Zero-hours and casual work in the United Arab Emirates
Reviewed by Mellow Editorial Team, HR & payroll content team
Zero-hours and casual working arrangements exist in the UAE, but they sit in a legal grey area. Federal Decree-Law No. 33/2021 does not define a "zero-hours contract" as a distinct category — employers who use flexible or on-call workers need to understand how the law actually applies to them.
What the UAE Labour Law says about flexible work
The 2021 labour law introduced several new work models that did not exist under the old regime. These include part-time, temporary, flexible, remote and project-based arrangements. Each must be formalised through a written contract that specifies the nature of the work model.
The "flexible work" model is the closest equivalent to what other jurisdictions call casual or zero-hours work. Under this model, working hours can vary depending on operational demand. However, the contract must still be registered, and the worker is still considered an employee — not an independent contractor — for the purposes of statutory entitlements.
There is no formal "zero-hours" designation in UAE law. If you engage someone on a genuinely unpredictable, as-needed basis without a written contract, you risk that worker being treated as a full-time employee by default.
Entitlements that still apply to flexible and casual workers
Even where hours are variable, certain entitlements follow the employment relationship itself, not the number of hours worked.
End-of-service gratuity accrues from the first day of employment. For expatriate employees, the calculation is 21 days' basic wage per year of service for the first five years, and 30 days' per year after that, capped at two years' total pay under Federal Decree-Law No. 33/2021. For a flexible worker, the "basic wage" used in the calculation is whatever the contract specifies — so if pay fluctuates, it is worth defining clearly what constitutes basic wage.
Annual leave of 30 calendar days applies after one year of continuous service. For a worker on genuinely irregular engagements — for instance, someone brought in for discrete project periods with clear breaks between them — continuity of service may not accumulate. But if the arrangement is effectively continuous with variable hours, leave entitlement will accrue.
Wage Protection System (WPS) compliance applies regardless of work model. All wages paid to employees must go through WPS. There is no exemption for casual or part-time workers.
UAE and GCC nationals enrolled in the GPSSA pension scheme retain that entitlement regardless of how their hours are structured.
The misclassification risk
Some businesses attempt to sidestep employment obligations by classifying casual workers as freelancers or independent contractors. This is a genuine legal risk in the UAE. If the working relationship has the hallmarks of employment — the employer controls when and how the work is done, the worker is integrated into the business, there is no genuine independence — labour authorities can reclassify the arrangement as employment.
The consequence is backdated liability: gratuity, unpaid leave, and potential WPS penalties. The UAE Ministry of Human Resources and Emiratisation (MOHRE) has the authority to investigate complaints and impose fines.
If your workers genuinely are independent professionals, the right route is typically a freelance permit or a commercial licence, not a verbal or informal arrangement that looks like employment.
How to structure a compliant casual arrangement
If you legitimately need workers on a variable-hours basis, the safest approach is:
- Use the flexible work model as defined under Decree-Law No. 33/2021 and register the contract with MOHRE through the standard channels.
- Define the basic wage clearly in the contract, even if total pay will vary. This matters for gratuity calculations later.
- Set a minimum engagement threshold if possible — agreeing a minimum number of hours or days per month reduces ambiguity about whether continuous service is accumulating.
- Pay through WPS on every pay cycle without exception.
- Keep records of hours worked and wages paid. If a dispute arises, this documentation is your primary protection.
The MOHRE standard contract templates for flexible work are a reasonable starting point. You can adapt terms around scheduling and hours, but statutory entitlements cannot be contracted out of.
Sector-specific considerations
Hospitality, retail, events and logistics are the sectors most likely to rely on casual labour in the UAE. These industries often face seasonal or event-driven demand that makes predictable schedules difficult. That is a legitimate operational reality, and the flexible work model was partly designed to accommodate it.
What it does not do is eliminate employer obligations. Workers engaged repeatedly over months or years, even on variable schedules, will almost certainly accrue gratuity and leave entitlements. Planning for that liability — rather than treating it as a surprise at the end of the relationship — is straightforward financial hygiene.
For businesses operating across borders, it is also worth noting that UAE labour law governs work performed in the UAE regardless of where the employing entity is incorporated. A foreign company with workers based in Dubai cannot apply home-country labour standards to those workers.
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