The two "minimum" health policies in the UAE exclude opposite things.

Three regulators, one obligation

The federal duty is short and it is not the source of the detail. Article 13(8) of Federal Decree-Law No. 33 of 2021 obliges the employer to bear "the costs of the worker's medical care in accordance with the legislation in force in the State", and Article 13(9) adds the expenses of insurances and contributions defined by that legislation. Article 22(3)(a) of Cabinet Resolution No. 1 of 2022 gives the Ministry the job of "monitoring the employer's compliance with respect to the provision of health insurance for workers" — again, in accordance with the legislation in force. Both provisions point outward. The actual content of the obligation is set by the emirate.

The Northern Emirates package, from MOHRE's own page

MOHRE describes it as the implementation of "the Cabinet decision to extend mandatory health insurance coverage to all the Emirates for private sector employees and domestic workers starting 1 January 2025", introduced with the Federal Authority for Identity, Citizenship, Customs and Port Security and the Ministry of Health and Prevention. The target population is stated exactly: "Private sector employees and domestic workers in Sharjah, Ajman, Fujairah, Ras Al Khaimah, Umm Al Quwain."

The medication line is worth flagging rather than paraphrasing. MOHRE's wording — "an annual co-payment of 30% is covered, capped up to AED 1,500" — reads two ways: a 30% co-payment on the insured's side up to a ceiling of AED 1,500 a year, or 30% of the drug cost being the covered share. The inpatient and outpatient lines on the same page are unambiguous and both put the percentage on the insured, which points to the first reading. It is set out here as written; before relying on it for a specific claim, take the number from the policy schedule the insurer issues.

Dubai: the minimum is a published table, not a price

Dubai Law No. 11 of 2013 puts the enrolment duty on the employer at Article 9(a)(2) — the employer enrols its employees on its own policy, "provided that the Health Benefits of such policy are no less than the Basic Coverage". The DHA fixes what Basic Coverage means. Its Policy Directive PD 01/2021 attaches the Table of Benefits for the Essential Benefits Package, and the heading of that table is the point most employers miss: it is "also the minimum standard for ANY policy of health insurance issued in the Emirate of Dubai".

So the EBP is not simply the cheap plan for low-paid staff. It is the floor under every Dubai policy, including the executive plan at the other end of the payroll. What the table actually requires:

• AED 150,000 annual upper aggregate claims limit, inclusive of any coinsurance and deductibles.
• Geographic scope for basic services: within the Emirate of Dubai. Emergency treatment, including ambulance charges, is covered across all seven emirates. A limited provider network is acceptable, but it "must provide reasonable geographic access for the insured in relation to place of work and residence".
• A GP referral gate: for EBP members, nothing incurred with a specialist or consultant is payable unless the insured first saw a licensed GP who made the referral through the DHA e-Referrals system.
• Inpatient non-urgent treatment: prior approval, 20% coinsurance capped at AED 500 per encounter and AED 1,000 a year; above the caps the insurer pays 100%. Emergency treatment: approval within 24 hours of admission. Rooms of two or more beds.
• Maternity is in. Outpatient ante-natal at 10% coinsurance — eight visits, three ultrasound scans and a specified list of initial investigations. Inpatient maternity at 10% coinsurance with a maximum benefit of AED 10,000 per normal delivery and AED 10,000 for a medically necessary caesarean, complications or a medically necessary termination, all limits inclusive of coinsurance. A newborn is covered on the mother's policy for 30 days from birth.
• Pre-existing conditions must be covered and cover cannot be denied because of them — but treatment for chronic and pre-existing conditions may be excluded for the first six months of an individual's first scheme entered into within the UAE. If such a condition becomes an emergency inside that six-month window, it must be covered up to the annual limit.
• Companion accommodation for a child under 16, or where medically necessary, at up to AED 100 a night.

