In 2016, the United Arab Emirates issued the Federal Decree Law number 18 of 2016 Regarding Reading (the “Reading Law”), an unusual law in global terms because it treats reading as an instrument of national development rather than a private hobby. Within the articles of this law is one that caught my attention, “Article 8” As it does something almost no employment law does: it directs the competent government authorities in the human resources sector to enable employees to read specialized materials in their field during official working hours.
Almost ten years later, the core employment regimes that actually govern the private‑sector relationships, as the UAE Federal Decree‑Law No. 33 of 2021 on the Regulation of Employment Relations (as amended) (“Federal Labour Law”), the DIFC Employment Law No. 2 of 2019 (as amended), and the ADGM Employment Regulations (2019, as amended, including the 2024 consolidation) remain SILENT on one simple but highly consequential question:
When an employee reads during working hours, is that “work” in the legal sense or is it personal use of paid time?
For boards, CEOs, and general counsel, the way this question is answered explicitly or implicitly shapes four things: The legal risk posture, The ability to defend employment decisions in disputes, The organisational capability curve, and the talent positioning in a knowledge driven market. This is no longer just a policy question. It is a governance question.
Federal Decree‑Law No. 18 of 2016 regarding reading defines it as a national value and assigns mandates to “competent authorities” to promote the right to read. Article 8 specifically requires government authorities in the HR sector to enable employees to read specialized materials in their field during official working hours.
Two important limits follow from the way the law is drafted:
Scope of application. The law states that it applies to government agencies and authorities responsible for protecting and promoting the right of reading. It does not purport to amend the Federal Labour Law or to create private sector employment entitlements equivalent to wages, leave, or working hours protections.
Private sector language. Where it refers to private sector participation, it does so in the language of encouragement (e.g., support for libraries, reading initiatives), not in the language of enforceable rights.
In other words: Article 8 is mandatory for the government ecosystem and persuasive for the private sector. It is best understood as a policy norm that can influence interpretation and governance design, rather than as a direct source of private‑sector claims.
Federal Labour Law (Decree‑Law No. 33 of 2021):
The Federal Labour Law is the primary framework for mainland private‑sector employment.
Employer development duty. Article 13 (Employer’s Obligations) requires employers to invest in the development of workers’ skills and to provide necessary training, qualification, and empowerment tools and programs. This is an explicit statutory hook for capability building inside the employment relationship.
Working time. Articles dealing with working hours (e.g., Article 17 and related provisions) cap normal working time at eight hours per day / 48 hours per week (subject to sector‑specific rules), with reductions during Ramadan, and impose daily and weekly rest requirements.
Nowhere does the law create a discrete right to “reading time.” But when an employer must (by law) develop worker skills and provide training and empowerment tools, it becomes more difficult legally to argue that all professional development activity must occur off the clock, especially where there is no meaningful training structure in place.
DIFC Employment Law No. 2 of 2019 (as amended):
Within the DIFC, employment relationships are not governed by Federal Labour Law but by DIFC Employment Law No. 2 of 2019 (as amended) where key features include:
Working time and rest. The law defines maximum weekly working hours (typically 48 hours per week unless otherwise agreed), rest periods, and overtime structures. It also requires adequate rest and imposes specific record‑keeping duties on employers.
Training obligations. While there is no general legal duty to provide “professional reading time,” the law explicitly requires employers to provide information, instruction, training, and supervision in relation to health and safety obligations.
The structural logic here is important. In a common law style regime like DIFC, tribunals and courts will look first to the contract, internal policies, and proven practice to determine whether an activity is part of “work.” The law creates a safety and welfare floor and recognises training, but it does not legislate reading as such.
ADGM Employment Regulations (2019, as amended):
ADGM’s Employment Regulations, originally issued in 2019 and updated (including in 2024), form a separate common law based regime for entities and employees within ADGM.
Two aspects are particularly relevant to the “reading as work” debate:
Working time and protections. The Regulations set a baseline of 48 hours per week (subject to agreement) and include health and safety obligations that restrict hours detrimental to employees’ health. Employers cannot require or allow working hours that compromise safety and wellbeing.
Remote work and equipment. Where remote work is agreed, the employer must provide and maintain the technical equipment necessary for the performance of work (unless the parties agree otherwise).
Again, there is no text supporting any “reading entitlement,” but the framework is designed around knowledge work, remote structures, and contemporary working patterns all of which assume that part of work is keeping up.
