What does human rights due diligence in the UAE require?
There is a gap between what most organisations say about human rights and what they do about it. The gap exists in most markets. In the UAE, where migrant workers constitute over 88 per cent of the total workforce and where the conditions governing recruitment, accommodation, wages, and mobility create specific systemic risks, that gap carries particular consequences.
Human rights due diligence in the UAE is not primarily about intent. It is about having a system that identifies risks, tracks them, and demonstrates that the organisation responds when something is wrong. The regulatory and commercial environment in 2025 and 2026 is making that distinction impossible to avoid.
What the framework requires
The UN Guiding Principles on Business and Human Rights, the foundational international standard, identify three pillars: the state duty to protect, the corporate responsibility to respect, and the need for access to remedy. The corporate responsibility to respect requires that businesses conduct due diligence, not only adopt a policy, but actively identify, prevent, mitigate, and account for adverse human rights impacts in their operations and supply chains.
The OECD Guidelines for Multinational Enterprises align with this framework and extend it to cover environmental impacts alongside human rights. For companies operating in or sourcing from the UAE, both frameworks apply. Neither is aspirational guidance at this point. They are the baseline against which investor scrutiny, procurement requirements, and litigation are assessed.
The EU Corporate Sustainability Due Diligence Directive (following the Omnibus I revisions) now applies to companies with over 5,000 employees and €1.5 billion in EU turnover, with application from July 2029. Even at its reduced scope, the directive's reach extends to supply chains globally. UAE employers, recruitment agencies, accommodation providers, and labour contractors serving companies in scope of CSDDD are inside this radius.
The specific risks in UAE and GCC labour markets
Understanding what due diligence requires in this context starts with understanding what the risks actually are.
The UAE's labour market is structurally different from European or North American contexts. The majority of the workforce consists of migrant workers recruited from South and Southeast Asia, East Africa, and beyond. The recruitment process itself is one of the highest-risk points: debt bondage through excessive recruitment fees, contract substitution on arrival, and wage delays are documented and recurring problems across multiple sectors.
The UAE has introduced significant reforms in recent years, including the wage protection system, restrictions on recruitment fee charging, and the expansion of labour mobility rights, and enforcement has strengthened. But reform at the policy level does not automatically translate into changed practice at the level of individual employers, recruitment agents, and accommodation providers. Due diligence requires looking at what is happening, not only at what the law says.
A sound HRDD system in the UAE must address recruitment practices and fee charging by third-party agents, contract terms against what was agreed before departure, working hours and overtime payment, accommodation standards, freedom of movement and passport retention, and access to grievance mechanisms. For the construction sector, facilities management, hospitality, and domestic work, the sectors with the highest migrant worker concentration, these risks are most acute.
Building a system that works
A human rights due diligence system requires four things to function: a way to identify risks, processes to address them, ongoing monitoring, and meaningful accountability.
Identification starts with a human rights risk and impact assessment, a structured process that maps where in the organisation's operations and value chain the highest risks sit, and prioritises them by severity and likelihood. In a UAE context, this assessment will almost always surface recruitment practices and accommodation standards as primary concerns, regardless of sector.
From there, the work is operational: developing supplier codes of conduct with enforceable standards, integrating HRDD requirements into procurement processes, conducting supplier assessments, and establishing corrective action systems that are genuinely used when problems are identified.
Monitoring means maintaining visibility over time rather than relying on one-time assessments. Worker voice mechanisms, periodic audits, and grievance channels that workers trust and will actually use are all part of this. A grievance mechanism that produces zero complaints is usually evidence of a design problem, not an absence of issues.
Accountability means disclosing what the system found and what was done about it. Under the UN Guiding Principles, this is not optional. The question is whether the disclosure is substantive, reflecting what actually happened, or whether it is a description of processes that runs to several pages and says nothing.
What investors and buyers are asking now
The investment community has moved substantially on this. The Principles for Responsible Investment network, which represents over 5,000 signatories managing approximately USD 128 trillion in assets, includes HRDD performance as a standard component of ESG assessments. Institutional investors are asking specific questions: what due diligence was conducted, what did it find, what was done, and what is the evidence.
European buyers with CSDDD obligations are asking similar questions of their UAE-based suppliers and partners. The organisations that can answer with evidence, documented assessments, corrective action records, monitoring data, worker feedback, are in a fundamentally different position from those that can only produce a code of conduct.
The purpose of human rights due diligence is not to produce a document. It is to identify harm and reduce it. The organisations in the UAE that understand this distinction are building something durable. Those that do not are accumulating risk they may not yet be able to see.
Frequently asked questions
Is human rights due diligence legally mandatory in the UAE?
The UAE does not currently have a national mandatory HRDD law equivalent to the German Supply Chain Act or the French Duty of Vigilance Law. However, UAE-based companies with significant European business relationships face HRDD obligations through the CSDDD's supply chain reach. In addition, UAE operations of companies headquartered in jurisdictions with mandatory HRDD legislation are in scope of those laws wherever they apply.
What is the difference between a human rights policy and human rights due diligence?
A policy states an organisation's commitment. Due diligence is the ongoing process of identifying, preventing, mitigating, and accounting for actual and potential adverse human rights impacts. The UN Guiding Principles make clear that a policy alone does not satisfy the corporate responsibility to respect.
Which sectors face the highest human rights risk in the UAE?
Construction, facilities management, hospitality, domestic work, and manufacturing carry the highest documented risks given their high concentrations of migrant workers and their reliance on third-party recruitment and accommodation arrangements.
How do we begin an HRDD programme?
A human rights risk and impact assessment is the standard starting point, mapping where in the organisation's operations and value chain the highest risks sit. In the UAE context, this will typically require looking at recruitment practices, accommodation standards, and wage payment processes across direct operations and key suppliers.
TCC works with organisations in the UAE and GCC to design and implement human rights due diligence systems that meet international standards and hold up under investor and regulatory scrutiny. To discuss your organisation's current position, get in touch.
