Global HR News

The Organisation for Economic Co-operation and Development (OECD) has released a significant update to its Model Tax Convention on Income and on Capital, introducing a new analytical framework for determining when an employee’s home office in one country may amount to a permanent establishment (PE) for an employer based in another. The revised commentary reflects the reality that remote and hybrid work are now embedded features of cross‑border employment, and it provides a more structured approach for assessing PE exposure in these arrangements.

For employers with staff working from locations outside their home jurisdiction, the new guidance raises important questions about whether a remote worker’s presence could trigger corporate tax obligations in that worker’s country of residence.

Why permanent establishment status matters

Tax treaties based on the OECD Model limit a country’s ability to tax a foreign enterprise unless that enterprise has a PE in that country. If a PE exists, the host country may tax the business profits attributable to that establishment.

Traditionally, a PE has been understood as a fixed place of business, such as an office, factory, or workshop. However, non‑traditional workplaces, including an employee’s home, can also qualify if the employer’s business is carried on from that location in a sufficiently permanent and meaningful way.

Earlier OECD commentary suggested that home‑office PEs would be rare and generally limited to situations where the employer required the employee to work from home. That approach no longer aligns with the global shift toward remote work, where employees may work from home for personal reasons, lifestyle preferences, or talent‑retention strategies.

The OECD’s new two‑part test

The updated Model introduces a two‑step analysis to determine whether an employee’s home constitutes a PE for their employer. Both steps must be satisfied before a PE is found.

1. Working Time Test
   Does the employee perform more than 50% of their total working time from home over any rolling 12‑month period?
   If the employee does not exceed this threshold, the home will generally not be considered a place of business of the employer. The assessment is based on the employee’s actual working patterns, supported by contractual terms where they reflect reality.
2. Commercial Reason Test
   If the 50% threshold is exceeded, is there a commercial rationale for the employee carrying out their activities from their home jurisdiction?
   A commercial reason exists where the employee’s physical presence in their home country facilitates the employer’s business. Examples include:
   • engaging with customers, suppliers, or affiliates in a sustained, non‑incidental way
   • developing new markets or identifying business opportunities
   • managing supplier relationships or overseeing contractual arrangements
   • interacting in real time with stakeholders in different time zones
   • accessing specialised expertise relevant to the employer’s business
   • collaborating with local businesses
   • performing services that require the employee’s physical presence
   • coordinating with colleagues or group entities.
   Where the employee works remotely solely for personal convenience or because the employer wishes to reduce office costs, the commercial reason threshold is generally not met.
   If the Working Time Test is met but the Commercial Reason Test is not, the home office will typically not constitute a PE unless other facts strongly indicate otherwise.

Implications for employers

The OECD’s revised guidance provides clearer parameters but also introduces new compliance considerations. The Working Time Test offers a straightforward quantitative indicator, while the Commercial Reason Test requires a more nuanced assessment of the employee’s role and how their activities contribute to the employer’s business.

For organisations with cross‑border remote workers, this means:

• monitoring where employees actually perform their work
• documenting the reasons for remote‑work arrangements
• evaluating whether an employee’s presence in a particular jurisdiction advances the employer’s commercial interests
• reviewing internal policies to ensure they address PE risk
• maintaining records that support the employer’s position in the event of a tax authority inquiry.

As remote work becomes more entrenched, tax authorities are likely to scrutinise these arrangements more closely. The updated OECD framework underscores the importance of proactive oversight and clear documentation.

Ontario’s New 2026 Job Posting Rules

Ontario has introduced a new set of job‑posting requirements that will apply from January 1, 2026, reshaping how employers advertise roles and communicate with candidates. The rules aim to increase transparency, fairness and predictability in the hiring process.

1. Mandatory pay transparency
   Employers with 25+ employees must include real pay information in every public job posting. This means:
   • A specific salary or
   • A salary range with a maximum spread of $50,000
   • Roles paying more than $200,000 annually are exempt.
2. Vacancy vs. Pipeline Disclosure
   Every posting must clearly state whether the role is:
   • An actual vacancy, or
   • A pipeline posting for future opportunities.
3. Ban on “Canadian Experience” requirements
   Employers can no longer require “Canadian experience” in job postings to ensure broader access to opportunities and focus hiring on skills and potential.
4. AI transparency in hiring
   If employers use AI or automated tools to screen, rank or assist with hiring decisions, they must disclose this in the posting.
   This includes tools embedded in applicant‑tracking systems.
5. Timely communication with candidates
   Employers must notify interviewed candidates of the hiring decision within 45 days.
   This reduces follow‑ups and helps maintain a respectful, predictable process.

Why these changes matter

The new rules reflect a broader shift toward fair, transparent and psychologically safer hiring practices. They also encourage employers to adopt more consistent internal processes, reducing stress and ambiguity for both hiring teams and applicants.

To comply smoothly, employers should:

• Update job‑posting templates.
• Build pay transparency into compensation planning.
• Review hiring workflows for AI use.
• Create a communication protocol for timely candidate updates.
• Train hiring managers on the new requirements.

New Employer Obligations on Workplace Equality and Violence Prevention

Mexico has enacted significant reforms aimed at strengthening workplace equality and ensuring safer, violence free working environments. On 15 January 2026, President Claudia Sheinbaum issued a federal decree amending several key statutes, including the Federal Labor Law and legislation on equality, health, education, and social protection. These changes took effect on 16 January 2026.

The reforms align Mexico’s legal framework around equality, non discrimination, and the right to a workplace free from violence, with a particular focus on gender equality and the prevention of violence against women. A central element is a new requirement for employers to provide training to all employees on preventing and eradicating violence against women in the workplace, establishing shared responsibility between employers and workers.

What employers need to do

To comply with the updated legal requirements, employers should prioritise the following actions:

• Review and update internal policies – Ensure that the Protocol to Prevent Gender Discrimination and Address Cases of Violence and Sexual Harassment or Abuse, the Psychosocial Risk Factors Policy, internal labour regulations, codes of conduct, and related policies explicitly reflect principles of equality, non discrimination, and violence free workplaces. Confirm that policies are clearly communicated and consistently applied.
• Implement or strengthen regular training programmes – Provide structured, periodic training on preventing and eradicating violence, with specific emphasis on violence against women. Maintain clear documentation of attendance, content, and frequency.
• Establish or validate a joint implementation committee – Create or confirm the effective operation of a joint employer employee committee responsible for supporting the implementation of the Protocol, overseeing related policies, and ensuring delivery of the required training.
• Assess reporting and investigation mechanisms – Ensure that reporting channels are accessible, confidential, and trusted by employees, and that they are well communicated across the organisation.
• Review investigation processes – Confirm that investigations are impartial, consistent, and aligned with the Protocol and committee oversight. Ensure that corrective measures are proportionate, documented, and effectively implemented.