The Interpretive Gap:
In any jurisdiction, when the law is silent on a specific activity, disputes will usually be argued around three anchors: the contract, the legal context, and public policy. In UAE mainland, DIFC, and ADGM, three arguments are particularly likely to arise in disputes about “reading on the clock”:
1. The Duty Performance argument
Where a role inherently requires staying continuously updated:
• Legal professionals needing to review new legislation and case law.
• Compliance and risk professionals tracking regulatory updates.
• Engineers, and technologists keeping up with new tech
It is open to an employee to argue that professional reading is a method by which they perform their contractual duties, not a side activity. The legal classification question becomes: Is this reading reasonably necessary to discharge the job description and KPIs? In other words, which comes first and who can define priorities?
In mainland courts, judges operating under Federal Labour Law may look at job titles, written job descriptions, past practice, and industry norms. If the employer has historically rewarded “research time,” or if the role is obviously knowledge heavy, the argument that reading is part of performance strengthens.
In DIFC/ADGM, courts and tribunals will approach this as a matter of contractual and factual construction: What does the contract say? How has the role actually been discharged? Are there internal policies referring to CPD, research time, or knowledge management? Common law judges will probably give significant weight to documented expectations and consistent practice.
2. The Employer Obligation argument (Federal Labour Article 13)
In the mainland context, an employee challenging disciplinary action for “reading during working hours” could point to Article 13 of Federal Labour Law and argue:
• The employer has a statutory duty to develop workers’ skills and provide training and empowerment tools.
• If the employer offers no real training program, no structured CPD, and no learning opportunities, yet disciplines employees for self directed professional reading, this can be framed as undermining the spirit and practical fulfilment of Article 13.
Will a court automatically convert that into a right to read any material at any time? I would say No. But in a dispute over wrongful dismissal or arbitrary disciplinary action, this context can influence the judge’s opinion and assessment of whether the employer acted reasonably and in good faith.
In DIFC and ADGM, there is no Article 13 equivalent; however, courts may still interpret extreme bans on professional development against the background of:
• Anti‑discrimination and good‑faith principles (particularly where reading is linked to maintaining professional competence, a license or professional standing).
3. The Policy Coherence argument
Even where the Reading Law is not directly enforceable against private employers, litigants and counsel may invoke it as contextual public policy:
• It demonstrates that the UAE legislature and executive view specialized reading as a productivity and development tool.
• It embeds the idea that reading belongs inside working time, at least in the public sector governance architecture.
In mainland courts, judges sometimes draw on broader policy when interpreting ambiguous statutory or contractual language. A lawyer might argue that a draconian prohibition on professional reading is inconsistent with the national policy direction reflected in the Reading Law, especially in government adjacent sectors.
In DIFC and ADGM, common law courts will be more cautious in treating such instruments as interpretive aids, but they can still form part of the narrative around reasonableness, good management practice, and the commercial context in which contracts operate.
How a Dispute Might Play Out: Mainland vs DIFC vs ADGM
To see how this could matter in practice, imagine this scenario:
A senior compliance officer is dismissed for “misuse of working time” after spending what may appear to be more than 90 minutes per week reading regulatory updates, industry enforcement actions, and technical guidance during office hours. Her performance metrics otherwise show solid delivery; there is no formal training program in place.
Mainland (Federal Labour Law, MOHRE, and Labor Court)
Pre‑court stage. The dispute would typically start with a complaint to the Ministry of Human Resources and Emiratisation (MOHRE), which often attempts conciliation before referring matters to the labour courts.
Legal arguments.
• The employer may argue: reading was unauthorised, not required by the role, and displaced productive time.
• The employee may argue: reading was directly linked to her compliance function, necessary to keep the company aligned with evolving regulations, and consistent with industry practice. She may invoke Article 13 (training/skill development duty) and, by analogy, the Reading Law’s policy stance.
• Judicial lens: Mainland courts tend to ask whether termination was arbitrary or without a legitimate reason, and whether procedures were followed. Where the reading can be tied clearly to compliance risk reduction, a judge may view the dismissal as disproportionate particularly if the employer cannot show any meaningful training or CPD structures.
Outcome is fact sensitive, but the legal environment gives the employee some narrative weight where reading is tightly role linked.
DIFC Courts / Arbitration Under DIFC Law
Jurisdiction and form. Disputes may go to the DIFC Courts or to arbitration if the contract so provides.
