If you employ 50 or more people in the UAE and some of them earn AED 1,500 a month or less, housing them is no longer a matter of finding beds. Under Ministerial Resolution No. 122 of 2026, the Ministry of Human Resources and Emiratisation (MOHRE) expects that housing to be approved, registered in its systems and kept up to date. Get the records wrong and MOHRE can suspend the accommodation file.
TL;DR: MOHRE Resolution 122 of 2026 requires establishments with 50 or more workers to house those earning AED 1,500 a month or less in MOHRE-approved, registered accommodation. Records must stay accurate. New standards include 24-hour security, one supervisor per 200 workers and free internet. Dubai sets its own threshold at AED 2,000.
Who Do the New UAE Labour Accommodation Rules Apply To?
They apply to private-sector establishments with 50 or more workers, for workers whose contractual monthly wage is AED 1,500 or less (Morgan Lewis, 2026). Workers on commission at occupational level 5 or above fall outside the wage test (Clyde & Co, 2026).
One detail catches people out. Local authorities can widen the net within their emirate, lowering the 50-worker headcount or raising the wage cap, in coordination with MOHRE. So treat the federal figures as the minimum.
In our experience the businesses closest to the line are not the large contractors, who have housed workers for years. They are growing cleaning, security, logistics and hospitality operators that crossed 50 staff recently and still rent flats on an ad hoc basis.
Does Dubai Have a Different Threshold?
Yes. Dubai Executive Council Resolution No. 12 of 2025 requires establishments licensed in Dubai with 50 or more workers earning AED 2,000 or less to provide them with accommodation (Dubai Legislation Portal, 2025).
That is a wider net than the federal AED 1,500 figure. A Dubai employer with staff on AED 1,800 a month sits outside the federal wage test but inside the Dubai one. The Dubai resolution gave covered establishments one year from its effective date to comply, with a single extension available.
So check both instruments. If you hold licences in more than one emirate, map your headcount and wages against each set of rules separately rather than assuming the federal threshold is the whole answer.
What Resolution 122 Actually Requires
The core duty is simple: house in-scope workers only in accommodation that MOHRE has approved and registered, and keep the accommodation and worker data in MOHRE's systems accurate whenever anything changes (Clyde & Co, 2026). Accommodation owners carry matching registration duties.
The standards themselves have also gone up. The resolution calls for 24-hour security from a licensed company, CCTV at entrances, exits and common areas, at least one supervisor per 200 workers, a minimum of one water cooler per 30 workers, free internet throughout, secure personal lockers, and periodic cleaning by specialist contractors. Facilities for People of Determination and for injured or sick workers are required too.
MOHRE's accommodation guide adds larger-site rules. Complexes housing 1,000 or more workers need a medical clinic open around the clock, and sites must sit at least 5 km from family residential neighbourhoods (Gulf News, 2026).
What Happens If Your Records Are Wrong?
MOHRE can suspend the accommodation file where it finds incorrect information or a breach of the standards, and notify the relevant authorities. Repeated violations can lead to further administrative action against both the establishment and the accommodation owner (Morgan Lewis, 2026).
The data point matters more than it looks. MOHRE ran about 212,000 inspection visits in the first half of 2026, and submitting incorrect data or documents was among the most common breaches found, alongside hiring without permits and missing Wage Protection System payments (WAM, 2026).
What we see most often is drift rather than deliberate error. A worker moves to a different building, leaves, or joins on a temporary arrangement, and nobody updates the file. If you already reconcile headcount for WPS compliance, add the accommodation register to the same monthly check.
The VAT Recovery Angle
Registered, mandatory housing can support your VAT recovery. Since 1 October 2026, Cabinet Decision No. 149 of 2026 lets you recover input VAT on employee accommodation through the legal-obligation route only where the housing is mandatory under MOHRE decisions or directives (Gulf News, 2026). We covered that change in our post on Cabinet Decision 149.
For an in-scope employer, Resolution 122 is the obvious MOHRE decision to point to. Keep a short file showing your headcount, the wage data that brings each worker into scope, and the MOHRE registration for each building. Housing provided to staff outside the thresholds needs the separate conditions in FTA Decision 17 of 2026 instead.
On corporate tax, housing you are required to provide is an employee cost, and employee costs are deductible under the ordinary wholly-and-exclusively rule. Our guide to UAE corporate tax deductions covers the wider picture.
What Should Employers Do This Month?
Start with a headcount test. Pull the payroll, count the workers on contractual wages of AED 1,500 or less (AED 2,000 in Dubai), and confirm whether you cross 50. If your workforce mixes job types, our guide to UAE work permit types helps with the classification.
Then work through three things:
- Check every building you use is MOHRE-approved and registered, and that each in-scope worker is recorded against the right address.
- Read your contracts with third-party accommodation providers. Morgan Lewis recommends confirming they address the new standards; in practice, add a clause making the provider responsible for security, supervision and cleaning levels, with evidence on request.
- Budget for the new standards. Licensed security, extra supervisors and specialist cleaning are recurring costs, and they belong in next year's forecast rather than a surprise invoice.
Finally, decide who owns the register. In most of the SMEs we work with, it lands with whoever runs payroll, which is the right place, provided they have a monthly prompt to update it.
Frequently Asked Questions
Does Resolution 122 apply to free zone companies?
It applies to private-sector establishments under MOHRE's remit. Free zones with their own employment regimes, such as DIFC and ADGM, run separate labour rules, so check with your free zone authority. Mainland employers and free zone businesses whose staff hold MOHRE work permits should assume the resolution applies.
When do I need to comply with the new accommodation standards?
The law firm briefings we reviewed, from June and October 2026, describe the requirements as current and set out no separate transition period. Treat them as applying now. In Dubai, the separate Executive Council resolution gave a one-year compliance window from its effective date.
Can I pay a housing allowance instead of providing accommodation?
Not for in-scope workers. The duty is to house them in approved, registered accommodation, and an allowance does not meet it. Offering an allowance as a cash alternative can also block VAT recovery on housing you do provide.
What if I have fewer than 50 workers?
The federal duty to provide registered accommodation does not bite, but check whether your emirate has lowered the headcount. If you house staff anyway, VAT recovery on that housing runs through the conditions in FTA Decision 17 of 2026 rather than the MOHRE-mandated route.
Is there a fine for incorrect accommodation records?
The resolution summaries do not list a fixed fine. The stated sanction is suspension of the accommodation file, notification to the authorities, and further administrative action for repeat breaches. Expect a suspension to need fixing before MOHRE will treat the file as compliant again, so correct records quickly.
Not sure whether your workforce crosses the threshold, or whether your VAT recovery on staff housing will hold? Talk to our team - we'll run the headcount and wage test with you and check your accommodation records and provider contracts against Resolution 122.