VoxxArrive · UAE onboarding topic
Free-zone vs mainland hiring in the UAE: who issues the visa and which employment law governs
Where you license your company decides who sponsors the visa and which employment regime governs the contract. Mainland hires get a MOHRE work permit and a GDRFA/ICP residence visa under Federal Decree-Law No. 33 of 2021; general free-zone hires (JAFZA, DMCC, Dubai South, etc.) are sponsored by the free-zone authority, which issues the establishment card and permit while residence visas still come from GDRFA/ICP, and their employment is, on the prevailing position since Federal Decree-Law No. 33 of 2021 took effect, governed by the federal labour law - though some zones keep their own supplementary employment rules, so confirm per zone. The two financial free zones, DIFC and ADGM, sit outside federal labour law entirely, each running its own common-law employment regulations and its own courts.
Steps
- Identify where the hiring entity is licensed - The employer's licence location, not the employee's nationality, sets the regime: mainland (onshore), a general/economic free zone, or one of the two financial free zones (DIFC or ADGM).
- Mainland hire: MOHRE work permit + GDRFA/ICP residence visa - A mainland company applies to MOHRE for the work permit and labour contract; the residence visa and Emirates ID are then issued by GDRFA (Dubai) or ICP (other emirates). Employment is governed by Federal Decree-Law No. 33 of 2021 and disputes go through MOHRE mediation and the UAE labour courts.
- General free-zone hire: free-zone authority sponsors, GDRFA/ICP issues the visa - The free-zone authority (e.g. JAFZA, DMCC, Dubai South, DAFZA) is the sponsor: it holds the establishment/immigration card and processes the entry permit and work permit, while final residence-visa issuance still rests with GDRFA or ICP. Per u.ae, free-zone employees are sponsored by the free-zone authority rather than directly by the employer, and each authority runs its own administrative rules. Since Federal Decree-Law No. 33 of 2021 took effect (2 February 2022), the prevailing position is that this federal labour law governs employment in the general free zones - though some zones retain their own supplementary employment rules, and the u.ae 'Working in free zones' page still states free-zone workers are 'generally not governed by the UAE Labour Law', which appears outdated on this point. Confirm the applicable regime with your specific zone.
- Financial free-zone hire (DIFC / ADGM): the zone's own regime governs - DIFC applies DIFC Employment Law No. 2 of 2019 (as amended) and ADGM applies its Employment Regulations 2024 (in force 1 April 2025, replacing the 2019 version). Federal civil and commercial law - including federal labour law - does not apply inside these zones; UAE criminal law still does. Disputes are heard in the DIFC Courts or ADGM Courts under English common law. You cannot contract out of these minimums for staff based in the zone.
- Check end-of-service and savings obligations for the chosen regime - Mainland and general free zones follow federal end-of-service gratuity rules. DIFC mandates the funded DIFC Employee Workplace Savings (DEWS) scheme in place of traditional gratuity; ADGM retains a gratuity model updated under its 2024 Regulations. Confirm the current contribution/accrual figures with the relevant authority before budgeting.
- Confirm work-location scope - A free-zone visa is primarily tied to working within that zone and for its licensed activity; deploying that employee onto mainland client sites can require additional permits. A mainland MOHRE permit allows work anywhere onshore. Verify scope with the specific authority for the role.
Timeline
Varies by authority and category. In practice both routes typically complete within a few weeks once documents and medical/Emirates ID steps are done; free-zone processing is often quoted as faster than mainland, but the exact day-counts are not published as fixed figures and are listed as unverified.
Cost & fees
No single figure applies. Costs differ by jurisdiction (mainland vs each free zone vs DIFC/ADGM), visa category, skill level and duration, and cover distinct components (work permit, establishment card, entry permit, medical, Emirates ID, residence-visa stamping). Free zones bundle fees through their own authority; mainland fees run through MOHRE plus GDRFA/ICP. Get a current quote from the specific authority.
Some figures on this page vary by jurisdiction, zone or nationality, or could not be independently confirmed from a public source at time of writing - confirm the current figure with the regulator before relying on it.
Sources
- u.ae (Official UAE Government Portal) - Working in free zones: free-zone employees are sponsored by the free-zone authority, not the employer, and are subject to that authority's rules (note: this page still says free-zone workers are 'generally not governed by the UAE Labour Law', which appears outdated post-Decree-Law 33/2021)
- UAE Legislation (uaelegislation.gov.ae) - Federal Decree-Law No. 33 of 2021 Concerning the Regulation of Labour Relations (the federal labour law that, on the prevailing post-2 February 2022 position, applies to the general free zones)
- u.ae (Official UAE Government Portal) - Authorities regulating free zone activities (financial free zones and Federal Law No. 8 of 2004)
- ADGM - Federal Legislation: financial free zones and activities are exempt from all federal civil and commercial laws, while UAE criminal law still applies
- ADGM - Announcement: new Employment Regulations 2024 repeal the 2019 regulations and take effect 1 April 2025
- DIFC - Legal database: Employment Law No. 2 of 2019 (DIFC's own employment statute, separate from federal labour law)
- MOHRE (Ministry of Human Resources and Emiratisation) - federal labour law and mainland work permits
- GDRFA Dubai - 'all-in-one' residency service for government and free-zone entities (Gulf News report on GDRFA's role in free-zone residence visas)
Frequently asked
Who issues the work permit - MOHRE or the free zone?
For mainland companies, MOHRE issues the work permit. For free-zone companies, the free-zone authority issues the work permit and acts as the visa sponsor; MOHRE is not involved. In both cases the residence visa and Emirates ID are issued by the immigration authority - GDRFA in Dubai or ICP in the other emirates.
Does UAE federal labour law apply in free zones?
It depends on the free zone. On the prevailing position since Federal Decree-Law No. 33 of 2021 took effect, general/economic free zones (JAFZA, DMCC, Dubai South, DAFZA and similar) are governed by that federal labour law, the same as the mainland, even though the zone authority handles the administration. That said, some free zones keep their own supplementary employment rules, and older u.ae guidance still describes free-zone workers as generally outside the UAE Labour Law, so confirm the position with your specific zone. The two financial free zones, DIFC and ADGM, are carved out of federal civil and commercial law and apply their own employment regulations instead.
How are DIFC and ADGM different from other free zones for employment?
DIFC and ADGM are the UAE's two financial free zones. Each has its own common-law-based employment statute (DIFC Employment Law No. 2 of 2019; ADGM Employment Regulations 2024) and its own courts (DIFC Courts, ADGM Courts). Employers there cannot apply federal labour law or contract below the zone's minimum standards; disputes are resolved inside the zone, not through MOHRE.
Can a free-zone employee work on the mainland?
A free-zone visa is tied to the zone and its licensed activity. Working for or at a mainland client can require additional permissions or a separate arrangement, whereas a mainland MOHRE work permit generally allows work anywhere onshore. Confirm the specific scope with the relevant free-zone authority for the role.
Who resolves an employment dispute in each regime?
Mainland and general free-zone disputes go through MOHRE mediation and, if unresolved, the UAE labour courts under Federal Decree-Law No. 33 of 2021. DIFC and ADGM disputes are heard in the DIFC Courts or ADGM Courts under their own employment regulations and English common law.