A Practical Compliance Guide for Employers, Graduates, Students, and Families

Quick Take

In the UAE, employment and internship arrangements are not only HR matters. They are also immigration, labour, and compliance matters.

For university graduates, the general position is straightforward: individuals aged 18 and above may generally enter into employment, internship, trainee, or graduate programme arrangements, provided the correct work permit, visa, sponsorship, and contractual structure is in place.

For younger students, the UAE framework is more restrictive. Employment or training may be permitted from the age of 15, but only under specific safeguards and with the appropriate MOHRE permit. Children below the age of 15 cannot be employed in the UAE.

The key point for employers is simple: the title of the arrangement does not remove the compliance obligation. Whether the role is called an internship, training programme, graduate scheme, work placement, or temporary work, the employer must ensure that the correct legal and immigration pathway is followed.

Legal Framework

Employment relationships in the UAE private sector are primarily governed by Federal Decree-Law No. 33 of 2021 on the Regulation of Employment Relations, as amended, together with its implementing regulations and MOHRE requirements. The UAE Labour Law applies broadly to private-sector employees in the UAE, whether UAE nationals or expatriates, subject to certain excluded categories or separate regulatory regimes.

MOHRE has also confirmed that Federal Decree-Law No. 33 of 2021 came into force on 2 February 2022 and replaced the previous UAE Labour Law framework for private-sector employment.

In practice, this means that employers must look beyond the commercial need to hire or train a young person. They must also consider age, legal capacity, visa status, work permit category, nature of work, working conditions, and whether any additional safeguards apply.

Graduates Aged 18 and Above

For individuals who have completed university, the usual working age is 18 years and above.

A graduate aged 18 or older may generally be engaged under an employment contract, internship, trainee arrangement, or graduate programme, subject to the employer obtaining the correct work permit and ensuring that the individual has the appropriate UAE residence, visa, or sponsorship status.

This is especially relevant for companies hiring recent graduates into:

graduate trainee programmes;

entry-level employment roles;

paid internships;

fixed-term training arrangements;

professional development programmes;

probationary employment positions.

From a compliance perspective, the employer should not rely only on the individual’s degree certificate or age. The employer should also confirm whether the person is already sponsored in the UAE, whether a new work permit is required, whether the role is paid or unpaid, and whether the proposed arrangement creates an employment relationship.

The UAE’s recent civil law reform also strengthens the legal position of individuals aged 18 and above. The new Civil Transactions Law reduces the age of legal majority from 21 to 18, which has important implications for civil capacity and the ability of young adults to act independently in contractual and financial matters.

Students and Young Individuals Aged 15 to Under 18

The UAE takes a more protected approach for students and young workers below the age of 18.

Children below the age of 15 are prohibited from being employed in the UAE. Individuals aged 15 to under 18 may work only under specific conditions and after obtaining the relevant juvenile work permit.

The UAE Government also confirms that students aged 15 and above may work and receive training at operating establishments, provided there is a written contract and the applicable conditions are met.

This means that a student internship for someone under 18 should not be treated as an informal arrangement. The employer should ensure that the role is suitable for the student’s age, that the work environment is safe, and that the necessary approvals and documentation are in place.

MOHRE Training and Work Permit for Students

MOHRE provides a specific Training and Work Permit for Students. This permit allows establishments registered with MOHRE to train or employ students who have reached the age of 15, subject to specific requirements and controls designed to ensure a suitable training and work environment.

The UAE Government’s work permit guidance also refers to a student training and employment permit, which enables establishments to employ a student aged 15 who is already in the UAE, in accordance with conditions intended to ensure a safe and suitable training and work environment.

This type of permit is particularly relevant for:

student internships;

summer training;

school or university placements;

short-term practical training;

early career exposure programmes;

temporary student work arrangements.

Employers should ensure that the permit matches the actual nature of the arrangement. A student training permit should not be used to disguise regular employment, and an internship should not be structured in a way that avoids normal labour and immigration obligations.

Practical Employer Considerations

Before engaging a graduate, intern, or student trainee, employers should consider the following:

Age confirmation: verify whether the individual is below 15, between 15 and 18, or 18 and above.

Visa and sponsorship status: confirm whether the individual is already resident in the UAE or requires employer sponsorship.

Correct permit category: identify whether the role requires a standard work permit, juvenile work permit, student training and employment permit, trainee permit, or another MOHRE-approved arrangement.

Nature of the arrangement: assess whether the role is employment, internship, practical training, work experience, or a graduate programme.

Payment and benefits: clarify whether the role is paid, unpaid, stipend-based, or salary-based.

Contract documentation: ensure that the arrangement is properly documented in writing.

Health and safety: confirm that the work environment is appropriate, especially for students and juveniles.

Free zone considerations: where the employer is based in a free zone, confirm whether the relevant free zone authority has additional procedures or permit requirements.

Immigration alignment: ensure that the labour arrangement and immigration status are consistent.

Why This Matters

The UAE labour market is becoming more structured, regulated, and compliance-driven. Graduate programmes and internships are valuable tools for talent development, but they must be properly documented and correctly permitted.

For employers, the risk is not only whether the individual is capable of doing the work. The risk is whether the company has used the right legal structure.

A compliant internship or graduate arrangement protects the employer, the young worker, the student, and the wider organisation. It also supports the UAE’s broader direction toward a more transparent, skilled, and future-ready labour market.

Suggested Wording

As per the applicable UAE labour framework, including Federal Decree-Law No. 33 of 2021 on the Regulation of Employment Relations, its implementing regulations, and the relevant MOHRE work permit requirements, individuals aged 18 and above may generally enter into employment, internship, trainee, or graduate programme arrangements after university completion, subject to the applicable visa, sponsorship, contractual, and work permit requirements.

For students and younger individuals, internships or training opportunities may also be permitted from the age of 15, provided the employer obtains the required MOHRE permit, including the Training and Work Permit for Students or juvenile work permit where applicable, and complies with the relevant safeguards on working conditions, health, safety, and suitability of the work environment.

Children below the age of 15 are not permitted to be employed in the UAE.

From a compliance perspective, employers should assess each arrangement based on the individual’s age, visa status, permit requirements, nature of work, and applicable authority rules before allowing the person to commence any employment, internship, or training activity.