Why this matters

Policies that are not actively communicated or supported by regular, documented training may be deemed insufficient. Non compliance can expose employers to administrative fines imposed by the Labor Ministry, ranging from approximately MXN 29,000 to MXN 586,000, as well as increased exposure to employee claims related to discrimination and workplace harassment.

NSW Passes Landmark Digital Work Systems Bill

The NSW Parliament has passed the Work Health and Safety Amendment (Digital Work Systems) Bill 2025, marking the most significant update to the State’s WHS framework in over a decade.

The reforms, an Australian first, bring AI‑enabled management tools, algorithmic scheduling, digital surveillance and automated decision‑making squarely within the scope of WHS regulation.

A new WHS duty for digital systems

The Bill introduces a Digital Work System Duty, requiring PCBUs to ensure, so far as reasonably practicable, that digital systems used to allocate or manage work do not pose risks to workers’ health and safety.

A “digital work system” is defined broadly to include algorithms, AI, automation and online platforms. Risks captured under the new duty include:

• Excessive or unreasonable workloads.
• Overly intrusive performance metrics.
• Excessive monitoring or surveillance.
• Discriminatory or biased automated decision‑making.

Expanded access and oversight

The reforms significantly broaden the powers of WHS entry permit holders (union officials), who will now be able to access digital systems — including emails, algorithmic tools and internal platforms — when investigating suspected WHS breaches. SafeWork NSW will issue guidelines governing how these powers are exercised, following public consultation.

Why this matters

While existing WHS duties arguably already extend to digital systems, the Bill reflects growing recognition that algorithmic management can create psychosocial risks such as stress, fatigue, job insecurity and inequitable work patterns. The amendments modernise the WHS framework and provide clarity for employers operating in increasingly digital workplaces.

Divergent stakeholder views

Unions have welcomed the reforms as overdue protections against harms associated with algorithmic management.

Employer groups have raised concerns about compliance burdens, data privacy implications and uncertainty around how regulators will assess digital risks.

Legal and operational implications

The expanded access powers create new legal risks, including potential exposure of privileged material and the possibility that union officials may encounter information unrelated to WHS matters.

Once the Bill receives assent, organisations will need to reassess how they procure, implement and govern digital work systems.

Key actions include:

• Treating digital tools as WHS hazards.
• Expanding WHS risk assessments to include algorithmic and psychosocial risks.
• Preparing for increased regulatory scrutiny of scheduling, monitoring and HR technologies.
• Reviewing vendor contracts for transparency and WHS‑related access rights.
• Strengthening data governance and worker consultation.
• Training managers on digital‑related WHS risks.

Looking ahead

The reforms signal a major shift in how WHS risks will be regulated in a digital work environment. With unions also gaining expanded rights of entry and new avenues to bring proceedings under earlier 2025 amendments, organisations that proactively assess their digital risk profile and update governance frameworks will be best placed to meet the new compliance expectations.

Payday Super reminder

Payday Super is coming - Australia’s superannuation system is about to undergo one of its most significant operational shifts in years. From 1 July 2026, employers will no longer be able to rely on quarterly superannuation guarantee (SG) cycles. Instead, super must be paid at the same time as wages — a reform widely known as Payday Super. 

The change affects every employer and every employee. Understanding what’s changing, and how to prepare, will be essential for compliance.

1. What Payday Super Actually Requires
   Under the new rules, SG contributions must be:
   • Calculated at 12% of Qualifying Earnings (ordinary hours plus any salary‑sacrificed super amounts).
   • Paid within seven business days of each payday.
   • Processed by the receiving fund within three business days, either by allocating the contribution or returning it if it cannot be accepted.
   Quarterly SG cycles will no longer apply. The new timing applies to all employers, including companies, sole traders, partnerships, and trusts.
2. Critical Timeframes Employers Must Meet
   

   Action	Deadline
   Employer pays SG o fund	Within seven business days of payday
   Fund allocates or return contribution	Within three business days of receipt

   If a contribution is rejected, the employer still only has the original seven‑day window to correct and resubmit it — otherwise the super guarantee charge (SGC) applies. Penalties include daily interest and strict enforcement.
   The ATO has signalled close monitoring, especially for related‑party transactions and potential non‑arm’s‑length arrangements.
3. Other Superannuation Changes Employers Should Note
   The Payday Super reforms sit alongside broader updates to SG settings:
   • The minimum SG rate increased to 12% from 1 July 2025
   • The Maximum Contribution Base (MCB) is $62,500 per quarter for 2025–26.
   • From 1 July 2026, the MCB becomes an annual cap of $250,000, creating a maximum annual SG liability of $30,000 per employee.
   SG eligibility applies to all employees aged 18+, and to under‑18s working at least 30 hours per week.
4. What Employers Should Do Now
   Even though the rules take effect in 2026, preparation needs to start well ahead of time.
   • Update payroll systems: Payroll software must be able to calculate SG on each payday, transmit contributions promptly, and maintain accurate records.
   • Review internal processes: Employers should map out how contributions flow from payroll to super funds and identify any bottlenecks that could cause late payments.
   • Strengthen documentation: Where employers are related or connected entities, robust documentation will be essential to demonstrate compliance and avoid non‑arm’s‑length concerns.
   • Communicate with employees: Workers may notice more frequent super contributions. Clear communication helps manage expectations and reduces administrative queries.

A landmark WHS case puts psychosocial risk management under the spotlight

A recent prosecution of a Commonwealth government department has marked a turning point in how Australian workplaces must approach psychosocial hazards. The case confirms what regulators have been signalling for several years: psychological health is a core element of work health and safety (WHS), and employers must manage psychosocial risks with the same rigour applied to physical hazards.

The matter arose from the tragic death of a 34‑year‑old technician who took his own life after being placed on four separate performance management “Work Plans” within six months. The department responsible for managing him was charged in 2022 with multiple offences under the Work Health and Safety Act 2011 (Cth), ultimately pleading guilty to one charge. The Court found that supervisors had not been trained in how to use the Work Plan process safely or how to identify and respond to psychosocial risks.

What the Court found

Evidence presented in court showed that the worker had displayed escalating signs of distress throughout the performance management process. Despite this, supervisors did not pause the process, refer him for support, or take steps to reduce the pressure he was experiencing.

