Overview

The new Labour Law No. 14 of 2025 (the “Labour Law”) officially took effect on the 1 September 2025, replacing the previous 2003 law in full. 

This update is intended to highlight the new reporting obligations imposed on employers and to clarify certain points of confusion regarding statutory internal regulations. In particular, employers are required to proceed with updating their regulations without waiting for the issuance of ministerial decrees.

Reporting Obligations

Against this background, we believe it would be useful to provide a brief update on a number of key matters, with specific focus on the provisions governing internal regulations.

• Employee Statement: Employers are required to prepare a detailed statement indicating the number of employees, their qualifications, occupations, age groups, nationalities, gender, and salaries. There is no prescribed form or template for this statement. Deadline is 30 September 2025.
• Employment Contracts: Employers must begin reviewing their employment contracts. The key change is that contracts are now required to be executed in four (4) copies (with the fourth copy submitted to the competent labour office).
• Internal Policies: Employers should review their internal policies to reflect several updates introduced by the Labour Law, including provisions on leave entitlements, maternity rules, and childcare leave.
• Statutory Internal Regulations: Employers with ten (10) or more employees are required to adopt and ratify statutory internal regulations in line with the Labour Law. Deadline is 30 October 2025.

Required Content of Statutory Internal Regulations

The statutory internal regulations must, in particular, include provisions relating to:

• Promotions.
• Transfers.
• Wages.
• Violations constituting a breach of duty.
• Disciplinary sanctions. 

Additional Procedural Points for Statutory Internal Regulations

With respect to statutory internal regulations, please note the following additional points:

• The regulations must be prepared within sixty (60) days from the commencement of the establishment’s operations, the date on which the required number of employees is reached, or the effective date of the Labour Law, as applicable.
• A copy of the regulations must be submitted to the competent administrative authority for review and approval. The competent administrative authority must also consult the relevant labour union organisation, which is required to provide its opinion to the authority within fifteen (15) days from the date of receiving the regulations; otherwise, the regulations shall be deemed approved. If the competent administrative authority does not ratify or object to the regulations within thirty (30) days from the date of receipt, the regulations shall be considered effective.
• The Minister of Labour is expected to issue a decree establishing the general rules of these regulations, rather than issuing model templates for regulations and disciplinary sanctions to guide employers.

Verbal Guidance from the Ministry (Practical Note)

Further, and referring to the last point, we note that during an event ADSERO attended with the Legal Advisor to the Minister of Labour, they have verbally confirmed on the following:

• Immediate Compliance: Employers should not wait for the issuance of the ministerial general rules. They are required to amend and update their statutory internal regulations in line with the provisions of the Labour Law and submit them to the competent labour office for approval within the deadline stated above.
• Reason for Delay in Guidance: The Legal Advisor explained that the delay in issuing the ministerial guidelines is intended to allow the authorities to first review and assess the internal regulations submitted by employers. This will enable the authorities to gather practical insights and common practices from different sectors, which will later be reflected in the official guidance.
• Flexibility from Old Templates: Employers are no longer bound by the templates previously adopted under Decree No. 185 of 2003. Instead, they may structure their internal regulations (including the disciplinary actions) as they see fit, provided these remain in full compliance with the Labour Law.

We note that, in practice, the inclusion of provisions relating to promotion and salary structures within the internal regulations may present challenges due to their sensitive nature that may lead to risks in addition to the fact that the Labour Law is not entirely clear as to what they should include. To address this part, the drafting is recommended to be general and brief as well as to ensure maintaining a balance between clarity, flexibility and non-discrimination.  

For example, with respect to the salary scheme, the internal regulations may stipulate that salaries shall not fall below the statutory minimum wage, while leaving room for flexibility by not imposing a maximum cap. Additionally, the regulations may outline a range-based structure between different levels or grades, whereby the salary differential is expressed as a percentage range rather than a fixed amount.

Employers’ Options (Practical Next Steps)

• Leverage Group Policies: If your company is part of a larger group with global HR policies, you may use these as a starting point to unify policies across the group, ensuring they are aligned with the provisions of the Labour Law.
• Review Local Policies: Assess your existing local policies in light of the parameters and requirements set out under the Labour Law.
• Create or Update Policies: Where necessary, create, update, or amend your policies to reflect the guidelines and provisions introduced by the Labour Law.

Anticipated Further Guidance

It is anticipated that additional ministerial decrees will be issued to provide further clarity and regulate various aspects of the Labour Law. Should any of these forthcoming decrees introduce provisions that conflict with existing internal regulations, we expect that employers will be required to amend their internal policies accordingly to maintain compliance.

Conclusion and Monitoring Note

Finally, please note that the above information is based on verbal confirmation. ADSERO will continue to monitor the situation and will provide you with updates should there be any changes or further official guidance issued.

The contributors to this article are Alia Monieb, Partner and Head of Employment, and Khaled Omar, Junior Associate.