Every year across the GCC countries, annual summer time working hours are implemented to protect the health and safety of employees pursuant to applicable Ministerial Resolutions. These Resolutions place restrictions on the hours between which employers can require their employees to carry out any sort of work under direct sunlight. There is a specific Ministerial Resolution for each GCC country which states the dates and hours which are restricted in that country (see table below).

Country  Dates the restriction comes in effect  Hours the restriction is in place  Ministerial Decision 
Bahrain  1 July 2019 to 31 August 2019 12.00 pm to 4.00 pm
 Article 1 of Ministerial Resolution No. 3 of 2013 
Kuwait 1 June 2019 to 31 August 2019  11.00 am to 4.00 pm
 Ministerial Resolution No. 189/L of 2010 as amended by Ministerial Resolution No. 212/L of 2011
Oman 1 June 2019 to 31 August 2019
 12.30 pm to 3.30 pm
 Article 16/3-3 of Ministerial Resolution No. 286/2008 as amended by Ministerial Resolution No. 322/2011
Qatar 15 June 2019 to 31 August 2019 11.30 am to 3.00 pm
 Ministerial Resolution No. 16 of 2007
Kingdom of Saudi Arabia  15 June 2019 to 15 September 2019
 12. 00 pm to 3.00 pm
 Ministerial Decision No. 3337, dated 14/05/2014
United Arab Emirates 15 June 2019 to 15 September 2019
 12.30 pm to 3.00 pm
 Ministerial Decree No. 365 of 2018

Additional requirements

In addition to prohibiting employers from forcing employees to carry out work under direct sunlight during the restricted hours outlined above, some of the GCC countries have their own further requirements regarding employers' responsibilities. We have summarised these requirements below. 

Country  Additional responsibilities
Bahrain  The employer should display in a visible place the summer time working hours which can be easily seen by staff and inspectors. 
Kuwait N/A 
Oman  The employer should ensure that:
  • There is cool drinking water available (commensurate to the number of employees)
  • That shaded area is provided during rest breaks
  • First aid tools are provided
  • Water for washing and other uses is provided and that the water is covered to keep it cool
  • An air conditioned bus is available near the work site
  • The employer complies with any other conditions that the Ministry may require
Qatar  The employer should display in a visible place the summer time working hours which can be easily seen by staff and inspectors. 
Kingdom of Saudi Arabia  N/A 
United Arab Emirates  Employees must be provided with a shaded area during rest breaks.
Employers must display in a prominent location the daily working hours in Arabic and any other language that is understood by employees.
Employers must provide appropriate protective equipment to avoid occupational injuries and disease, in accordance with the provisions of the Labour Law.

Exceptions

Some GCC countries have implemented limited exceptions to the summer time working hours and the additional requirements highlighted above. We have summarised these exceptions below:

  • Bahrain and the Kingdom of Saudi Arabia - Those workers that work for oil and gas companies as well as maintenance workers who are required for emergencies, are excluded 
  • Qatar - Those workers that work for oil and gas companies are excluded 
  • United Arab Emirates - Work that must be non-stop for technical reasons is exempt from the midday rest period provided that employees have cold drinking water; rehydration sachets, lemons and any other substances approved by the health authorities; first aid; air conditioners; and protective shade against direct sunlight

Penalties for non-compliance

Employers who do not comply with the applicable Ministerial Resolution on summer time working hours can face severe penalties, which vary depending on location but can include fines and temporary or permanent closure of the establishment.

The penalties are summarised below:

Country  Additional responsibilities
Bahrain 
  • Imprisonment for a period not exceeding three months 
  • A fine not less than 500 Dinars and not more than 1000 Dinars 
  • Or any one of the two sanctions above
Kuwait
  • The employer shall be given a notice to rectify the contravention within the period specified provided that it shall not be more than three months
  • If the contravention is not rectified or remedied within the prescribed period, the violation shall be punished by a penalty of not less than KD 100 and not more than KD 200 for every labourer against whom the penalty is committed
  • In the event of a repetition of non-compliance/breach within three years from the date of final judgement, the penalty shall be doubled
Oman  Inspectors in charge of monitoring safety and health of employees shall be authorised to take the following procedures:
  • Issue the necessary orders to rectify violations within a specific period of time; or
  • The immediate stoppage of work partially or totally, and seeking the assistance of the Royal Oman Police if necessary
  • Companies may also be fined and/or management jailed for breaches of the regulations
Qatar  A work location can be closed by a Ministerial decision for a period not exceeding 1 month.
Kingdom of Saudi Arabia  A potential penalty of 3,000 SAR (to be multiplied by reoccurrence).
United Arab Emirates  A special record shall be prepared to document any violation and: 
  • First time offenders will receive a fine of AED 10,000 and will be downgraded to a Grade C of the second category of the Ministry's grading scale for a minimum of three months. Where a company already has this grade, no work permits shall be granted for a minimum of six months in addition to the AED 10,000 fine
  • Second time offenders will receive a AED 15,000 fine, be downgraded to Grade C of the second category of the Ministry's grading scale, and no work permits shall be granted for a minimum period of six months. Where a company already has this grade, no work permits shall be granted to it for a minimum period of nine months, in addition to the AED 15,000 fine
  • Third time offenders will receive a AED 20,000 fine, be downgraded to Grade C of the second category of the Ministry's grading scale, and no work permits shall be granted for a minimum period of nine months. Where a company already has this grade, no work permits will be granted to it for a minimum period of twelve months, in addition to the AED 20,000 fine
  • Each facility not complying with the provisions will be subject to AED 5,000 per worker found working during the announced break hours to a maximum AED 50,000 if the violation involves a considerable number of workers

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.