Employment
What regulations govern employment affairs in the UAE?Employment relations in the UAE are generally governed by Federal Decree Law No. 33 of 2021 Regulating Labour Relations which is read in conjunction with Cabinet Resolution No. (1) of 2022 on the Executive Regulations of the UAE Labour Law (together, the “UAE Labour Law”), that set out a minimum standard of employment conditions. As a Federal statute, the provisions of the UAE Labour Law apply to private sector employers based in the UAE, including employers established in a freezone. Although a freezone may implement internal employment regulations applicable to companies established and operating within it, these regulations will merely supplement the minimum provisions as laid out in the UAE Labour Law. Whilst some governmental corporations/entities operate like private sector enterprises they generally fall outside the scope of the UAE Labour Law.
The only current exceptions to the overarching application of the UAE Labour Law are in the Dubai International Financial Centre (“DIFC”) and the Abu Dhabi Global Market (“ADGM”) that are separate jurisdictions with their own employment legislation, namely DIFC Law No. 2 of 2019 (as amended) (“DIFC Employment Law”) and ADGM Employment Regulations 2019 (as amended) (the "ADGM Employment Regulations"). The application of the DIFC Employment Law and the ADGM Employment Regulations are to all employees and employers who are based and ordinarily work out of the DIFC and ADGM respectively.
What type of employment contracts may employers issue?
UAEThe UAE Labour Law only permits fixed term contracts. Fixed term contracts have a specified commencement and termination date and may be of any duration. In practice, however, the Ministry of Human Resources and Emiratisation (“MOHRE”) only accepts contracts for a maximum duration of fifteen years, whereas some free zone authorities will only accept contracts for two years, but are thereafter renewable for the same or shorter periods by mutual consent of the parties. Any extension or renewal of the term will be considered as continuous employment and will therefore count towards the employee’s total service period when calculating end of service gratuity. The minimum and maximum notice periods for termination of an employment contract are thirty and ninety days respectively.
Note that unlimited term contracts were permitted under a previous version of the UAE Labour Law and therefore in circumstances where an employee is currently already party to an unlimited term contract, employers have until 31 December 2023 to transition the employee onto a fixed term contract. If the unlimited term contract is terminated prior to 31 December 2023, the minimum notice period is thirty days if the service period is less than five years, sixty days if the service period is more than five years and ninety days if it is more than ten years.
DIFC and ADGMThe DIFC Employment Law and ADGM Employment Regulations recognise unlimited and fixed- term contracts. However, in the case of fixed-term contracts, legislation does not expressly restrict the length of the term. Similarly there is no restriction upon entering into further fixed-terms. Market practice in the DIFC and the ADGM is to issue unlimited term contracts (unless of course the employment is expected to be required for a fixed term period).
Historically, employers were obliged to provide sponsorship to employees for residence purposes, with the exception of persons sponsored by spouses or on dependant residence visas, or nationals of GCC states. In recent years however many expatriates have been granted self-sponsored long-term “golden visas” on the basis of various factors.
What is the process to hire employees?Historically, the issuance of residence visas for expatriates in the UAE was linked to the employment of individuals by a UAE registered employer. Employers were therefore obliged to provide sponsorship to employees for residence purposes, with the exception of persons sponsored by spouses or on dependant residence visas, or nationals of GCC states. In recent years however many expatriates have been granted self-sponsored long-term “golden visas” on the basis of various factors, including but not limited to:
expatriates who hold senior job titles and earn a minimum of AED 30,000 (approx. USD 8,170) each month;
expatriates invested in real estate or public investments in the UAE (subject to minimum thresholds),
In all cases, the employer is responsible for procuring either a work permit from the MOHRE or a freezone identity card issued by the relevant freezone authority.
In addition, it is compulsory for all UAE residents to hold an Emirates ID card and undergo a medical examination which usually consists of a blood test and chest x-ray, primarily to identify infectious diseases. The presence of certain infectious diseases will lead to the application for residency to be automatically rejected.
When applying for a work permit (and residence visa, where applicable), employers are obliged to issue and submit standard form employment contracts prescribed by the MOHRE or, in respect of freezones, a relevant freezone authority prescribed contract.
