement.
- The Ministry may settle the case before judgment.
- At least 50% of the fine for the minimum penalty for the offence must be paid.
- The employer must refund all financial incentives given to the fictitious employees.
Settlement is discretionary; it cannot be treated as a right to pay half of the fine. If more than one employee is involved, verify the calculation before stating a figure.
How Do Fines Get Multiplied When There Are Many Workers?
Article 62 stipulates that fines imposed on employers are increased in relation to the number of employees subjected to violations, subject to a limit of AED 10 million for that provision. Article 60(2) also states that fines are increased depending on the number of fictitious workers.
Example Scenario: Five Affected Workers
If a fine of AED 100,000 applies for each of five affected workers, the illustrative calculation is:
5 workers × AED 100,000 = AED 500,000
This illustration assumes the stated fine and multiplication apply; it is not a prediction of a court's decision.
The AED 10 million ceiling under Article 62 should not be described as a universal limit covering every possible liability, repayment or consequence under other legislation.
What Other Rules Do Employers Need to Know?
Some other rules help explain this broader scenario.
| Provision | Rule to understand |
|---|---|
| Article 6(4) | Employers must not charge workers recruitment and employment fees or costs, directly or indirectly. |
| Article 59 | False information or documents intended to recruit an expatriate worker can attract AED 20,000-100,000 fines. |
| Article 63 | Other violations of the law, its Executive Regulation or implementing decisions can attract AED 5,000-1,000,000 fines. |
| Article 64 | Repeating a similar violation within the specified one-year period after the previous judgment can attract imprisonment and/or a doubled fine. |
Labelling a recruitment charge as a “processing fee” does not make the problem disappear. Look at what the fee includes, who collected the money and whether the employment cost was passed to the employee.
Each provision must be considered separately and should not be aggregated into one Article 60 penalty without legal analysis.
What Should Be Verified Prior to Employment Recruitment?
Verification needs to align permit records with the actual employment relationship. Use this checklist for recruitment and whenever the job, placement or activity changes.
- Job: Each permit relates to the actual job and responsibilities.
- Approval documents: Offers and contracts have passed necessary authority checks, such as MOHRE approval.
- Salary: Salaries are paid through WPS wherever applicable.
- Attendance and assignment records: Attendance and assignment records exist.
- Cost of recruitment: Workers do not incur costs for permits and recruitment.
- Permit purpose: Actual employment corresponds to the allowed establishment and type of employment.
- License, contract and permit records: License, contract, permits and payroll records are maintained properly.
- Workers' rights at closure: Workers' rights are verified before activities are closed.
Payroll records are reliable data sources, but payment of salaries does not itself ensure compliance with employment-relationship laws.
What Are the Steps to Take If There Is No Job Being Offered?
Verify whether the offer and company are authentic before travelling. Keep all documents if the promised job is not offered.
The UAE Government's guidance on avoiding labour and visa fraud explains how to check a MOHRE offer using its reference number and reminds workers that recruitment expenses are the employer's responsibility.
Keep the following documents:
- Signed offer and contract.
- Documents related to visa and permits.
- Emails or letters about the job offer from the recruiter.
- Documents showing money that was requested or paid.
- Letters about the missing job and salary.
Contact MOHRE through proper channels to understand how to lodge a complaint. Provide the facts without trying to predict the final penalty for the employer.
How Can GetMyAccounting Support Employment Records?
Understanding Article 60 of the UAE Labour Law helps businesses identify arrangements that need closer review.
GetMyAccounting's Payroll & WPS services can support payroll preparation, reconciliations and organised supporting records within an agreed accounting scope. Legal interpretation, criminal proceedings and settlement advice should be handled by a qualified UAE employment lawyer.
Frequently Asked Questions
What Is the Difference between Article 60(1) and Article 60(2)?
Article 60(1) relates to violations of employment and work-permit provisions, such as unauthorised employment, recruiting without providing work and abuse of a work permit. Article 60(2) deals with fictitious appointments of workers to bypass labour-market rules. Leaving a worker without work does not necessarily mean fictitious employment.
What If I Recruit a Worker and Then Have No Work for Them?
This case may be covered by Article 60(1)(B). Analyse the commitments undertaken and the conditions of employment. A lack of business is not enough by itself to eliminate the employer's obligations.
What Is Fictitious Employment?
Article 60(2) refers to fictitious employment of workers to evade legal, regulatory or decisional restrictions concerning the labour market. It is not limited to Emiratisation, and it cannot be inferred simply because an employee was not working.
Can the Fine Be Settled?
Article 60(4) provides a conditional settlement route for the Article 60(2) offence before judgment. It requires an employer request, Ministry agreement, at least 50% of the minimum specified fine and return of relevant incentives. Other Article 60 violations should not be assumed to qualify.
What Is the Maximum Fine for All Liabilities?
According to Article 62, a maximum total fine of AED 10 million applies to the worker-based multiplier in that article. This does not mean that there is a maximum total fine for all liabilities and incentives.
Can an Employer Ask Workers to Pay for Work Permits?
Article 6(4) prohibits imposing recruitment or employment fees or costs on workers. Employment costs relating to permits must not be imposed on workers in any form.
Disclaimer: This article is general information on UAE employment compliance, not legal advice. For a specific dispute, consult a qualified UAE employment lawyer.