The department had several risk‑control measures available to it, including training supervisors to:

• recognise how the Work Plan process could itself create psychosocial hazards
• identify when a worker subject to performance management may be at risk
• understand when to refer a worker for medical assessment or suspend the process to prevent harm.

The absence of this training was central to the Court’s conclusion that the department had failed to meet its WHS obligations.

The department was convicted, fined $188,000, and made subject to an adverse publicity order (yet to be published). It is the first conviction of a Commonwealth employer for failing to manage psychosocial risks under the Act. Additional charges relating to alleged psychosocial risks in remote‑work arrangements are still pending.

Themes emerging from the case

Psychosocial hazards are now mainstream WHS issues. Regulators expect organisations to treat psychological health as an integral part of WHS compliance. Processes that create foreseeable stress, uncertainty, or harm, such as performance management, must be risk‑assessed and controlled.

HR processes can themselves create risk

Performance management can generate psychosocial hazards when it is repetitive, prolonged, poorly communicated, or inconsistently applied. Employers must ensure these processes are proportionate, transparent, and responsive to changes in a worker’s wellbeing.

Supervisors are the frontline of compliance

Policies alone are insufficient. Supervisors must be trained to recognise psychosocial risks, understand when to escalate concerns, and know when to pause or redesign a process to protect worker health.

Practical steps for organisations

1. Build supervisor capability
   Supervisors should be trained to understand:
   • what psychosocial hazards look like in day‑to‑day work
   • how HR processes can contribute to psychological harm
   • when to stop, modify, or escalate a process
   • their own WHS duties and potential personal liability.
2. Review performance management systems
   Organisations should examine whether their frameworks:
   • are clear, consistent, and proportionate
   • include wellbeing checkpoints
   • avoid unnecessary repetition
   • provide oversight and quality control.
3. Integrate HR and WHS functions
   Psychosocial risk management cannot sit solely with HR or WHS. Both functions, along with operational leaders, need shared ownership of controls and decision‑making.
4. Document decisions and risk assessments
   Keeping records of how psychosocial risks were identified and managed during HR processes is both good practice and valuable evidence if issues arise later.

The broader message for employers

The case sends a clear signal: employers must ensure their systems, leaders, and processes are equipped to manage both performance and risk. Psychosocial hazards are no longer peripheral — they are central to WHS compliance, and regulators expect organisations to act accordingly.

Hong Kong will introduce a phased expansion of statutory holidays beginning in 2026, ultimately increasing the total number of statutory holidays to 17 days. The rollout will occur in stages:

• 15 days from 2026
• 16 days from 2028
• 17 days from 2030

This gradual increase continues the government’s long‑term plan to align statutory holidays more closely with general holidays.

What employers need to do

The expansion of statutory holidays places renewed importance on maintaining accurate wage and leave records for all employees. Employers must ensure that:

• Records fully comply with the requirements of the Employment Ordinance.
• Wage, attendance, and leave information is complete, up to date, and readily accessible.
• Internal processes for tracking statutory holiday entitlements are reviewed and updated to reflect the phased increases.

Failure to maintain proper records may expose employers to breaches of statutory obligations and potential penalties.

Major reforms under the Employment Relations Amendment Act now in force

The Employment Relations Amendment Act represents the most significant overhaul of New Zealand’s employment law framework since the Employment Relations Act was first introduced. The legislation received Royal Assent and came into force on 21 February 2026.

Key changes now in effect

New “Specified Contractor” gateway test

A statutory five‑part test now determines when a worker is a contractor. If all criteria are met, the individual is excluded from employee rights and entitlements.

High‑income threshold for unjustified dismissal claims

Employees earning NZD 200,000 or more in total remuneration can no longer bring unjustified dismissal personal grievances. A 12‑month transition period allows parties to opt back into the personal grievance regime or negotiate bespoke terms.

Stronger reductions to remedies for misconduct

Remedies may be reduced by up to 100% where an employee’s conduct contributed to the grievance. In cases of serious misconduct, remedies may be eliminated entirely.

Removal of the 30‑day rule

New employees no longer automatically begin employment on collective agreement terms, although employers must still provide a copy of the collective agreement and inform employees of its existence.

What this means for employers

Most changes apply immediately, with limited exceptions for non‑retrospective contractor rules and transitional carve‑outs for high‑income dismissal provisions. These reforms signal a new era in workplace relations, reshaping contractor classification, dismissal rights, and the role of collective agreements. Employers should review employment agreements, remuneration structures, and misconduct processes to ensure compliance with the new regime.

A new statutory modern slavery regime

New Zealand is preparing to take a significant step toward a formal legal framework for addressing modern slavery, with a cross‑party member’s bill set to be introduced to Parliament next week. The proposal, jointly sponsored by Greg Fleming MP and Camilla Belich MP, would create mandatory reporting obligations for large organisations and establish a coordinated national approach to preventing, identifying, and responding to modern slavery risks.

The bill’s introduction has been enabled by a recent change to the Standing Orders, allowing a member’s bill to proceed directly to the House if it has the support of at least 61 non‑executive MPs. That threshold has been met, clearing the way for the bill to begin its legislative journey.

What the bill seeks to address

Modern slavery encompasses a wide range of exploitative practices where coercion, deception, or threats are used to deprive individuals of their freedom. Under the proposed legislation, the term would cover:

• offences under the Crimes Act 1961 relating to slavery, trafficking, coerced marriage, and people smuggling
• the worst forms of child labour under ILO Convention No. 182
• trafficking in persons as defined in the UN Protocol
• forced or exploitative labour, servitude, debt bondage, sexual exploitation, and slavery
• The bill aims to create a unified framework for identifying and responding to these practices across both public and private sectors.

Who would be required to report?

The reporting obligations would apply to organisations with consolidated revenue of NZD $100 million or more in a reporting period. This includes:

• New Zealand entities
• overseas companies carrying on business in New Zealand
• parent entities that control an organisation meeting the threshold.

The definition of “entity” is broad and covers companies, partnerships, trusts, bodies corporate, Crown agencies, local authorities, and more. The threshold mirrors Australia’s AUD $100 million requirement.

What reporting would involve

Each reporting entity would need to prepare an annual modern slavery statement covering:

• the entity’s structure, operations, and supply chains
• any actual incidents of modern slavery identified within those operations or supply chains
• known or anticipated risks of modern slavery
• actions taken to assess, prevent, mitigate, and remediate modern slavery risks
• complaints received and how they were investigated or resolved
• how the entity evaluates the effectiveness of its actions
• training provided to employees and supply‑chain workers
• consultation undertaken with relevant stakeholders.