The residence visa process generally follows the following stages:
Filing of countersigned offer letter to the MOHRE (not required in respect of freezones);
Filing of countersigned employment contract and application made to the MOHRE /freezone for ‘entry permit’ to allow the individual arrive in UAE;
Security and background check undertaken on the individual by UAE authorities;
Entry by the individual into the UAE for employment purposes;
Undergoing a medical examination;
Application for work permit/identity card and Emirates ID card; and
Application for residence visa submitted to the immigration authorities.
Employment residence visas are valid for two years. Golden visas are valid for five or ten year periods, depending on the basis on which the golden visa was granted.
Can employment be subject to a probationary period?
UAEA probationary period can be for a maximum period of six months and cannot be extended beyond this period even with the consent of the employee. If an employee is working under a probationary period, he may be dismissed for any reason by his employer by providing at least fourteen calendar days’ written notice. When an employee has completed his probationary period successfully and continues employment, the probationary period is counted towards his overall period of service.
If the employee wishes to resign during the probationary period, he/she must provide the employer with written notice as follows:
one months’ notice if the employee is resigning to join another employer in the UAE; or
fourteen calendar days’ notice if the employee is resigning so as to leave the UAE or for any other reason.
If the employee (i) resigns during the probationary period in order to join a new employer in the UAE; or (ii) leaves the UAE and then returns within a period of three months in order to take up new employment, the employee shall cooperate with their previous employer as directed so as to recover their recruitment costs as borne by their previous employer from the employee’s new employer, in accordance with the UAE Labour Law.
DIFC and ADGMThe DIFC Employment Law and ADGM Employment Regulations both allow for a maximum probationary period of six months. Unless otherwise agreed, if an employee is working under a probationary period, he may be dismissed without notice for any reason by his employer within or immediately upon completion of the probationary period. When an employee has completed his probationary period successfully and continues employment, the probationary period is counted towards his overall period of service.
What is the minimum wage and how are salaries paid?
UAEThere is no statutory minimum/maximum salary in the UAE however, in order to sponsor a dependent (spouse and children) to live in the UAE an employee must earn a minimum salary of at least AED 4,000 (approx. USD 1,100) per month or AED 3,000 (approx. USD 820) where the employer provides housing. In order to sponsor parents to live in the UAE this minimum salary is AED 10,000 (approx. USD 2,720) per month.
While the UAE Labour Law provides that salaries may be paid in any currency, the UAE operates an electronic Wage Protection System (“WPS”) that has been established in order to safeguard the timely payment of employees’ salaries (primarily aimed at protecting blue-collar workers) and to ensure that payments made are accurate. Employers are required to pay salaries through the WPS in AED and to an employee’s UAE bank account. These payments are registered and monitored against the employee list and registered wages for each employee. The WPS does not operate in freezones (with the exception of Jebel Ali Free Zone and the Dubai Multi Commodities Centre) and therefore any employees outside of the scope of WPS may be paid in any currency and to a bank account outside of the UAE.
DIFC and ADGMAs above, there is no minimum/maximum salary in the DIFC or the ADGM, however the same minimum salary requirements apply in order to sponsor family. WPS is not applicable in the DIFC or ADGM.
UAE, DIFC and ADGMEmployees are entitled to leave with full pay on public holidays as announced by the UAE authorities for the private sector. Certain holidays are based on local sightings of the moon. Accordingly, the authorities provide a predictive date for the holiday which is confirmed closer to the time.
UAEFull time employees are entitled to minimum annual leave as follows:
Two calendar days for each month of service in the first year of service (which may be taken after completion of the first six months of service); and
Thirty calendar days for each year of service thereafter (equivalent to twenty-two working days on a five day week basis).
In practice, the minimum accrual in the first year under the UAE Labour Law is not commonly enforced and a prorated entitlement is more common.
Part-time employees are entitled to annual leave on a pro-rata basis, with the minimum entitlement being five working days.
Under the UAE Labour Law, the default position is that any unused leave will expire unless it is used in the leave year in which it accrued. In practice, most employers allow for five to ten days to be carried forward to the next year.
DIFC and ADGMAn employee is entitled to an annual vacation of at least 20 working days, which is accrued pro rata for employees who have been employed for at least 90 days. An employee is not entitled to payment in lieu of vacation days except where the employee's employment is terminated or the employer agrees otherwise.
Part time employees (i.e. those who work for less than five days a week) are entitled to annual leave on a pro-rated basis.