The low-salary segment is a separate mechanism inside the same rules. DHA Policy Directive PD 11-2020 defines Participating Insurers as the companies approved "to transact and market EBP product for Low Salary Band employees (employees who draw salaries below AED 4000/-)". Those insurers have exclusive access to that segment and in exchange cannot refuse to cover it. Where staff sit below that line, the EBP is bought from a Participating Insurer and no other.

Abu Dhabi: the only emirate that makes you insure the family

Article 5 of Abu Dhabi Law No. 23 of 2005 is a single sentence with an unusually wide reach: "The Employer shall undertake to provide health insurance coverage for all his employees/workers and their family members including an employee's/worker's wife and three children under 18 years of age." The same article closes the loop on immigration: a non-UAE national "may not obtain a residence permit or renewal thereof, nor may he be employed, unless after enrollment into the health insurance scheme."

The Implementing Regulation fills in the mechanics, and several of its clauses have no equivalent anywhere else in the country:

• Article 11(2). Where an employee has more than one wife on his sponsorship he must tell the employer in writing which is to be insured; absent that notice, "the Employee's first wife shall be deemed to have been selected".
• Article 11(3). More than three children under 18 on the sponsorship: the employer insures the first three resident in the State, eldest first, and when one turns 18 the next in birth order takes the place.
• Article 11(4). The employer bears the cost of the policies for the employee and their dependents "and shall not pass on the cost of providing such policies, or any part thereof, to its Employees".
• Article 11(6). The authorities "shall not renew an Employer's trade licence" without evidence of subscription for the previous period. Article 11(9): no work visa application without evidence of subscription.
• Article 12(7). The clock. The obligation begins "after seven working days following the arrival of the Employee or the sponsored person to the Emirate or from the date on which the medical examination card is obtained, whichever occurs first" — not on visa issue, and not on the first day of work.

The fine is the smaller half of the exposure

Both emirate laws impose a penalty, and both then quietly impose something larger.

Read the Abu Dhabi arithmetic before assuming the fine is a rounding error. AED 300 a month is a floor, it runs per month of non-subscription, and it compounds by headcount. Twenty uninsured workers for a year is AED 72,000 at the statutory minimum, before the AED 5,000–20,000 in Article 24(2) and before the licence renewal is refused.

Then compare that with the last row. Dubai's Article 10(4) attaches emergency costs to the employer. Abu Dhabi's Regulation goes further: Article 9(2) covers the emergency case, but Article 11(5) is not written as an emergency provision at all — it makes an unsubscribed employer liable for the cost of healthcare services provided to employees and their dependents. One intensive-care admission clears the top of Dubai's fine range on its own. The insurance is not priced against the penalty; it is priced against a bill nobody can forecast.

Free zones are not outside this

Article 4 of Dubai Law No. 11 of 2013 states its own scope: the Law "will apply to all areas of the Emirate including Special Development Zones and free zones such as the Dubai International Financial Centre", and it lists employers and sponsors among the persons it binds. A DIFC or free-zone employer whose employment relationship sits outside the federal labour law is still inside the Dubai health insurance regime, and still inside Article 10(4). Employment law and health insurance law draw their boundaries in different places — see how the same split works for end-of-service in the DIFC.

What an employer actually has to do

1. Establish which regime each worker sits in — by the emirate of the establishment and the residence permit, not by where the head office is.
2. In Abu Dhabi, count the dependents. The spouse and three children under 18 are the employer's obligation, not the employee's, and the written nomination in Article 11(2) should be collected at onboarding rather than at claim time.
3. Diarise the Abu Dhabi start date from the medical examination card, and from arrival plus seven working days, and use the earlier of the two.
4. In Dubai, check the policy against the PD 01/2021 table rather than the broker's summary — annual limit AED 150,000, maternity limits, the six-month pre-existing rule, and the GP referral gate, which is what most rejected specialist claims turn on.
5. In Dubai, if any employee is under AED 4,000 gross, buy from a Participating Insurer. The segment is closed to other insurers.
6. In the Northern Emirates, budget AED 320 per head per year and note the two-year policy term, with the second year refundable on visa cancellation — that refund is real money on a workforce with turnover.
7. Tell workers in the Northern Emirates scheme, in writing, that maternity and dental are not covered. It is the single most common surprise in that package and the cheapest one to prevent.
8. Never deduct the premium from wages, and never make its repayment a condition of resignation. It is prohibited in all three regimes.
9. Keep proof of subscription for the previous period. In Abu Dhabi the trade licence renewal depends on it; everywhere the residence permit does.