Statements would need to be published on the organisation’s website and lodged on a public electronic register.

Unlike the Australian regime, the New Zealand proposal explicitly requires reporting on actual incidents, not just risks.

Enforcement and penalties

A key point of difference from Australia’s current framework is the introduction of a comprehensive enforcement regime. The bill proposes:

• criminal offences for failing to prepare, submit, or publish a modern slavery statement
• criminal offences for knowingly providing false or misleading information
• fines of up to $200,000 for these offences
• High Court‑imposed financial penalties of up to $600,000 for non‑government entities
• director and senior management liability where offences occur with their knowledge, authority, or consent, or where they fail to take reasonable steps to prevent them.

The bill would also amend the Public Finance Act 1989 to bar entities convicted under the regime from receiving Crown funds, effectively excluding them from government procurement.

Additional government responsibilities

The bill would also require:

• annual government reporting on national progress in addressing modern slavery
• an expanded role for the Human Rights Commission
• periodic reviews of legislation, policy settings, and victim‑support arrangements.

These measures are intended to ensure ongoing oversight and continuous improvement.

What the bill does not include

Mandatory due diligence — originally proposed under the previous government—has not been included. However, the reporting criteria are drafted in a way that makes meaningful due diligence difficult to avoid in practice. Organisations will likely need to undertake supply‑chain mapping, risk assessments, and remediation planning to meet the reporting standard.

Next steps in the legislative process

The bill is scheduled for introduction on 10 February 2026, after which it will proceed to first reading and select committee. Public submissions will be invited, and amendments are expected as the bill progresses. The sponsoring MPs have expressed hope that the legislation will pass before Parliament rises for the general election later in the year.

Preparing for the new regime

Organisations can begin preparing by:

• mapping supply chains and identifying high‑risk areas
• reviewing procurement and supplier‑management processes
• developing or updating modern slavery policies and codes of conduct
• establishing due diligence and remediation frameworks
• training boards, executives, procurement teams, and legal teams
• assessing whether existing Australian‑compliant processes meet the proposed New Zealand requirements.

High Court Affirms Implied Duty of Mutual Trust and Confidence in Employment Contracts

In a landmark judgment, the Singapore High Court has confirmed that an implied duty of mutual trust and confidence forms part of all employment contracts. The decision arose from a dispute between a senior employee and his former employer, and it clarifies the standard of conduct expected of employers when managing investigations, disciplinary processes and termination.

The case: what happened

The dispute involved a senior employee who was placed under an internal investigation following allegations of misconduct. Key factual elements included:

• The employer initiated an investigation process that the employee argued was unfair, opaque and conducted in a manner that damaged his professional standing.
• The employee claimed that the employer’s actions – including the way allegations were communicated and the manner in which the investigation was handled – undermined the trust and confidence essential to the employment relationship.
• He argued that this amounted to a breach of an implied contractual duty, even though the employment contract did not expressly contain such a term.
• The employer maintained that it had acted within its contractual rights and that no such implied duty existed under Singapore law.

The High Court disagreed, holding that the duty is implied by law and applies to all employment contracts unless expressly excluded.

The Court affirmed that:

• Employers must not, without reasonable and proper cause, act in a way that is likely to destroy or seriously damage the relationship of trust and confidence.
• The test is objective – the question is whether a reasonable employer would have acted in the same way.
• The duty applies even where the employer has a contractual right to terminate with notice; the manner in which that right is exercised must still be fair and non oppressive.
• Poorly handled investigations, biased processes or humiliating treatment can amount to a breach.

 Why this matters for employers

The ruling elevates expectations around procedural fairness and respectful treatment. It also increases the likelihood that employees may bring contractual claims where they believe an employer’s conduct has been heavy handed or unjustified.

Areas of heightened risk include:

• Internal investigations.
• Disciplinary processes.
• Performance management.
• Communications surrounding termination.
• Decisions affecting an employee’s reputation or psychological safety.

Practical steps for organisations

To mitigate exposure under the newly affirmed duty, employers should:

• Review investigation and disciplinary procedures for fairness and transparency.
• Train managers on appropriate conduct and communication.
• Ensure investigations are impartial, well documented and proportionate.
• Avoid actions that could be perceived as retaliatory or damaging to an employee’s dignity.
• Seek legal advice before taking steps that may significantly impact an employee’s standing.

Looking ahead

This decision brings Singapore closer to other common law jurisdictions that recognise the implied duty of mutual trust and confidence. Employers should expect employees to rely on this duty more frequently in disputes and should ensure that people management practices reflect the higher standard of fairness now clearly embedded in Singaporean employment law.

Workplace Fairness Act — Implications for employers

Singapore is moving toward a more robust and transparent framework for addressing workplace discrimination. With the passing of the Workplace Fairness (Dispute Resolution) Bill on 4 November 2025, the full legislative structure supporting the Workplace Fairness Act (WFA) is now in place. The Act is expected to take effect by the end of 2027, giving organisations a clear runway to prepare.

How the new framework works

The WFA sets out a clear, three stage process for resolving discrimination disputes:

1. Resolve issues internally wherever possible. Employers must implement a documented grievance handling process that includes investigating complaints, communicating outcomes, maintaining written records, and protecting confidentiality. This process must be shared with all employees.
2. Attempt mediation if internal efforts fail. Mediation with a neutral third party becomes mandatory before any claim can proceed further, expanding on the current approach used for ECT matters.
3. Escalate to adjudication only when necessary. Claims that remain unresolved may be brought to the ECT (for disputes up to SGD250,000) or to the High Court for higher value matters. All hearings will be private, though judgments are expected to be published in future.

Employer protections

The framework includes measures to discourage baseless claims. Courts may strike out frivolous or vexatious matters, and individuals who misuse the process may face cost orders, police investigation, or restrictions on filing further claims.

Implications for employers

The WFA represents a cultural shift as much as a legal one. With a significantly higher claim cap and the possibility of discrimination allegations being combined with other employment disputes, employers should anticipate more complex cases. Clear policies, well documented processes, and consistent application of fair practices will be essential.

Organisations should begin reviewing their HR frameworks now — particularly hiring practices, grievance procedures, anti discrimination measures, and non retaliation policies — to ensure readiness ahead of the WFA’s implementation.