An employer and employee may agree as to the number of days of annual leave that may be carried over to the following holiday year; provided that an employee must be permitted to roll over at least five days. Any leave which remains unused within one year of carrying forward, shall expire.
UAEEmployees are entitled to 90 calendar days of sick leave as follows:
First 15 calendar days at full pay;
Next 30 calendar days at half pay; and
Remaining 45 calendar days unpaid.
An employee on probation is not entitled to any paid sick leave.
An employer may legitimately terminate an employee’s contract of employment, should they fail to resume their duties at the end of the sick leave entitlement, but not during it.
Employers in the emirate of Dubai must provide private medical health insurance to all employees. In the emirate of Abu Dhabi, employers must provide private medical health insurance to all employees, their spouse and up to three dependant children under the age of 18 years.
DIFC and ADGMThe law provides a maximum sick leave entitlement of 60 working days in any twelve-month period, payable as follows:
First 10 working days at full pay;
Next 20 working days at half pay; and
Remaining 30 working days unpaid
An employee on probation is entitled to paid sick leave.
Employment may be terminated immediately in writing where an employee has taken in excess of an aggregate of 60 working days sick leave in any twelve month period (except where the sick leave taken is on account of a disability).
Part time employees are entitled to sick leave on a pro-rated basis.
In the DIFC and the ADGM, employers are required to provide health insurance cover for employees only.
UAEFemale employees are entitled to a total of 60 calendar days maternity leave, payable as follows:
First 45 calendar days at full pay;
Remaining 15 days at half pay.
Maternity leave is also applicable to female employees who undergo miscarriages after a minimum of six months of pregnancy, a still birth or in case of death of an infant post delivery.
In certain circumstances, there are additional entitlements for female employees who have exhausted maternity leave benefit:
Maternity “sick” leave: where a female employee has exhausted her maternity leave entitlement, but is unable to return to work as a result of a medical condition arising out of pregnancy or childbirth, she shall be entitled to an additional 45 consecutive or intermittent days of unpaid leave. The medical condition must be evidenced by way of a doctor’s note. This is a reduction in employees’ entitlement under the current law (which provides for 100 consecutive or intermittent days of maternity sick leave); and
Leave to care for a child of determination: an additional 30 calendar days of fully paid leave is granted to female employees who are mother to a child of determination whose health condition requires constant companionship. This leave can be extended for an additional 30 calendar days without pay.
On her return to work, a female employee shall be entitled to two additional breaks per day (not exceeding a total of one hour) for nursing purposes. The employee shall remain entitled to these breaks until the child has reached the age of six months.
Both male and female employees are entitled to 5 calendar days of paid parental leave on the birth of their child. Female employees are entitled to parental leave in addition to maternity leave.
There are no provisions for maternity or parental leave or leave on account of adoption under the UAE Labour Law.
DIFC and ADGMAn employee is entitled to a minimum of 65 working days' maternity leave, provided that she:
has been continuously employed for at least 12 months preceding the expected or actual week of childbirth;
gives her employer written notice that she is pregnant at least 8 weeks before the expected week of childbirth, if requested by the employer;
provides her employer with a doctor's certificate stating the expected or actual delivery date, if requested by the employer; and
gives her employer at least 21 days' written notice before she proposes to commence maternity leave.
Maternity pay is payable by the employer as follows:
first 33 working days at full pay; and
remaining 32 working days at half pay.
On her return to work, a female employee shall be entitled to an additional one hour break for nursing purposes. The employee shall remain entitled to these breaks until the child has reached the age of six months.
In the DIFC, maternity rights also apply to a female employee who is adopting a child of less than five years old. In the ADGM, maternity rights apply to those adopting a child of less than three months old.
A male employee whose wife is pregnant is entitled to five days of paid paternity leave provided that he:
has been continuously employed for at least 12 months preceding the expected or actual week of childbirth; and
gives his employer written notice that his wife is pregnant at least eight weeks before the expected week of childbirth.
In the DIFC only, the above is also applicable to a male employee who is adopting a child under five years old. Male employees in the ADGM are not entitled to paternity leave when adopting a child.
In the DIFC, paternity leave must be taken within a month of the child being born or the adoption date of the child. In the ADGM, paternity leave must be taken within two months of the child being born.
