When an employee is injured in a warehouse, at an installation location, or on a client’s premises, businesses often focus first on insurance: whether the policy covers the incident, whether the client is responsible, and whether the insurer has approved treatment. None of these questions justifies delaying medical care or the required reports.
The sequence should be clear. Protect the injured person and secure the site while starting the applicable reports to the police and the Ministry of Human Resources and Emiratisation (MOHRE). Then confirm the employer, preserve the facts and medical records, and address treatment costs, wages during treatment, and disability or death compensation as separate matters. An accident at a client site does not automatically transfer the employer’s responsibilities arising from the employment relationship.
Treatment and reporting must begin without waiting for insurance approval
The first task after an employee is injured is to arrange medical care and control any continuing danger at the site. Article 37(2) of Federal Decree-Law No. 33 of 2021 on the Regulation of Labour Relations requires the employer, subject to the conditions and procedures in the implementing regulations, to bear the cost of treatment for a work injury or occupational disease until the employee recovers and can return to work, or a disability is established. (Source: UAE Legislation, November 2026; subject to the latest official publication.)
An insurance notification can proceed alongside treatment, but treatment should not be held back pending approval. A client may help call an ambulance, contact a hospital, or preserve the scene. That assistance does not by itself discharge the employer’s obligations.
An accident at a client site does not determine who the employer is
The place of the accident and the identity of the employer are separate facts. Where the federal private-sector employment regime applies, the business should check the employment contract, the employee’s legal status, the wage-payment relationship, and the on-site work arrangements. If direct employees, contractor personnel, and the client’s staff are working together, the accident location alone cannot determine who bears every responsibility.
If the injured person is your employee, assistance from the client or a main contractor does not automatically remove your treatment, reporting, and employment-benefit responsibilities. Contractual indemnities, recovery rights, and cost allocation can be reviewed separately; they should not interrupt the response to the employee. Employment relationships governed by special regimes such as the Dubai International Financial Centre (DIFC) or Abu Dhabi Global Market (ADGM) require a separate assessment under the relevant rules.
We recommend recording two points on the day of the accident: who controls site coordination, and who is the legal employer. The first determines who can retrieve access records, CCTV footage, and work documents. The second affects responsibility for reporting, treatment costs, and employment benefits. When these roles are treated as one and the same, each party may assume that the other has already filed the required reports.
The 48-hour limit is a deadline, not a waiting period
Article 3 of Cabinet Resolution No. 33 of 2022 requires the employer or its legal representative to notify the medical institution and coordinate treatment, report the matter to the police with territorial jurisdiction, and report it to MOHRE through the designated channels. A work injury caused by an accident, as well as another non-occupational-disease injury, must be reported to the police immediately. A work injury other than a suspected occupational disease must be reported to MOHRE no later than 48 hours after the accident. For a suspected occupational disease, the 48-hour period starts when the employer becomes aware of the suspected disease. (Source: UAE Legislation, November 2026; subject to the latest official publication.)
The two 48-hour periods do not share the same starting point, and neither permits a business to wait until the deadline before acting. A sudden accident will generally have an identifiable occurrence time. An occupational disease may involve different dates for the onset of symptoms, diagnosis, and the employer’s awareness, which is why the rules use a different trigger.
Under Article 6 of the same resolution, medical institutions have a separate duty to submit periodic data. A hospital’s submission does not replace the employer’s report under Article 3. An internal incident notice, a police report, a MOHRE report, and an insurance notification each serve a different purpose. Informing one party does not complete the other steps. (Source: UAE Legislation, November 2026; subject to the latest official publication.)
Record the facts without making your own work-injury determination
The report to MOHRE should include the employee’s name, age, occupation, nationality, workplace, and identification number, together with a brief description of the accident or suspected occupational disease, how it occurred, and the treatment measures already taken. Articles 4 and 5 of Cabinet Resolution No. 33 of 2022 also address the investigation and medical report. (Source: UAE Legislation, November 2026; subject to the latest official publication.)