EU Pay Transparency Directive: Implementation Progress Across Member States

The EU Pay Transparency Directive (PTD) is moving steadily toward its June 2026 transposition deadline, and Member States are now at very different stages of implementation.

The Directive introduces sweeping new obligations aimed at closing the gender pay gap through mandatory transparency, reporting and worker rights – we cover everything you need to know about the EU Pay Transparency Directive. Based on current developments it is unlikely that many of Member States will have transposed the Directive by the June deadline.

Where Member States currently stand

Key updates from Joint Committee No. 200 for 2025–2026

Recent collective bargaining agreements (CBAs) concluded within Joint Committee No. 200 introduce several important changes for employers and employees. These measures implement the commitments negotiated in the sectoral agreement of 18 December 2025 and apply from early 2026 onward.

1. End of Year premium: updated rules
   Effective 1 January 2026, several adjustments impact how the year end premium is calculated:
   • Temporary unemployment counted as work: Up to five days of temporary unemployment (economic or force majeure) now count as regular working days when calculating the premium.
   • Dismissal with counter notice: Employees dismissed but who provide counter notice are now entitled to a pro rata premium, provided they have six months’ seniority.
   • Resignations and mutual terminations: Employees who resign or end their contract by mutual agreement will receive a pro rata premium after three years’ seniority (reduced from five).
2. Mobility Benefits: enhanced employer contributions
   Several mobility related improvements have been introduced:
   • Train travel: Employers must now cover 100% of the cost of a second class train ticket (as of 1 January 2026), with a recommendation to use the third party payer system.
   • Bicycle allowance: From 1 October 2026, the allowance increases to EUR 0.32/km, capped at EUR 12.80/day.
   • Private transport threshold:  The annual gross salary threshold used to determine employer contributions for private transport will be indexed annually from 2026.
3. Bereavement Leave: more generous entitlements
   From 1 January 2026, bereavement leave increases as follows:
   • Death of a partner or child: 12 days (previously 10).
   • Death of a parent or parent in law: five days (previously three).
4. Time credit and end of career schemes extended
   Sectoral arrangements for time credit systems and end of career reductions have been extended until 30 June 2029, including:
   • Time credit (with or without motive).
   • End of career reductions (1/5 or half time from age 55).
   • The EUR 90.45/month supplementary allowance for employees using these schemes.

New Military Service Requirements

Croatia has reintroduced compulsory military service following amendments to the Defence Act and the Act on Service in the Armed Forces, which entered into force in November 2025. The changes apply to all male citizens who turn 19 in a given calendar year, requiring them to complete two months of basic military training.

During the training period, the individual’s employment relationship is suspended, but employers are prohibited from terminating the employment contract. Conscripts will receive approximately EUR 1,100 net, paid directly by the Ministry of Defence for the duration of their service.

Employers must reinstate the employee to the same position once the training is completed. The government has indicated that calls for military service will be issued throughout 2026, meaning employers should prepare for potential absences across the year.

What employers need to prepare for

• Workforce planning – Anticipate potential short-term absences of eligible employees and plan staffing accordingly.
• Contract and policy review – Ensure employment contracts and internal policies reflect the suspension and reinstatement rules.
• Reinstatement obligations – Prepare processes to return conscripted employees to their original roles without delay.
• Payroll considerations – Note that remuneration during training is paid by the Ministry of Defence, not the employer.

Update to proposed amendment to Employment Contracts Act

The Finnish government has now published its proposal to amend the Employment Contracts Act, introducing more flexibility for fixed‑term employment agreements. Under the proposal, employers would be able to conclude a fixed‑term contract without a justified reason in two situations: when entering into a first employment agreement with an employee, or when rehiring an employee whose previous employment ended more than two years earlier. These contracts could last up to 12 months in total and be renewed twice within that period.

Additional changes to fixed‑term employment

The proposal also introduces re‑employment obligations and a right to terminate fixed‑term contracts with notice, marking a shift from the earlier draft published last year. Further changes include:

• Reducing the layoff notice period from 14 days to seven days.
• Limiting post‑employment re‑employment obligations in redundancy situations to employers with at least 50 employees.

These amendments would not affect equivalent provisions in collective labour agreements.

Expected timeline

If approved by Parliament, the amendments would enter into force on 1 April 2026.

Employment (Contractual Retirement Ages) Act: Legislative Update

The Employment (Contractual Retirement Ages) Bill 2025 completed all stages in the Oireachtas in December 2025 and was signed into law on 16 December. Although enacted, the legislation has not yet commenced, and no commencement date has been announced.

Key features of the new legislation

The Act introduces statutory rules governing contractual retirement ages (CRAs), requiring employers to adopt a consent‑based approach and to objectively justify any mandatory retirement provisions. Employees with a CRA below the State Pension Age (currently 66) may issue a non‑consent notification, stating that they do not agree to retire at the contractual age. The notification must be provided:

• At least three months (and no more than one year) before reaching the CRA.
• Within any notice period specified by the employer, up to a maximum of six months.

Once notified, employers may only enforce the CRA if they can demonstrate that retirement is objectively and reasonably justified by a legitimate aim and proportionate means.

New offences and penalties

The Act prohibits penalisation of employees who issue a non‑consent notification. Employers must provide a reasoned written response, and failure to do so without reasonable cause constitutes an offence. Penalties include:

• A Class A fine of up to EUR 5,000.
• Imprisonment for up to 12 months.
• Or both.

Liability may extend to both the organisation and responsible officers.

Compensation for breaches

The Workplace Relations Committee may award compensation of up to two years’ gross remuneration or EUR 40,000, whichever is greater, where an employer breaches the legislation.

Practical steps for employers

Employers should review retirement policies, ensure they have a robust framework for assessing objective justification, and implement clear procedures for handling non‑consent notifications once the Act comes into force.

New Collective Labour Agreement for Temporary Agency Workers

The new collective labour agreement (CLA) for temporary agency workers came into force on 1 January 2026. From this date, agency workers must receive employment conditions equivalent to those of comparable employees at the hirer, marking a significant expansion beyond the previous hirer’s remuneration rules. The changes also align closely with the objectives of the draft More Security for Flexible Workers Act.

What “equivalent employment conditions” now means

The CLA requires agencies to provide both essential and non‑essential employment conditions from the hirer:

• Essential conditions include wages, all allowances, and working/rest times. European case law interprets “wages and allowances” broadly, covering almost all monetary and in‑kind benefits – such as training budgets or access to on‑site facilities.
• Non‑essential conditions include all other terms; so far, only employer‑paid pension contributions fall into this category.