An employee who is pregnant or whose wife is pregnant is also entitled to take reasonable paid time off during working hours to receive ante-natal care. This right also applies to employees taking time off to attend adoption proceedings, although the time off is limited to an aggregate of eight hours in the case of adoption proceedings.
UAEEmployees are entitled to paid bereavement leave as follows:
Five working days on the death of an employee’s spouse; and
Three working days on the death of an employee’s parent, sibling, child, grandparent or grandchild.
DIFC and ADGMEmployees are not entitled to bereavement leave under the DIFC Employment Law and the ADGM Employment Regulations. In practice, many employers provide bereavement leave as a matter of company policy.
UAEEmployees who have been employed by the employer for at least two years and are enrolled in an accredited education institution in the UAE are entitled to up to ten working days of study leave per year in order to sit examinations.
DIFC and ADGMEmployees are not entitled to study leave under the DIFC Employment Law and the ADGM Employment Regulations. Unless company policy provides otherwise, most employees use their annual leave in order to sit examinations.
UAEThere is no statutory entitlement to Hajj or pilgrimage leave.
DIFC Muslim employees who have completed at least one year of continuous employment are entitled to 21 calendar days of unpaid leave in order to perform Hajj. Hajj leave may only be taken once during the employee’s period of employment with the employer.
ADGMMuslim employees who have completed at least one year of continuous employment are entitled to 30 calendar days of unpaid leave in order to perform Hajj. Hajj leave may only be taken once during the employee’s period of employment with the employer.
What are the maximum working hours allowed and are employees entitled to overtime pay?
UAEThe maximum normal working hours for employees is eight hours per day. Employees working a five day working week may therefore work up to 40 hours; employees working a six day week may work up to 48 hours per week. Employees must not work over five consecutive hours without a break of one hour. During the holy month of Ramadan the normal daily working hours are reduced by two.
Overtime should not exceed two hours per day, other than in exceptional circumstances and is calculated at different rates depending on circumstances. The standard overtime (i.e. where the work conditions require the employee to work past their set working hours) rate is calculated on no less than 25% of the employees daily basic remuneration. In the event overtime is recorded between 10 p.m. and 4 a.m., overtime shall be calculated based on 50% of the employee’s daily basic remuneration (unless it relates to a shift worker who ordinarily works between these hours). The same rate applies to overtime recorded on a day of rest.
The Executive Regulations provide that certain categories of employees are exempt from overtime pay. Accordingly, an exemption is granted to/where:
Chairmen of the boards of directors and board members;
Employees who occupy supervisory positions (such that they represent the employer);
Crew of naval vessels and employees who work at sea who have special conditions of service due to the nature of their work;
Businesses whose technical nature requires employees to be engaged on shift work or tour guides provided that the average working hours do not exceed 56 per week; and
Preparatory or complementary works that must be carried outside the normal day.
DIFCThe Employment Law provides that working time for employees will not exceed an average of 48 hours for each seven-day period, unless the employer first obtains employee consent in writing. Whilst there are no provisions dealing with overtime, the working hours are in any event subject to the principle that they shall not be excessive or such as to be detrimental to the employee’s health and safety.
During Ramadan, a Muslim employee shall not be required to work in excess of six hours per day (without any commensurate reduction in remuneration).
An employee whose daily working time is more than six hours is entitled to an uninterrupted rest break of one hour. The daily rest period is not less than 11 consecutive hours in each 24- hour period. The weekly rest period is not less than 24 hours in each seven-day work period.
ADGMThe Employment Regulations state that employees must not work more than 48 hours in a seven-day period, unless the employee has given his prior written consent.
During Ramadan, Muslim employees who observe the fast have their working hours reduced by two hours per day.
Every employee must be granted not less than 11 consecutive hours of rest in each 24 hour period, and at least 24 hours of rest in each seven day period. Where an employee is required to work more than six hours a day, he is entitled to a break of at least one hour.
An employer can decide whether the overtime compensation is provided in monetary form, by time in lieu or a combination of both. Monetary overtime compensation is calculated as follows: (i) daily wage + 25% of the hourly rate for overtime worked between 4 a.m. and 9 p.m. and (ii) daily wage + 50% of the hourly rate for overtime worked between 9 p.m. and 4 a.m.
Employees in managerial or supervisory positions, as well as those in positions where it is reasonably expected within that industry internationally that overtime compensation is not payable, are exempted from overtime compensation.
