Mainland versus 自由区 for a 招聘 agency

Determine whether the company will earn placement fees, retainers, staffing margins, software subscriptions, consultancy fees or referral commissions.

Separate HR consultancy, 招聘 mediation, executive search, temporary employment, outsourcing, labour supply, job portals and domestic-worker 招聘.

Determine whether clients are Mainland companies, 自由区 entities, overseas employers, government bodies or individual consumers.

Establish the target professions, nationalities, skill levels and countries of 招聘.

Obtain activity confirmation from DET, the selected 自由区 and MOHRE where applicable. Identify any additional sector authority.

Confirm the requirements for 股东, beneficial owners, managers and responsible employees.

Determine the applicable guarantee, 保险, capital and working-capital requirements.

Confirm office requirements before entering a long-term tenancy.

Document services, 费用, clients, candidate sourcing, overseas partners, staffing and 合规 controls.

Complete name approval, 章程文件, ownership declarations and commercial registration.

Complete the required MOHRE and other authority procedures before performing regulated 招聘.

Register the agency for the employee, work-permit and immigration processes applicable to its structure.

Provide the bank with a consistent description of the 招聘 model, customer profile and expected transactions.

Prepare employer terms, candidate privacy notices, overseas-agent agreements, anti-fee policies and complaint processes.

Set up placement tracking, recruiter commissions, worker payroll, WPS, 增值税 and 企业所得税 records.

Do not advertise, place candidates or supply workers until all required permissions are active.

Advising on HR systems is not the same as introducing candidates for employment.

The agency must verify geographic scope and any MOHRE requirement.

The authority considers the actual employment and supervision arrangement, not only the contract title.

招聘 and employment costs should not be transferred to workers through direct or indirect fees.

Regulated 招聘 can require security separate from share capital and operating cash.

The 阿联酋 agency can face legal and reputational exposure for misconduct in the 招聘 chain.

CV 提交 and personal-data sharing require appropriate controls.

A 迪拜 Mainland 招聘 agency is formed through the 迪拜 经济与旅游局 and requires approval from MOHRE where the proposed activity falls within regulated 招聘 or employment-agency services.

The Mainland company may be able to serve employers throughout the MOHRE-regulated 阿联酋 private sector, subject to:

A commercial 执照 issued by DET is only one component of the structure. The agency must also hold any required MOHRE permission before it begins regulated 招聘 operations.

A 自由区 company is incorporated and licensed by a specific 自由区 authority.

The legal scope of those activities must be confirmed carefully.

The presence of the word "招聘" in an activity description does not automatically authorise every form of employment intermediation 在阿联酋.

The Ministry of Human 资源 and Emiratisation regulates 招聘 and employment-agency activities within its jurisdiction under the 阿联酋 labour-law framework.

Relevant legislation includes Federal Decree-Law No. 33 of 2021 Regulating Labour Relations and its Executive Regulations.

A 自由区 company should not assume it can provide unrestricted candidate-placement services to Mainland employers.

A 自由区 company may be able to provide certain services to Mainland clients, but regulated 招聘 activity must remain within the permission granted by the responsible 主管部门.

A client's willingness to pay an invoice does not prove that the agency is properly licensed.

迪拜 introduced a broader framework in 2025 allowing eligible 自由区 establishments to conduct specified activities outside their Free Zones after obtaining the appropriate DET 执照 or permit.

Under 迪拜 Executive Council Resolution No. 11 of 2025, possible routes can include:

This framework does not remove federal regulatory requirements.

Even if a general consultancy activity is eligible for a Mainland operating permit, regulated 招聘, employment intermediation or temporary staffing may still require MOHRE approval.

A permit should therefore not be treated as a shortcut around 招聘-agency licensing.