Conditions do not need to be identical, but the overall package must be equivalent. Essential conditions may only be offset by other essential conditions. Non‑essential conditions may be compensated with essential ones — for example, a lower pension contribution may be balanced by a higher salary.

Information obligations and liability risks

Agencies rely on hirers to provide accurate information about the employment conditions applicable to comparable roles. Under the Waadi, hirers are legally required to supply this information fully and correctly.

Before 1 January 2026, agencies should have requested and assessed this information and confirmed the equivalent package to each agency worker. Although the responsibility sits with the agency, hirers should verify that this has been done properly, as agency workers may hold the hirer directly liable for correct pay.

Approaches to composing an equivalent package

Agencies may use one of three methods:

• Full alignment – adopting all of the hirer’s employment conditions, with equivalent alternatives where exact alignment is not possible.
• Partial alignment – following key elements such as wages and leave, while creating their own arrangements for benefits that are difficult to value.
• Own scheme with project allowance – applying the agency’s standard package and adding an allowance where the hirer offers superior conditions.

Agencies must ensure their package is demonstrably equivalent. Hirers must take their information obligations seriously, as they may face chain liability if incorrect conditions are applied.

Civil court route for non‑compliance

If hirers fail to comply with the CLA, agency workers may bring a claim before the civil court. Non‑compliance may constitute non‑performance under the Dutch Civil Code. If the breach is attributable to the hirer and causes damage, the hirer may be held liable — provided a clear causal link exists. Courts may also order hirers to comply with the CLA at the worker’s request.

New Definition of “Dependent Work” from 2026

Slovakia has amended the definition of dependent work under the Labour Code, with changes taking effect on 1 January 2026. The updated definition removes the requirement that work must be performed “during working hours determined by the employer,” broadening the scope of what may be considered an employment relationship.

The reform is aimed at reducing misclassification risks, particularly in situations where self‑employed contractors or single‑member companies carry out work that otherwise reflects the characteristics of employment. Under the new framework, Labour Inspectorates will have greater authority to reclassify contractor arrangements as employment where the substance of the work aligns with the hallmarks of dependent work.

Employers found to be engaging in illegal employment face increased penalties, with the minimum fine rising to EUR 4,000, or EUR 8,000 where two or more individuals are involved.

Practical steps for employers

To prepare for the new definition and increased enforcement powers, employers should:

• Review contractor engagements – Assess whether current contractor roles could be interpreted as dependent work under the revised definition.
• Update documentation – Ensure contracts, statements of work, and internal policies accurately reflect the nature of the engagement and the level of independence expected.
• Prepare for inspections – Strengthen internal processes and maintain clear records to support classification decisions in the event of a Labour Inspectorate review.

Implications for workforce planning

The broadened definition may affect organisations that rely heavily on freelancers or sole‑trader arrangements. Employers may need to reassess workforce models, consider whether certain roles should transition to employment status, and evaluate the financial and operational impact of potential reclassification.

Rethinking Employee Geolocation: From Telepizza to the CJEU’s New Privacy Line

The debate over whether employers can track the location of their workforce has taken several sharp turns in recent years. What began as a dispute over a food‑delivery app has evolved into a broader conversation about how geolocation, AI‑driven analytics, and emerging neurotechnologies reshape the boundaries of workplace privacy.

1. The Telepizza Case: A Turning Point in Spain
   Telepizza’s internal “Tracker” initiative required delivery drivers to install a company‑designed app on their personal phones so the business could monitor their routes in real time.
   Spain’s Supreme Court initially endorsed the practice (Judgment 766/2020), reasoning that geolocation data was relatively innocuous: it merely revealed the position of a vehicle and did not expose personal traits or private circumstances. On that basis, the Court concluded that no privacy violation had occurred.
   The Constitutional Court disagreed. In its landmark ruling of 8 February 2021, it annulled the requirement entirely – not because geolocation was inherently unlawful, but because the company had attempted to impose the use of employees’ personal devices. Employers, the Court held, cannot compel workers to surrender their own property for monitoring purposes.
   This led many practitioners to infer a simple rule: Geolocation is permissible if the tracking is done through company‑owned devices. That assumption no longer holds.
2. The CJEU’s 2025 Judgment: A New Layer of Protection
   The Court of Justice of the European Union (CJEU), in its 6 November 2025 decision in Guyvan v. Ukraine, reframed the issue entirely.
   In that case, employees had been told that company‑issued tools could be monitored. When one worker made international roaming calls, the employer obtained detailed call‑location data from the telecom provider and ultimately dismissed the employee for unexplained absences.
   Under Spanish Constitutional Court doctrine, this might have been acceptable: the monitoring concerned company equipment.
   The CJEU took a different view.
   What the CJEU clarified
   • Geolocation data is personal data. Even if collected during working hours, it can reveal patterns, habits, or sensitive information such as ideology, religion, or lifestyle.
   • AI changes the equation. Data that seems harmless in isolation can be enriched through inference technologies, producing highly revealing profiles.
   • Company ownership of the device is irrelevant. Monitoring still requires:
     • clear, specific prior information to the employee
     • a strict proportionality assessment, following the logic of Barbulescu and López Ribalda.
   Where the employer failed
   • Insufficient information. Employees were told monitoring was possible, but not the scope, the disciplinary consequences, or that external data sources (like telecom providers) might be used.
   • Lack of necessity. Location data was not precise enough to confirm workplace presence, and less intrusive alternatives existed.
3. What This Means for Employers Going Forward
   The combined effect of the Telepizza ruling and the CJEU’s 2025 judgment is profound:
   The old distinction—personal device bad, company device good—is no longer a reliable guide. Any geolocation data, even when collected through corporate tools, may trigger heightened privacy protections. The rise of AI, neurotechnology, and behavioural analytics means that almost any dataset can become “sensitive” through inference.
   The new compliance baseline
   Employers must now treat geolocation as a high‑risk data category and ensure:
   • transparent, detailed notice explaining what is monitored, why, how long, and with what consequences
   • a documented proportionality test, demonstrating that the monitoring is appropriate, necessary, and the least intrusive option available
   • a reassessment of monitoring tools, especially those capable of AI‑driven data enrichment.
4. The Bigger Picture: A Shift Toward “Inferred Privacy”
   The CJEU’s reasoning signals a broader trend: privacy law is moving away from focusing solely on the data collected and toward the inferences that can be drawn from it. As AI systems become more capable of extracting emotional states, behavioural patterns, or cognitive signals, the threshold for what counts as “personal data” continues to expand.

