INSITE - UAE- November 2025
- sukhwinder21
- Dec 24, 2025
- 3 min read
BAHRAIN LABOUR LAW INSIGHTS: WINTER 2025 COMPLIANCE UPDATE
Summary: Bahrain has introduced and proposed several important labour law developments impacting employer compliance in Winter 2025. Key updates include stricter workplace first aid and emergency care requirements, proposed reforms tightening redundancy termination procedures, clarifications from the Court of Cassation on pension contributions and arbitration clauses, and the continued rollout of the Wage Protection System (WPS) ahead of full enforcement in February 2026.
In Detail: Bahrain continues to refine its employment and workplace compliance framework. This Winter 2025 update highlights key regulatory, legislative, and judicial developments with immediate relevance for employers operating in the Kingdom.
In this edition, we cover:
enhanced first aid and emergency medical care requirements under Ministerial Resolution No. 16 of 2025;
proposed amendments tightening redundancy dismissal procedures;
recent Court of Cassation guidance on pension contributions and arbitration clauses in employment contracts; and
the ongoing implementation of the Wage Protection System (WPS), including registration, payroll, and enforcement timelines.
These developments have practical implications for HR, legal, and compliance teams across all sectors. Employers should review internal policies, payroll workflows, and dispute-resolution mechanisms to ensure alignment with Bahrain’s evolving labour law landscape and mitigate enforcement risk.
Enhanced Workplace First Aid & Emergency Care Requirements
The Ministry of Health’s Resolution No. 16 of 2025 has elevated workplace health and safety standards by introducing mandatory first aid and emergency response obligations. Employers are now required to:
establish first aid arrangements proportionate to workforce size and workplace risk;
appoint certified first-aid personnel at a minimum ratio of one trained employee per 20 employees;
designate a responsible person to maintain supplies and coordinate with authorities;
provide fully compliant first aid kits; and
implement a comprehensive emergency response plan, including evacuation routes and details of nearby medical facilities.
These requirements should be integrated into broader health and safety systems, including staff training schedules and emergency preparedness planning. Non-compliance carries criminal penalties, including imprisonment of up to three months and/or fines ranging from BHD 300 to BHD 3,000.
Proposed Tightening of Redundancy Termination Rules
A bill recently passed by the Bahrain Parliament proposes stricter requirements for economic dismissals, including:
extending the advance notification period to the Ministry of Labour from 30 to 60 days; and
conditioning reduced termination compensation on documentary evidence of genuine financial hardship.
Failure to meet the proposed criteria may expose employers to full termination compensation liability under Article 111 of the Labour Law. While the bill is still subject to further legislative process, employers contemplating restructuring should begin documenting financial justifications contemporaneously to ensure readiness if the amendments are enacted.
Recent Court of Cassation Guidance
Recent judgments from Bahrain’s Court of Cassation provide important clarification on employment compliance:
Pension Contributions: The Court confirmed that employees are insured by operation of law, regardless of whether they are formally registered with the Social Insurance Organisation. Employers remain responsible for timely registration and contribution deductions. Where an employer pays the employee’s share due to payroll error, the employer retains a right of recourse against the employee as a personal debt, subject to a 15-year limitation period, preventing unjust enrichment.
Arbitration Clauses in Employment Contracts: While arbitration clauses are generally enforceable, the Court held they will not be upheld where they undermine statutory labour protections or public-order considerations. Employment disputes particularly lower-value claims may proceed before the Labour Courts despite contractual arbitration provisions.
Employers should review arbitration clauses and consider tiered dispute-resolution mechanisms that preserve statutory labour rights.
Wage Protection System (WPS): Implementation & Enforcement
Bahrain’s Wage Protection System (WPS) requires employers to pay wages exclusively through licensed banks or payment service providers regulated by the Central Bank of Bahrain, with electronic payroll monitoring serving as legal proof of payment.
Key compliance steps include:
registration on the Expatriate Management System (EMS);
appointment of a Wage Responsible Person holding a smart Bahrain or GCC ID;
setup and verification of payroll sender accounts through BENEFIT integration; and
maintenance of detailed employee salary profiles, including bank or wallet details and fixed and variable pay components.
Bank onboarding continues through late 2025, with full enforcement scheduled for February 2026. Non-compliance may result in restrictions on work permit issuance, enforcement action, and classification as a violation of workers’ rights. Employers should therefore ensure payroll systems and file formats are fully aligned with WPS requirements well ahead of the enforcement deadline.
Comments