Introduction
The employment relationship is no longer governed solely by the employment contract signed between the employer and the employee. As businesses continue to expand and workplaces become increasingly sophisticated, employers require a comprehensive legal framework regulating the daily functioning of the enterprise. This framework is generally embodied in what is commonly referred to as the Employees’ Internal Regulations (or Internal Work Regulations).
Internal regulations constitute one of the most important instruments of corporate governance and labor compliance. They establish the rights and obligations of employees, define disciplinary procedures, regulate working conditions, and create a transparent working environment that minimizes disputes and promotes productivity.
Although both Lebanon and the United Arab Emirates recognize the importance of internal regulations, each legal system has adopted its own legislative approach concerning the obligation to prepare such regulations, their content, and the role of governmental authorities in supervising them.
This article examines the legal framework governing employees’ internal regulations under Lebanese and UAE labor legislation while highlighting the principal similarities and differences between both jurisdictions.
The Purpose of Internal Regulations
Internal regulations should not merely be viewed as an administrative document prepared to satisfy legal formalities. Rather, they constitute the internal constitution of the workplace.
Properly drafted regulations achieve several important objectives.
First, they establish uniform workplace rules applicable to all employees without discrimination.
Second, they clarify the rights and obligations of both employers and employees, thereby reducing misunderstandings and legal disputes.
Third, they create transparent disciplinary procedures that protect both parties against arbitrary decisions.
Finally, they strengthen corporate governance by ensuring consistency in the employer’s decisions and employment practices.
For multinational companies operating across several jurisdictions, internal regulations also facilitate compliance with local labor legislation while maintaining consistent corporate standards.
Internal Regulations under Lebanese Labor Law
Lebanese labor legislation has long recognized the importance of internal workplace regulations.
The principal legal basis is found in Article 66 of the Lebanese Labor Law, which provides:
Every employer employing fifteen employees or more must prepare internal regulations governing employees and the organization of work within the establishment. Such regulations must obtain the approval of the Minister of Labor.
This provision reflects two fundamental principles.
First, internal regulations become mandatory once the employer reaches the statutory threshold of 15 employees.
Second, Lebanese law subjects these regulations to governmental approval by the Ministry of Labor before they become enforceable.
This governmental supervision distinguishes Lebanon from many other jurisdictions and demonstrates the legislator’s intention to protect employees against internal regulations that may infringe mandatory labor rights.
The Ministry of Labor reviews the proposed regulations to verify their compliance with the Lebanese Labor Law, public policy, and employees’ statutory protections.
Consequently, employers cannot simply draft any internal policy they consider appropriate. Any provision contradicting mandatory labor legislation may be rejected or amended before approval.
Contents of Lebanese Internal Regulations
Although Article 66 does not specify an exhaustive list of provisions, approved internal regulations generally address:
- working hours;
- attendance procedures;
- overtime;
- annual leave;
- sick leave;
- employee duties;
- occupational safety;
- workplace conduct;
- confidentiality obligations;
- disciplinary measures;
- grievance procedures;
- use of company property;
- health and safety obligations.
Particular importance is attached to disciplinary procedures.
Internal regulations should clearly define disciplinary violations together with the sanctions applicable to each violation while respecting the principle of proportionality.
Such regulations significantly strengthen the employer’s position in the event of litigation before the Lebanese Labor Arbitration Councils.
Internal Regulations under UAE Labor Law
The UAE has adopted a modern and business-oriented approach to workplace regulation.
Unlike Lebanon, the obligation to prepare internal regulations is governed primarily by Federal Decree-Law No. 33 of 2021 on the Regulation of Labour Relations, which entered into force on 2 February 2022.
More specifically, the obligation is reflected in Article 13 of the Labour Law, read together with Article 14 of Cabinet Resolution No. 1 of 2022 concerning the Executive Regulations.
These provisions require employers employing 50 employees or more to establish written workplace regulations.
Unlike Lebanese legislation, the UAE Executive Regulations expressly state that these regulations may include:
- work organization;
- internal administrative procedures;
- disciplinary rules;
- disciplinary penalties applicable to employees.
Accordingly, UAE legislation grants employers considerable flexibility in designing workplace policies adapted to the nature of their business, provided that these policies remain consistent with the Labour Law and do not violate employees’ statutory rights.
The UAE Approach: Greater Employer Flexibility
One of the distinguishing characteristics of the UAE system is the absence of prior governmental approval comparable to that required under Lebanese law.
Employers are generally free to draft their own internal regulations without obtaining prior approval from the Ministry of Human Resources and Emiratisation (MOHRE).
This flexibility reflects the UAE’s broader economic policy aimed at encouraging investment and facilitating business operations.
Nevertheless, this freedom is not unlimited.
Internal regulations cannot contradict mandatory provisions relating to:
- working hours;
- wages;
- annual leave;
- maternity leave;
- discrimination;
- termination of employment;
- occupational health and safety;
- disciplinary procedures.
Accordingly, employers remain responsible for ensuring that their internal regulations comply with applicable labor legislation.
Comparing Lebanon and the UAE
Despite sharing the same objective, namely regulating workplace relations, Lebanese and UAE legislation differ in several important respects.
- Threshold for Application
The first distinction concerns the number of employees.
Lebanese law requires internal regulations once the employer employs 15 employees or more.
By contrast, UAE legislation imposes this obligation only on employers employing 50 employees or more.
Consequently, many medium-sized enterprises operating in Lebanon are legally required to prepare internal regulations, whereas similar businesses in the UAE may not yet fall within the statutory threshold.
- Governmental Supervision
The second distinction concerns governmental oversight.
Lebanese employers must submit their internal regulations for approval by the Minister of Labor before implementation.
In the UAE, no comparable approval process generally exists.
This difference illustrates Lebanon’s more protective regulatory model compared with the UAE’s business-oriented approach.
- Scope of Workplace Policies
Modern UAE regulations generally address broader issues than traditional Lebanese internal regulations.
Today, UAE employers frequently regulate:
- remote work;
- hybrid work;
- artificial intelligence;
- cybersecurity;
- data privacy;
- social media;
- whistleblowing;
- conflict of interest;
- anti-harassment policies.
Lebanese employers are increasingly incorporating these subjects as well, although many approved regulations continue to follow more traditional formats.
Conclusion
Internal regulations have become an indispensable component of modern employment relationships.
In Lebanon, Article 66 of the Labor Law reflects the legislator’s commitment to protecting employees through mandatory internal regulations approved by the Minister of Labor.
In the UAE, Federal Decree-Law No. 33 of 2021 together with Cabinet Resolution No. 1 of 2022 adopt a more flexible approach by requiring larger employers to establish workplace regulations while granting them greater discretion in determining their content.
Despite these procedural differences, both legal systems pursue the same objective: creating transparent, organized, and legally compliant workplaces.
For employers, carefully drafted internal regulations are no longer merely a legal obligation. They constitute a strategic management tool that promotes good governance, strengthens compliance, reduces litigation, and contributes to a productive working environment.
As labor legislation continues to evolve, employers who invest in comprehensive, legally compliant, and regularly updated internal regulations will be better positioned to protect both their organizations and their workforce.