Is an annual flight ticket to the employee’s home country mandatory?
UAEThere is no requirement under the UAE Labour Law to provide an annual flight home, however this is market practice and some freezones make this a mandatory requirement as part of their internal employment regulations. The employer may use their discretion to extend this entitlement to the employee’s family if deemed appropriate.
DIFC and ADGMLikewise, the DIFC Employment Law and ADGM Employment Regulations do not require employers to provide an annual flight home, but it is customary to do so.
In what circumstances can an employer terminate employment?
UAEEmployees may be terminated on completion of the fixed term period. Alternatively, an employer may terminate employment at any time by providing notice and paying out all statutory and contractual entitlements. After the successful completion of the probation period, notice can range from 30 to 90 days.
The contract of employment will continue to be valid during the course of the notice period and the employee can be required to continue working for this period. However, an employer can opt to make a payment in lieu of notice if it so chooses.
If the employer or the employee fails to give the required period of notice prior to terminating the employment contract, the party in breach will be liable to pay the other compensation in lieu of notice. This holds true even where such failure has caused no loss to the other party. Compensation in lieu of notice is calculated as the amount equal to the employee’s wage for the notice period in full (or in proportion to the diminished part if some notice has been provided).
An employer may terminate employment at any time by providing notice and paying out all statutory and contractual entitlements.
There are limited grounds under which an employer may validly terminate an employee’s services without notice. These exhaustive grounds are as follows:
If it is proven that the employee impersonates another person or has submitted false certificates or documents.
If the employee makes a mistake that results in a grave material loss to the Employer, or if the employee deliberately harms company property and acknowledges the same, provided that the latter shall inform the MOHRE of this within seven (7) working days.
If the employee violates the instructions of the company’s internal system related to the safety of work.
If the employee fails to perform his basic duties according to the employment contract and continues to breach them despite receiving two written warnings.
If the employee discloses any of the work secrets related to industrial or intellectual property, which results in losses to the company, missing an opportunity for the company or gaining a personal benefit to the employee.
If during working hours he is found drunk or under the influence of a narcotic or psychotropic substance or has committed an act contrary to public morals in the workplace.
If in the course of his work, the employee commits, against the company , the manager or any of his superiors or colleagues, a verbal or physical assault or any other form of assault punishable under UAE laws.
If the employee is absent from work without a legitimate reason for more than twenty (20) non-consecutive days, or more than seven (7) consecutive days.
If the employee illegally exploits his job position to obtain personal results and gains.
If the employee works for another company without complying with the controls and procedures established in this regard.
Save for notice, employees terminated for any of the above reasons are entitled to all statutory entitlements, including end of service gratuity (where applicable).
An employer may not terminate the employee’s services for health reasons before the employee has taken the period of sick leave he is entitled to and any agreement made to the contrary is null and void.
Termination of an employee’s services may be considered unlawful in the event the employee’s contract is terminated due to his filing a serious complaint to MOHRE or filing a case against the employer before the authorities which has been proven to be true (similar to retaliation in other jurisdictions). The UAE Labour Law provides for compensation in such circumstances is capped at three months’ wages. In determining the compensation payable, the Labour Courts will consider (i) the type of work carried out by the employee, (ii) the amount of damage sustained by the employee and (iii) the length of the employee’s service.
DIFC and ADGMAfter the successful completion of an employee’s probation period, the employer may terminate employment by providing notice and paying out all statutory and contractual entitlements.
The DIFC Employment Law provides for a minimum notice period for both an employer and an employee, as follows:
7 days, if the period of continuous employment is less than three months;
30 days, if the period of continuous employment is three months or more; or
90 days, if the period of continuous employment is five years or more.
The ADGM Employment Regulations provide for a minimum notice period for both parties, as follows:
7 days, if the period of continuous employment is less than three months; or
30 days, if the period of continuous employment is three months or more.
Notwithstanding the above, neither the DIFC Employment Law nor the ADGM Employment Regulations prevent an employer or employee from agreeing to a longer period of notice, nor do they prevent either party from waiving notice or from accepting a payment in lieu of notice.
In the DIFC only, waiving notice or accepting a payment in lieu of notice must be agreed with the employee (as part of a written settlement agreement) as part of the arrangements to terminate the employment or to resolve a dispute with the employer (with the employee being given the opportunity to obtain independent legal advice from a DIFC legal practitioner prior to entering into the agreement).