The business should retain reporting receipts, factual site material, and medical documents so that the investigation, treatment follow-up, and benefit calculations refer to the same event. Record verifiable facts: when the accident happened, what work the employee was performing, who was present, what treatment was arranged, and what the medical institution concluded. Preserve CCTV footage, access records, work assignments, or site photographs when they exist. Do not create a seemingly complete file by adding facts that were never recorded.
An employee’s operating error does not, on its own, establish that no work-injury benefits are due. The exclusions from compensation under Article 38 of Federal Decree-Law No. 33 of 2021 must be established through an investigation by the competent authority. Ordinary negligence and deliberate misconduct are not the same, so a business should not make its own exemption decision before the investigation and medical findings are available. (Source: UAE Legislation, November 2026; subject to the latest official publication.)
Use the records only for handling the incident and restrict the circulation of the injured employee’s identity and medical information. An early conclusion reached outside the proper process can leave the police report, insurance claim, and employment dispute relying on conflicting accounts.
Treatment costs, wages during treatment, and compensation require separate calculations
Payments following an employee injury fall into at least three categories: treatment costs, wages while the employee cannot work, and compensation after disability or death is established. Each has different conditions and calculation rules. They should not be combined into a single private settlement, and an insurer’s pending decision should not suspend the employer’s review.
Under Article 37(2) of Federal Decree-Law No. 33 of 2021, an employee who cannot perform their work because of a work injury or occupational disease is entitled to full pay during treatment for the shorter of the treatment period or 6 months. If treatment continues beyond 6 months, half pay is due for up to a further 6 months, or until the employee recovers, a disability is established, or the employee dies, whichever occurs first. (Source: UAE Legislation, November 2026; subject to the latest official publication.)
Two calculation errors are particularly easy to make. An injured employee is not automatically entitled to a fixed full year of wages: the wage treatment depends on the inability to work and the actual course of treatment. Nor should wages during treatment automatically be calculated using basic wage alone. Death compensation under Article 37(3), by contrast, uses basic wage and is subject to the statutory range. Disability compensation must also be determined by reference to the applicable schedule under Cabinet Resolution No. 33 of 2022 and the medical findings; the employer should not set the disability percentage or final amount itself. (Source: UAE Legislation, November 2026; subject to the latest official publication.)
HR and finance should continue tracking treatment status, fitness to return to work, any disability finding, and the relevant dates, with every payment assigned to the correct category. Ordinary sick-leave rules, deductions for damaged goods, and disciplinary procedures do not replace the work-injury analysis. Insurance proceeds may affect the business’s final financial exposure, but they do not transfer the employer’s reporting and employment-benefit responsibilities to the insurer.
What should the business complete on the day of the accident?
The response should follow the dependencies between each action:
- Arrange treatment immediately, remove any continuing danger, and record when the accident occurred and what measures were taken.
- Confirm the injured person’s employment relationship and on-site work arrangements, distinguishing the employer from the parties assisting at the site.
- Do not wait for the hospital or insurer to file on the employer’s behalf. Start the police report immediately and complete the MOHRE report within 48 hours of the applicable trigger.
- Preserve reporting receipts, factual material, and medical documents so that different channels do not contain conflicting descriptions of the accident.
- Track treatment costs, wages while the employee cannot work, the return-to-work or disability determination, and any later compensation separately.
The client, a contractor, and the insurer can all participate in the response. The business should still assign someone to track the statutory deadlines and the employee’s status until the employee returns to work, a disability is established, or another legally relevant outcome is reached.
For a review of whether your incident-response process, employment contracts, and insurance arrangements work together, Schedule a 30-minute complimentary assessment. Confirm the employer, reporting responsibility, and benefit calculations before addressing recovery rights and cost allocation; the most time-sensitive duties should not be left until the end.
Last updated: November 2026. This content is for informational purposes only and does not constitute legal or tax advice. For professional consultation, please contact the MIRISE team.