Introduction:
Since the beginning of 2025, we have seen several significant legal developments that affect employers across various sectors in Qatar. These include:
- Nationalisation in the Private Sector Law which will come into effect on Thursday, 17 April 2025 (Nationalisation Law);
- Cabinet Resolution No (3) of 2025 (the Executive Regulations) to the Social Insurance Law (Law No (1) of 2022) (Pensions Law);
- New guidance on constructive dismissal under the QFC Employment Regulations; and
- The introduction of a new template QFC employment agreement.
These changes reflect the government's broader efforts to enhance employment regulation, promote national workforce participation, and increase employer accountability.
What does this mean for employers?
a) Nationalisation in the Private Sector Law (Effective 17 April 2025):
Employers operating in Qatar's mainland private sector must adapt hiring practices and HR processes to prioritise Qatari nationals and children of Qatari mothers (Nationals). This includes:
- Prioritising the recruitment and training of Nationals;
- Using standardised registered employment contracts for Nationals;
- Complying with job vacancy reporting and post-recruitment disclosures
- Registering on and utilising the designated applications/portals, including Tawteen, Istamer, Kawader, and Basher;
- Reporting biannually to the Ministry of Labour (MoL) on workforce composition;
It is worth noting that most of the obligations – save for the reporting requirements – require secondary legislation to provide specific details. Though employers should already be:
- Reviewing existing workforce and organisational structures;
- Identifying roles that may be subject to nationalisation;
- Preparing internal tracking and reporting mechanisms.
Failure to comply may result in hefty fines, visa blockages, reputational consequences, including public naming and shaming, and imprisonment for any fraudulent claims of complying with the Nationalisation Law.
b) Executive Regulations to the Pensions Law, applicable to Qatari and eligible GCC nationals:
Employer obligations include the requirement to:
- Register eligible employees with the General Retirement and Social Insurance Authority (GRSIA);
- Update employee data within 30 days of any changes;
- Maintain accurate Workplace Files and Insured (pensionable) Employee Files;
- Deduct and remit pension contributions based on the statutory capped salary;
- Appoint a compliance liaison officer.
Additionally, the Executive Regulations set out the notification requirements and assumption of obligations (as applicable) on employers in the context of any merger, liquidation, or dissolution, including the submission to the authorities of supporting documents and insured (pensionable) employee-related data. Further, the Executive Regulations indicate the relative responsibilities of any successor entity arising out of a merger.
Failure to comply may result in fines that could be multiplied per each insured (pensionable) employee.
c) QFC Guidance on Constructive Dismissal
The Employment Standards Office (ESO) of the Qatar Financial
Centre has issued helpful guidelines to better understand what
constitutes constructive dismissal under Article 22 of the QFC
Employment Regulations.
QFC Employers should:
- Avoid unilateral substantial changes without a contractual basis, or conduct which individually or collectively could amount to a material breach;
- Maintain workplace standards, follow internal procedures, and health/safety obligations;
- Treat whistleblowers fairly and prevent hostile work environments.
A misstep could entitle an employee lawfully to resign without notice and claim compensation. Also, any employee constructively dismissed is not bound by certain key obligations under their employment contract.
It is a good time for QFC Employers to now:
- Review employment contracts and handbooks.
- Review internal grievance procedures;
- Train HR and managers on identifying and avoiding conduct that could be deemed a material breach.
d) Introduction of New Template QFC Employment Agreement
The QFC has also launched a new Employment Agreement Template
that is more detailed than the previous one available.
QFC licensed entity employers should review their employment
contracts to ensure that they are (at least) in line with the new
template provided.
How can we help?
Al Tamimi & Company's Employment team advises clients across Qatar and the MENA region on the practical implementation of labour reforms. We can assist with:
- Workforce nationalisation strategy and compliance planning;
- Pensions Law registration and recordkeeping protocols;
- Employment agreement reviews (QFC and non-QFC);
- Internal policy updates to help mitigate the possibility of constructive dismissal claims.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
