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DIFC and ADGM employment law: The two zones with laws of their own.

How DIFC and ADGM employment law differ from the federal law: DEWS and uncapped gratuity, leave in working days, sick pay, final pay and pensions.

Branches and establishments in DenwaysHR: four branches across Dubai, Abu Dhabi and Sharjah with their codes, locations, week offs and employee counts

The short answer

Companies licensed in DIFC follow the DIFC Employment Law No. 2 of 2019, and those in ADGM the ADGM Employment Regulations 2024, instead of the federal labour law. For payroll the main differences are that DIFC employers pay monthly DEWS contributions of 5.83% or 8.33% of basic instead of gratuity, ADGM gratuity has no two-year cap, and both zones give 20 working days' annual leave.

Most UAE free zones follow the federal labour law. Two do not. The Dubai International Financial Centre and Abu Dhabi Global Market each write their own employment law, and a company in either needs HR rules that are not the mainland's.

Which employment law applies in DIFC and ADGM?

Federal Decree-Law No. 33 of 2021 applies on the mainland and in the free zones, except where a zone has its own employment law. In practice that means the two financial free zones.

A company licensed in DIFC follows the DIFC Employment Law No. 2 of 2019; a company licensed in ADGM follows the ADGM Employment Regulations 2024, unless it holds a dual licence from the Abu Dhabi Department of Economic Development with staff under the federal law. A company in JAFZA, DMCC or any other zone follows the federal law. The UAE Government portal words this differently, saying each free zone authority has its own employment law; our free zones page explains how we read it.

Federal lawDIFCADGM
End of serviceGratuity, capped at two years' wageMonthly DEWS contributions since 1 February 2020Gratuity with no cap, or a pension or savings scheme the employee chooses
Basic pay for end of serviceBasic salary in the contractAt least 50% of total wageAt least 50% of total pay
Annual leave30 calendar days20 working days20 working days, from the first day
Sick leave90 days: 15 full, 30 half, 45 unpaid60 working days: 10 full, 20 half, 30 unpaid60 days: 10 full, 20 half, 30 unpaid
Final pay dueWithin 14 daysWithin 14 daysWithin 21 days
ClaimsMOHRE, then the courtsDIFC CourtsADGM Courts
As at November 2026: the DIFC law as consolidated in July 2025, the ADGM regulations in force since 1 April 2025.

How does the DIFC Employment Law differ?

The DIFC Employment Law has been amended several times since 2019, most recently by DIFC Law No. 1 of 2025, in force from 15 July 2025. The change that matters most to payroll is older: since 1 February 2020 a DIFC employer pays end-of-service money monthly into a qualifying scheme instead of building up gratuity to pay at the end.

DEWS contributions

The default scheme is DEWS, the DIFC Employee Workplace Savings plan. The employer contributes 5.83 per cent of the employee's monthly basic wage for the first five years of service, and 8.33 per cent from then on. Service before February 2020 counts towards the five years. For the calculation, basic wage is never less than half of the total wage.

Gratuity still exists for service before 1 February 2020. An employee who joined in 2016 is owed gratuity for the four years before the scheme began, at the daily rates in the law on the basic wage at the date employment ends, and DEWS contributions for everything after. If the employer moves that gratuity into the scheme with the employee's written consent, the amount is struck as at the day before the scheme began and the later payment falls away.

Leave and hours

  • Annual leave of 20 working days a year, after 90 days of service; at least five days can be carried over, and carried leave lapses after twelve months
  • Sick leave of 60 working days in any twelve months: the first 10 on full pay, the next 20 on half, the last 30 unpaid
  • Maternity leave of up to 65 working days, paid after a year's service at 33 days on full pay and 32 on half; paternity leave of 5 working days
  • Working time averaging 48 hours a week, and no more than six hours a day for Muslim employees during Ramadan

Pay and claims

Wages are due within seven days of the end of each pay period, with an itemised statement. Final pay is due within fourteen days of employment ending. If it is late and the unpaid amount is more than a week's wage, the employer owes a further day's wage for every day of delay. An employee has six months to bring a claim to the DIFC Courts.

UAE and GCC nationals in DIFC are registered with the pension authority rather than DEWS and earn no gratuity. Where the pension contribution is lower than DEWS would have been, the employer pays the difference, provided it comes to at least AED 1,000 a month.

How do the ADGM Employment Regulations differ?

Abu Dhabi Global Market replaced its 2019 employment regulations with the ADGM Employment Regulations 2024, which took effect on 1 April 2025. They keep much of the federal structure and change the parts that cost money.

  • Gratuity keeps the federal daily rates of 21 and 30 days, but on at least half of total pay, with no two-year cap, and owed whatever the reason employment ends
  • An employer can offer a pension or savings scheme in place of gratuity, and the employee chooses in writing
  • Final pay is due within 21 days, and a late payment can attract a penalty of up to six months' wages
  • A repatriation flight is owed within 30 days of leaving, unless the employee was dismissed for cause
  • Paying in lieu of notice needs the employee's agreement
  • Annual leave of 20 working days accrues from the first day, with at least five days carried over
  • UAE and GCC nationals have to be enrolled in their pension within 30 days

The cap is the expensive difference

On the mainland, long service stops adding to gratuity once the total reaches two years' wage. In ADGM it keeps adding. For a long-serving employee on a large package the difference can be several months' pay, and a payroll system built for the federal law will understate it.

What do the DIFC and ADGM rules mean for payroll?

  • Know which law each employee is under before applying any rule, from the licence of the company that employs them
  • In DIFC, contribute monthly and keep the schedule each month's payment was based on
  • In both zones, check that the basic used for end-of-service is at least half of total pay
  • Set leave up in working days, not calendar days, for employees in either zone
  • MOHRE's Wage Protection System binds establishments registered with the ministry. We found no mention of it in the DIFC law or ADGM's wage sections, so confirm with the zone how wages are monitored for your licence

DenwaysHR calculates DEWS contributions, freezes gratuity at the scheme start date and prints a DEWS line on the payslip. ADGM's uncapped gratuity is not built yet.

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