Stricter Rules on Labour Immigration

The Swedish Government has presented a package of reforms aimed at tightening labour‑migration rules and reducing the risk of system abuse. The proposals introduce new conditions for work permits, including a requirement for comprehensive health insurance and a higher salary threshold.

Under the proposal, the minimum salary for a work permit would increase from 80% to 90% of the median wage, equivalent to approximately SEK 33,390. Certain occupational groups would be exempt from this threshold, while others would be excluded entirely from eligibility for work permits.

The reforms also allow authorities to deny work permits where an employer has been sanctioned or is suspected or convicted of specific criminal offences.

These changes have drawn criticism from employers, who argue that the measures will increase administrative and financial burdens. There are also concerns that stricter requirements may limit access to foreign talent, particularly in shortage occupations, potentially increasing reliance on EU/EEA recruitment and accelerating the need to upskill the domestic workforce.

The proposed amendments are scheduled to take effect on 1 June 2026.

Increased Penalties for Employers

Alongside the changes to work‑permit rules, the Government has proposed higher penalties for employers who hire foreign nationals without the legal right to reside or work in Sweden.

Two new offences would be introduced:

• Exploitation of foreign labour – targeting employers who take advantage of migrant workers’ vulnerable status.
• Trafficking in work permits – addressing the misuse or sale of work‑permit arrangements.

These measures are also expected to come into force on 1 June 2026.

Neurodiversity‑related tribunal claims nearly double in five years

Employment tribunal cases involving neurodivergent conditions have risen sharply, according to new analysis of government data. In 2020, 265 cases were recorded; by 2025, that figure had grown to 517, an increase of almost 95%. The pace of growth is accelerating, with a 19% rise between 2024 and 2025 alone. The latest six‑month period shows the highest number of cases yet.

Conditions most frequently cited

Autism and ADHD now dominate the landscape of neurodiversity‑related claims. Both reached their highest recorded levels in 2025, with autism cases rising to 121 and ADHD cases to 118. Together, they represent a substantial share of all claims in this category.

Other conditions show varied patterns:

• Dyslexia remains prominent, rebounding in 2025 after a dip the previous year.
• Tourette syndrome continues to appear at relatively high levels, even if growth has slowed.
• Dyspraxia and OCD remain less common but show gradual upward movement.
• Dyscalculia and dysgraphia remain rare.

Why claims are rising

Many claims stem not from deliberate discrimination, but from employers failing to recognise their obligations early enough. Under the Equality Act, a condition may qualify as a disability even without a formal diagnosis, provided it has a substantial and long‑term impact on daily activities. This triggers the duty to make reasonable adjustments.

A “one size fits all” approach is increasingly risky. Adjustments must be tailored to the individual, and assumptions about what an employee with a particular condition needs can lead to disputes.

Implications for employers

With autism and ADHD now appearing in record numbers of tribunal cases and the rise in adult diagnosis, organisations should reassess their policies, recruitment practices and day‑to‑day management. Failure to do so increases the likelihood of costly and avoidable claims.

Scotland to get an extra public holiday for football World Cup

The Scottish government has declared that the 15 June 2026 will be an additional public holiday to mark the country’s progression to the Word Cup finals. However only public sector workers working for the government will have an automatic right to the additional day off – for private sector employers it will come down to the wording in their employment contracts or their employer’s discretion (i.e. if the contract specifically states that the employee will be entitled to x number of days holiday in addition to the ‘usual’ public holidays then there will be no contractual obligation on the employer to provide the additional day.)

Updated timetable for the Employment Rights Act 2025

The government has now issued an updated timetable for implementing the Employment Rights Act 2025 (ERA). While most dates remain consistent with the original roadmap published in July 2025, there are some important shifts — most notably, the new restrictions on “fire and rehire” practices have been pushed back to January 2027.

Key implementation dates

February 2026

Repeal of most of the Trade Union Act 2016, easing ballot and notice requirements, removing the need for picket supervisors, and extending dismissal protection for employees taking protected industrial action.

Employees newly eligible for Day 1 paternity leave and unpaid parental leave may begin giving notice.

1 April 2026

National Minimum Wage increases:

• 21+: £12.71 per hour
• 18–20: £10.85
• 16–17 and apprentices: £8.00
• Accommodation offset: £11.10.

6 April 2026

• Collective redundancy: maximum protective award period doubles (applying to dismissals on or after this date).
• Day 1 rights for paternity leave and unpaid parental leave take effect.
• Whistleblowing protections strengthened for disclosures relating to sexual harassment.
• Bereaved Partners’ Paternity Leave: up to 52 weeks’ leave where a mother or primary adopter dies within the child’s first year.
• Statutory Sick Pay: removal of the Lower Earnings Limit and the waiting period.
• Voluntary gender equality and menopause support action plans.
• Publication of menopause guidance.
• Simplified trade union recognition process.
• Increases to statutory maternity, adoption, shared parental pay and maternity allowance to £194.32 per week (or 90% of earnings if lower).
• SSP increases to £123.25 per week (or 80% of pay if lower).

7 April 2026

Establishment of the Fair Work Agency, chaired by Matthew Taylor CBE. Enforcement powers will commence at a later date.

July 2026

Unfair dismissal qualifying period reduces to six months only from January 2027 and will apply to existing employees. Anyone hired from late June 2026 will therefore qualify from January 2027.

August 2026

Introduction of electronic and workplace balloting for statutory trade union ballots.

October 2026

• Regulations to establish the Fair Pay Agreement Adult Social Care Negotiating Body in England.
• Introduction of a two‑tier procurement code.
• Strengthened tipping protections.
• New duty to inform workers of their right to join a trade union.
• Enhanced trade union access rights.
• Employers required to take all reasonable steps to prevent sexual harassment.
• New duty not to permit third‑party harassment.
• Power to specify what counts as “reasonable steps” in preventing harassment.
• Regulation of unfair practices in the union recognition process.
• New rights and protections for trade union representatives.
• Extended protection against detriment for taking industrial action.

Not earlier than October 2026

Extension of employment tribunal time limits to six months.

January 2027

• Reduction of the unfair dismissal qualifying period to six months for dismissals from 1 January 2027.
• Removal of statutory caps on unfair dismissal compensation.
• Introduction of restrictions on fire and rehire.