Sources

• The Basic Health Insurance Scheme — the 1 January 2025 extension to all emirates for private sector employees and domestic workers, the five target emirates, the AED 320 premium, the two-year term and second-year refund, the inpatient, outpatient and medication co-payments, the exclusions for pregnancy, childbirth and dental care, cover for chronic and pre-existing conditions without a waiting period, the network size, dependents and telehealth, and the purchase channels, MOHRE, Guidance and Awareness Portal
• Law No. (11) of 2013 Concerning Health Insurance in the Emirate of Dubai — Article 4 on scope including free zones and the DIFC, Article 8 on health benefits for residents, Article 9 on responsibility for enrolment, Article 10 on the obligations of an employer including bearing emergency costs for an uninsured employee and not charging the cost to beneficiaries, Article 23 on penalties, Dubai Legislation, official English text
• Policy Directive PD 01/2021 — Updated Table of Benefits for the Essential Benefit Plan, described in the table heading as the minimum standard for any policy of health insurance issued in the Emirate of Dubai: the AED 150,000 annual aggregate limit, geographic scope, provider network standard, the pre-existing conditions rule, the GP referral requirement, inpatient coinsurance caps and the maternity benefits, Dubai Health Authority (PDF)
• Compliance with Essential Benefits Plan, PD 11-2020 — the EBP as the minimal level of cover under Law 11 of 2013, and Participating Insurers as those approved to market the EBP for the Low Salary Band, defined as employees drawing salaries below AED 4,000, Dubai Health Authority (PDF)
• Law No. (23) of 2005 Concerning Health Insurance in the Emirate of Abu Dhabi and its Implementing Regulation — Article 4 on compulsory subscription, Article 5 on the employer's duty to cover employees and their family members, Article 24 on penalties; Regulation Article 9 on the cost of emergency healthcare for the uninsured, Article 11 on the obligations of the employer including the nomination of a spouse, the first three children, the prohibition on passing on cost, the trade licence and work visa conditions, and liability for healthcare costs when not subscribed, and Article 12(7) on when the obligation begins, Department of Health – Abu Dhabi (PDF)
• Federal Decree by Law No. (33) of 2021 Concerning Regulating Labour Relations and its amendments — Article 13(8) on bearing the costs of the worker's medical care and Article 13(9) on the expenses of insurances and contributions, MOHRE, consolidated English text (PDF)
• Cabinet Resolution No. (1) of 2022 Concerning the Executive Regulation of Federal Decree-Law No. (33) of 2021 — Article 22(3)(a), the Ministry's role in monitoring employer compliance with the provision of health insurance, MOHRE, full English text (PDF)

Verified 9 September 2026. The Northern Emirates figures were read on MOHRE's own Basic Health Insurance Scheme page on the day of publication. The Dubai benefit limits, coinsurance caps, maternity maxima, referral rule and pre-existing conditions rule come from the DHA's published Table of Benefits in Policy Directive PD 01/2021, and the AED 4,000 Low Salary Band definition from PD 11-2020. The Abu Dhabi obligations and penalties are quoted from the Department of Health's own English text of Law No. 23 of 2005 and its Implementing Regulation. Premium quotations circulating on broker and comparison sites were not used; the only premium stated here is the AED 320 published by MOHRE. Both emirate laws note that the Arabic text prevails over the English, and the MOHRE English texts carry "This is not an official translation". General information, not legal or insurance advice.