Free zone companies sit outside MOHRE’s Emiratisation quotas because they register with their free zone authority rather than with MOHRE, but if you also hold a mainland licence or branch, that mainland entity is assessed on its own registered workforce, and the free zone side does not shelter it.
Source: MOHRE framework; DIFC Employment Law No. 2 of 2019; ADGM Employment Regulations 2019 · Checked August 2026
Part of the full Emiratisation compliance guide.
The short version
| Your structure | Emiratisation quota applies? |
|---|---|
| Free zone licence only | No |
| DIFC or ADGM only | No, separate employment frameworks |
| Mainland licence only | Yes, subject to size and sector |
| Both, dual licence | Yes, to the mainland entity, on its own headcount |
Why free zones sit outside
Emiratisation obligations attach to companies registered with MOHRE. Free zone entities register with their own authority, which sets its own employment rules.
DIFC and ADGM go further than commercial free zones. Both operate under English common law frameworks with their own courts and regulators.
“Exempt” overstates it
Almost every published guide says free zones are exempt. The more accurate description is outside current scope. A consequence of how registration and jurisdiction work, rather than an exemption written into the framework.
The difference matters for planning. A statutory exemption is a right. A scope boundary can move, and several free zones are progressively aligning practices with mainland standards.
Nobody is suggesting quotas land on free zones tomorrow, but a five-year workforce plan built on permanent exclusion rests on more than the evidence supports.
The dual licence trap
If your business holds both a free zone licence and a mainland licence or branch, the mainland entity is assessed on its own registered workforce. It does not matter that the free zone entity is larger or that the two are managed as one.
Then the detail most guidance misses:
What counts is which entity an employee is registered under, not where they sit.
Only employees on the mainland MOHRE register count toward the assessment. A group that staffs both entities through one structure, or moves people between them, has to track registration carefully. An Emirati registered under the free zone entity does not count toward the mainland entity’s target, however genuinely they work for the group.
That cuts both ways. It can create a shortfall you did not know about. It can also mean an Emirati you already employ is not being counted where it would help.
If you have a dual licence
Three questions, in order:
- Is the mainland entity registered with MOHRE, and how many employees are on that register? Not group headcount. That register.
- How many are UAE nationals in skilled roles earning at least AED 6,000?
- Which sector is the mainland entity’s activity classified under?
If the answers put you in scope and short, exposure is AED 10,000 per unfilled position per month from 1 July 2026.
What free zone employers should still check
Nafis eligibility. Free zone employees are not automatically excluded. The Emirati Talent Competitiveness Council operates a gradual adjustment mechanism for private-sector employees outside MOHRE and Central Bank scope, where salary is below the approved AED 6,000 minimum. See Nafis eligibility.
Wage protection. Requirements vary by zone. Since Nafis eligibility is linked to wage protection compliance, this matters more than it first appears.
Your free zone authority’s own position. “MOHRE doesn’t apply” is not the same as “nothing applies.”
Mainland expansion plans. Model the obligation before you sign.
Read next: Who has to comply with Emiratisation. The size and sector thresholds in full.
Last checked August 2026 · Sources: official platforms