During 2027

• Mandatory gender equality and menopause support action plans.
• Enhanced dismissal protection for pregnant employees and new mothers.
• Regulations specifying what counts as “reasonable steps” to prevent sexual harassment.
• Extended blacklisting protections.
• Reforms to the industrial relations framework.
• Regulation of umbrella companies.
• New collective redundancy consultation thresholds.
• Reforms to flexible working.
• New rights to bereavement leave, including for pregnancy loss.
• Guaranteed hours contracts and shift notice requirements for zero‑ and low‑hours workers.
• Electronic and workplace balloting for recognition and derecognition ballots.

Measures with no confirmed implementation date

• Annual leave record‑keeping: Section 35 ERA will require employers to keep records demonstrating compliance with annual leave obligations for at least six years. The commencement date is still to be confirmed.
• Further restrictions on non‑disclosure agreements: These are expected but not included in the revised timetable.

Updates to expatriate job title rules: implications for employers

Saudi Arabia has introduced new controls affecting how private‑sector employers assign job titles to expatriate staff. The adjustments, made through the Ministry of Human Resources and Social Development’s Qiwa platform, have prompted questions from companies about whether certain senior roles remain open to non‑Saudi nationals. Although the initial rollout created the impression that expatriates were being excluded from key commercial positions, subsequent clarification confirms that this is not the case — provided employers meet specific regulatory requirements.

A shift in Qiwa’s processing of job titles

At the end of January 2026, employers noticed that Qiwa had stopped allowing changes to several job titles for non‑Saudi employees. The titles affected were:

• general manager
• sales representative
• marketing specialist
• procurement manager.

Because Qiwa is the system through which work permits, employment contracts, and occupational classifications are managed, any restriction within the platform has immediate practical consequences. When a title is blocked, employers cannot issue new work permits or update an expatriate’s profession to that designation.

The sudden change led to speculation that the general manager role had been fully localized, with some reports suggesting that expatriates would need to adopt alternative titles such as CEO or chairman.

Clarification from Qiwa: eligibility unchanged, process tightened

Qiwa has since confirmed that expatriates can still hold the title of general manager. The update was procedural rather than a new Saudization rule.The key requirement is that the job title must match the company’s Commercial Registration (CR). While expatriates can no longer submit open profession‑change requests to adopt the general manager title through Qiwa, they may continue to hold the role if:

• they are formally appointed as general manager at the corporate level, and
• the CR lists them using that exact title.

This alignment ensures consistency between corporate records, employment documentation, and Qiwa’s labour data. The platform’s recent changes are intended to enforce this consistency, not to exclude expatriates from senior leadership positions.

How the update fits into the broader labour landscape

The tightening of job title controls reflects Saudi Arabia’s ongoing efforts to reshape its labour market and increase Saudi participation in key business functions. Sales, marketing, procurement, and senior management roles are considered strategically important, and the government has been steadily increasing localization requirements in these areas.

For example, companies with at least three employees in sales or marketing must ensure that 60% of those roles are filled by Saudi nationals, subject to minimum salary thresholds for Saudis to count toward localization quotas.

The recent Qiwa changes sit alongside these broader initiatives, reinforcing the government’s focus on regulating how expatriates are positioned within the private sector.

Practical considerations for employers

The developments highlight the importance of ensuring that job titles are consistent across all official records. Employers should review:

• the titles listed in employment contracts
• the designations recorded in Qiwa
• the company’s CR and corporate governance documents
• any discrepancies may prevent work permit renewals or profession changes for expatriate staff.

The episode also underscores the need for ongoing monitoring of Saudization rules, particularly in commercially sensitive functions where localization requirements are evolving.

Clarity on Alternative End‑of‑Service Benefits Scheme

The UAE Ministry of Human Resources and Emiratisation (MoHRE) has issued new guidance (11 January 2026) that finally answers many of the practical questions employers have been asking since the Alternative End‑of‑Service Benefits Scheme launched in October 2023. The update clarifies who can participate, how contributions work, how existing gratuity entitlements are treated, and what happens on termination.

The Scheme applies to private‑sector employers under MoHRE jurisdiction. It does not apply to organisations in the DIFC or ADGM, which continue to operate under their own end‑of‑service frameworks.

1. Participation Rules and Scope of the Scheme
   The Scheme is designed as an optional replacement for traditional end‑of‑service gratuity but opting in has lasting consequences.
   Participation framework:
   • Voluntary entry: Employers choose whether to join.
   • Mandatory once enrolled: After opting in, all eligible employees must be covered.
   • Minimum one‑year commitment: Employers cannot exit during the first 12 months.
   This structure gives employers flexibility at the outset but imposes stability once the decision is made.
2. Employer Contributions and Employee Options
   Monthly contributions are tied to an employee’s basic salary, with rates increasing based on length of service:
   • 5.83% for employees with less than five years of service
   • 8.33% for employees with five years or more.
   Contributions must be paid within the first 15 days of each month. Employees may also make voluntary contributions up to 25% of salary, which are tracked separately and do not affect the employer’s mandatory payments.
3. Treatment of Existing Gratuity Rights
   The guidance confirms that the Scheme does not erase or replace accrued gratuity.
   • All gratuity earned before enrolment is preserved under UAE Labour Law.
   • This amount is frozen at the date of enrolment.
   • It must be paid separately at termination, alongside any Scheme‑related entitlements.
   • Only post‑enrolment service falls under the new Scheme.
   This dual‑track approach means employers must maintain accurate historical records even after joining.
4. Key Risks and Commercial Considerations
   Compliance and operational risks
   • Late or incorrect contributions may trigger regulatory exposure.
   • Weak record‑keeping can lead to disputes at termination.
   • Exiting the Scheme after the first year requires MoHRE approval and may involve liquidity and financial‑health assessments.
   Commercial impact
   The Scheme can smooth cash flow by replacing large end‑of‑service lump sums with predictable monthly contributions. Investment returns are not guaranteed, and the financial risk ultimately sits with the employee/beneficiary. Employers may need to update payroll systems, HR processes, and employment contracts to reflect Scheme participation.
   Areas where guidance is still developing
   • Practical expectations for exiting the Scheme after the first year
   • Treatment of specific employee categories and non‑standard benefit structures
   • Provider‑level rules on withdrawals, investment choices, and fund administration.
5. What Employers Should Do Next
   Assess applicability
   Confirm whether your workforce falls under MoHRE or a free‑zone regime such as DIFC or ADGM.
   Evaluate financial and operational impact
   Model the cost of monthly contributions, review liquidity implications, and assess how the Scheme interacts with existing benefit structures.
   Update internal systems
   Review and adjust:
   • HR policies
   • Payroll processes
   • Employment contracts.