Workplace Intelligence for HR, Talent & HRTech Leaders in the Middle East Emiratisation Hub العربية Human Resource Events

Does Emiratisation Apply to Free Zone Companies?

By Vibhor Sharma, Co-Founder & CEO, StrongYesLast fact-checked 13 October 2026
Does Emiratisation Apply to Free Zone Companies?: StrongYes Emiratisation Hub
Quick answer

Companies registered only in a UAE free zone sit outside MoHRE's Emiratisation targets because they register with their free zone authority, not MoHRE. A mainland licence or branch held by the same business is assessed on its own registered workforce. Banks and insurers licensed by the Central Bank of the UAE follow the Central Bank's own Emiratisation targets.

The short version

Your structure MoHRE target applies?
Free zone licence only No
DIFC or ADGM only No, separate employment frameworks
Mainland licence only Yes, subject to size and sector
Free zone and mainland (dual licence) Yes, to the mainland entity, on its own headcount
Licensed by the Central Bank Central Bank targets apply, wherever registered

"Exempt" overstates it

Most guides say free zones are exempt. The accurate description is outside current scope: a result of where the company is registered, not an exemption written into the rules. Scope can change, so a five-year workforce plan should not assume permanent exclusion.

The dual-licence rule

If a business holds a free zone licence and a mainland licence or branch, the mainland entity is assessed on its own MoHRE-registered workforce. What counts is which entity an employee is registered under, not where they sit. An Emirati registered under the free zone entity does not count toward the mainland entity's target, however much they work for the group.

Central Bank-licensed firms

Banks and insurance companies licensed by the Central Bank of the UAE have their own targets: 45% by end 2026 for banking and 30% by end 2026 for insurance. Financial firms in DIFC and ADGM are regulated by the DFSA and FSRA rather than the Central Bank. See banking and insurance.

What free zone employers should still check

  • Nafis eligibility. Free zone employees are not automatically excluded from Nafis; the salary floor of AED 6,000 applies. See Nafis eligibility.
  • Wage protection. Nafis eligibility is linked to salary paid through an approved system.
  • Your free zone authority's own rules. "MoHRE does not apply" is not the same as "nothing applies".

Frequently asked questions

01Are free zone companies exempt from Emiratisation?

Companies registered only in a free zone are outside MoHRE's Emiratisation targets. A mainland licence or branch is assessed separately, and Central Bank-licensed banks and insurers follow the Central Bank's targets.

02Does Emiratisation apply to DIFC and ADGM companies?

Not MoHRE's targets. DIFC and ADGM have their own employment frameworks, and financial firms there are regulated by the DFSA and FSRA.

03Can free zone employees get Nafis support?

They are not automatically excluded. Eligibility depends on being a UAE national in the private sector with a salary in the qualifying band.

Sources

  1. CBUAE: Emiratisation targets for banking, finance and insurance. Central Bank of the UAE, 22 April 2026.
  2. DIFC Employment Law No. 2 of 2019; ADGM Employment Regulations 2019.

This page explains UAE Emiratisation rules for general information. It is not legal advice. Rules change, so confirm against the official MoHRE, Nafis or Central Bank source linked above before acting. StrongYes is an independent publication and is not affiliated with MoHRE, Nafis, the Emirati Talent Competitiveness Council or any UAE government body. Full disclaimer.