Both, the DIFC Employment Law and ADGM Employment Regulations adopt a similar principle in respect of termination without notice, referred to as termination for cause. Employment may be terminated for cause where the conduct of the employee is such that a reasonable employer would have terminated the employment in such circumstances. By contrast with the above exhaustive list in the UAE Labour Law, the DIFC Employment Law and ADGM Employment Regulations adopt a principle of reasonableness in the response to the particular conduct.
Similar to the position in the UAE, save for notice, employees terminated for ‘cause’ in the DIFC and ADGM are entitled to all statutory entitlements, including end of service gratuity (where applicable).
UAE and ADGMIn the UAE and the ADGM, an employee who has completed at least one year of continuous service is entitled to an end of service gratuity payment on termination of employment, which is calculated with reference to the last basic salary (excludes any allowances) as follows:
21 calendar days’ basic pay for each year of service for the first five years
30 calendar days’ basic pay for each year of service above five years
The entitlement is subject to a cap of two years’ wages.
Qualifying UAE and GCC national employees must be registered with the relevant state pension scheme. The minimum benefits payable into the state pension scheme differ depending on the employee’s nationality.
DIFCPrior to February 2020, the DIFC Employment Law also required payment of an end of service gratuity, similar to the UAE Labour Law and the ADGM Employment Regulations, above. With effect from 1 February 2020 however, all employees (other than qualifying UAE and GCC nationals and other exempted categories) must be registered under the DIFC Employee Workplace Savings Scheme or other qualifying scheme as approved by the DIFC (collectively the “Scheme”). The minimum benefits payable into the Scheme on a monthly basis are 5.83% of an employee’s basic salary for that month (for the first five years of employment) and 8.33% of the employee’s basic salary for that month (once the employee has at least five years of continuous employment). Employees may opt to make voluntary contributions into the Scheme in addition to the statutory contributions made by the employer, should they wish.
Where an employee has been in employment prior to 1 February 2020, the employee may either:
be paid out any gratuity (which they accrued in the period of employment prior to the implementation of the Scheme) on termination of their employment; or
opt to have the accrued gratuity transferred into the Scheme.
For the purpose of making contributions into the Scheme and end of service gratuity calculations, basic salary should comprise at least 50 percent of the total salary.
Are companies obliged to hire UAE nationals?Employers in the banking and insurance sectors have, historically, been required to comply with Emiratisation targets. In June 2022 however, a federal government program aimed at increasing the competitiveness of UAE nationals and encouraging them to occupy jobs in the UAE private sector (“NAFIS”), was made mandatory for all private sector employers regardless of industry.
Employers in onshore or mainland UAE (and governed for employment and labour purposes by the MOHRE), employing 50 or more employees must enroll with NAFIS and subsequently increase their percentage of UAE nationals hired by 2% each year, until the target of 10% by 2026.
Failure to do so initially resulted in fines of AED 6,000 (approx. USD 1,630) per month per UAE national not hired. Fines were initially expected to be issued at the start of each year however in February 2023, the authorities announced that the target percentage increase would be amended to a 1% increase every 6 months instead, with fines payable at the half-year mark as well as at the start of each year. In 2023, the monthly fine for non-compliance was increased to AED 7,000 (approx. USD 1,905) per month, with monthly fines set to increase by AED 1,000 (approx. USD 270) each year.
Private sector employers in mainland UAE with 20 to 49 employees within several sectors, including but not limited to those in the banking, healthcare, manufacturing wholesale and retail sectors, are also obliged to hire at least one UAE national employee in 2024 and another UAE national in 2025. Companies which fail to meet the target in 2024 will face a fine of AED 96,000 in January 2025 and a further fine of AED 108,000 in January 2026.
Certain specific roles must also be filled by UAE nationals, including:
Private sector employers in mainland UAE with over 100 employes must hire at least one UAE national Public Relations Officer (PRO);
Private sector employers in mainland UAE with over 1,000 employes must hire at least two UAE national data entry officers; and
Private sector employers in mainland UAE in the construction and industrial sector with over 500+ employees must hire at least one UAE national as a Health and Safety Officer.
Emiratisation quotas are not applicable in any free zones, including the DIFC and the ADGM.
