Fake Emiratisation in the UAE: the fines in Cabinet Decision No. 43 of 2025 and the HR records that prove a job is real

Fake Emiratisation means registering a UAE national with a work permit and contract but no real job. MoHRE, the UAE Ministry of Human Resources and Emiratisation, flagged 377 cases at 266 private companies in the first half of 2026. Under Cabinet Decision No. 43 of 2025, each fake hire linked to Nafis can cost AED 20,000 to 100,000.

What changed. 22 September 2026: MoHRE reported 377 fake Emiratisation cases found in the first half of 2026 through its field and digital monitoring, and said it acted under Cabinet Decision No. 43 of 2025. That decision, issued on 16 April 2025 and in force from the day after its Official Gazette publication, replaced the 2022 penalty rules for Nafis, the federal programme that supports Emiratis working in the private sector. This page reads its fines row by row.

What MoHRE found in 2026

Two MoHRE releases in September 2026 show how the ministry now works:

• 377 cases at 266 companies in the first half of 2026, flagged through field visits and digital monitoring. MoHRE calls the practice limited in scope, not widespread.
• About 212,000 inspection visits for all labour-law checks in the same half year (more than 211,000, says the release's subheading), run by what MoHRE calls an AI-powered inspection, monitoring and compliance system that points inspectors at high-risk companies.
• The most prominent violations across those inspections: employing people without permits, not paying wages through the Wage Protection System (WPS), and giving MoHRE incorrect data or documents.

The message for an HR team is plain. MoHRE says its digital tools point inspectors at high-risk companies, so your records should tell the same story as your workplace.

What counts as fake Emiratisation

MoHRE's definition has three parts: a UAE national is registered with the company, a work permit and contract are issued, and there is no genuine employment relationship or real job tasks behind them. The ministry's own test is "a real job, real tasks, and a real career path; not just a number in records."

Hiring is not the risk. MoHRE describes the goal as a genuine and productive employment relationship, with actual tasks, responsibilities and a career path. The risk is a person who exists in the systems and nowhere else. If your company is still working out its own targets, start with our guide to Emiratisation targets for 2026.

The fines, row by row

Cabinet Decision No. 43 of 2025 lists nine violations linked to Nafis and Emiratisation. The six rows below fine the company. Rows 6 and 7 apply to the Emirati employee, and row 8 makes the company repay the support it received when it does not employ the person after a supported training period. "The Council" is the UAE Talent Competitiveness Council, which runs Nafis. Amounts are in UAE dirhams (AED). The last column is our reading of the record that answers each row.

The text around the table matters as much:

• Support is paid back. For rows 1, 2, 4, 5 and 8 the owner repays all the Nafis support the employee received (Article 3).
• Fines add up. More than one penalty can be imposed where more than one violation is committed, and the Council can stop dealing with the company (Article 6).
• Prosecution stays possible. A fine does not stop a referral to the Public Prosecution (Article 6).
• The target resets. After a row 9 violation, the company must reach the target it would have had before getting around it (Article 6).

The ladder of AED 100,000, 300,000 and 500,000 is not new. MoHRE announced it in May 2023 under the earlier rules, which Cabinet Decision No. 43 of 2025 repealed and replaced with the same amounts in row 9. It is the figure in MoHRE's 2023 headline. On our reading, row 1 is the one written for a fake hire linked to Nafis, per worker; MoHRE has not said which rows it applied to the 2026 cases, and row 9 also covers "any other form of circumvention" the ministry establishes.

A worked example

This shows how the rows can add up on our reading. It is our own example, not a MoHRE ruling.

A company hires two UAE nationals with Nafis support. The first is registered but never given real work. The second gets a work permit but never starts, and the company does not follow the procedures the law requires.

The fines are only part of the cost. The support repaid comes on top, the Council may stop dealing with the company, and the case may be referred to the Public Prosecution.

The audit file: records that show a job is real

MoHRE's releases do not list its risk indicators. Read against the table, these are the records we would want to hand an inspector for every Emirati employee:

1. A signed contract and a job description with real tasks that match the job level you report.
2. A valid work permit and every other required document, with expiry dates tracked before they lapse (row 3).
3. Attendance from the first day: clock-ins, leave and absence approvals (row 4).
4. Salary paid through WPS every month, the same amount the contract and Nafis records show. Our UAE WPS payroll guide covers the salary file.
5. Evidence of work: tasks, approvals, reports or training in the person's own name, and a manager who can describe the role.
6. A dated change log: promotions, pay changes, transfers and exits, each reported to the Council when it affects support (rows 4 and 5).

If an audit of your own finds a gap, fix the record and report the change now, before an inspector asks.

If MoHRE contacts you

• Answer with records, not explanations. The six items above are the records we would expect to be asked for.
• Appeal in writing within 10 days. Article 4 allows a reasoned appeal to MoHRE with supporting documents within 10 days of notification; MoHRE decides within 20 days. The decision does not say whether these are calendar or working days, so treat them as calendar days to be safe.
• Ask about relief. Article 5 lets the Council's Chairman grant exemption from a penalty or allow payment in instalments, in cases and on conditions set by a separate Chairman's decision, which we have not seen.

How Tarleaks helps

Tarleaks HR keeps each employee's work permit number, MOHRE person code and Nafis registration with its date, shows your Emiratisation ratio, and alerts manager and HR 90, 60, 30, 15 and 7 days before a visa or work permit expires, by default. Attendance records clock-ins, leave and approvals. Payroll builds the WPS salary file from the approved run. HR keeps an audit log of sensitive changes such as contract approvals and terminations. Your official Emiratisation position still comes from MoHRE's own systems.

What to do next

• Run the six-item audit above for every Emirati employee this month.
• Check your year-end position with our guide to Emiratisation targets.
• Choosing HR software? Use our 15 questions for the demo.
• Book a demo to see HR, Attendance and Payroll records for one employee in one place.

Questions people ask

What is fake Emiratisation?

MoHRE defines it as registering a UAE national with a company and issuing a work permit and employment contract without a genuine employment relationship or real job tasks. It is usually an attempt to meet Emiratisation targets on paper or to collect Nafis support.

What is the fine for fake Emiratisation in the UAE?

Under item 1 of Cabinet Decision No. 43 of 2025, AED 20,000 to AED 100,000 per worker. The company must also repay the Nafis support the person received, and the case can be referred to the Public Prosecution.

Is the fine for fake Emiratisation AED 500,000?

Not as a rule. AED 100,000, 300,000 and 500,000 are the fines for the first, second and third time a company gets around its targets by cutting numbers, changing job classifications or another way (item 9). Item 1, written for sham Emiratisation linked to Nafis, is per worker. MoHRE has not said which rows it applied to the 2026 cases.

How does MoHRE find fake Emiratisation?

MoHRE says it finds cases through its field and digital monitoring, using digital systems and data analytics, and that it keeps developing these tools. It also asks the public to report cases on 600590000, through its smart app or its website.

Can a company appeal a fake Emiratisation fine?

Yes. Article 4 of Cabinet Decision No. 43 of 2025 allows a written, reasoned appeal to MoHRE within 10 days of being notified, with the supporting documents. MoHRE decides within 20 days of the appeal.

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General information, not legal advice. Checked against the official sources listed on this page on 1 November 2026. The English text of Cabinet Decision No. 43 of 2025 that MoHRE publishes is a third-party translation of the Arabic original. Confirm your position with MoHRE or your adviser.