Contract‑first approach. The court will parse the employment contract, handbook, and policies:
• Is there any clause on CPD, research time, or professional updates?
• Are there clear prohibitions on non-task reading during work?
• What does performance documentation say about expectations?
Reasonableness and proportionality. Even in a contract centric system, DIFC judges can and do examine whether a dismissal was within the range of reasonable responses. If the reading clearly supported the compliance function, and there is no evidence it caused delivery failures, a court may be sceptical of a dismissal based solely on “being caught reading.”
The more sophisticated and explicit the employer’s policy framework, the more defensible its decisions become in DIFC.
ADGM Courts Under ADGM Employment Regulations
Common law logic, regulatory context. ADGM Courts, like DIFC’s, apply a common law style analysis. But they also sit in a jurisdiction deliberately positioned as a hub for sophisticated, regulated industries (financial services, asset management, fintech).
Risk and competence lens. In a compliance role, the argument that reading regulatory material is integral to the job is particularly strong. An ADGM court may be receptive to the idea that penalising such reading, absent demonstrable performance detriment, conflicts with the implicit expectations for regulated entities to stay updated.
Remote and hybrid work. Where the employment is remote or hybrid, and the employer has provided the tools for knowledge work, it becomes even harder to draw a bright line around “reading as not work” when that reading is domain specific.
Again, many turns on documentation, but the structural orientation of ADGM (towards sophisticated financial services) gives “reading as compliance work” a strong factual narrative.
Don’t Wait for a Test Case. Design the Rules
At the moment, there is no explicit, on point reported case that resolves this issue across UAE, DIFC, and ADGM in the way, say, overtime or gratuity has been litigated. Waiting for a perfect test case is not a governance strategy. The organisations that will look best at courts, and before regulators, and investors are those that anticipate the issue and design their internal architecture accordingly.
We recommend a few steps that can be done now to mitigate the risk of any similar conflict between the employer and their employees, not just for the Reading example but also for anything else that the law and the legislation might come silent about, especially that there are lots of industries with special factors and conditions that some problems and conditions are very much industry focused. Some of these steps – going back to the reading example as per this article – is to implement the following steps:
- Codify Professional Reading as a Structured Category of Work
• Define “professional reading” for your organisation (e.g., legislation, standards, technical documentation, reputable industry analysis directly linked to the role).
• Set indicative parameters (e.g., 30–60 minutes weekly, or per‑matter allocations for complex advisory work).
• Embed this in policies, performance frameworks, and, for key roles, in the employment contract itself.
• Define the reading resources that are approved and recommended by the employer or at least some guidance to narrow creativity.
This gives you something concrete to point to if a dispute arises and prevents the argument collapsing into “this manager likes reading, that one doesn’t.”
- Make Reading Outcome Based and Auditable
• Require a simple output: a short note, a risk alert, a policy tweak, a checklist update, or an internal knowledge base entry.
• Encourage team‑level sharing (e.g., “regulatory updates” segments in meetings).
• Mark in the KPIs writing to be published internally or externally by the staff as organization’s producer literature to make use of the professional reading time into more organization productivity rather than just professional development to the employee alone.
This has two legal benefits:
• It strengthens the classification of reading as duty performance, not personal time.
• It demonstrates to a court or regulator that you are turning reading into organisational value, not simply indulging employee preferences.
- Build Management Controls
• Allow managers to pause reading time during intense delivery windows (transactions, go lives, regulatory inspections) and to restore it after.
• Communicate that this is deliberate capacity management, not a de‑facto ban.
This shows that you are balancing productivity and development responsibly a stance that will play well in any of the three legal systems if your decisions are later scrutinised.
Rethinking “Work” in a Reading Economy
The UAE has already made a normative choice at the public policy level by enacting the Reading Law: specialized reading during working hours is a tool of national development. Federal Labour Law has made a separate, equally important choice: employers must invest in developing worker capabilities (Article 13). DIFC and ADGM have built regimes that assume knowledge intensive, global‑facing work.
What remains is for the private sector leaders to reconcile their internal concept of “work” with this external architecture. The challenge is to attend to such risks realistically and responsibly considering the of possible disputes between different cultures and their gaps as well as the gaps between generations of senior and junior employees shifting from a more “work hard” mentality into the “work smart” mentality to a “work life balance” culture.
If, in a dispute, your organisation appears to have punished precisely the sort of learning that the state encourages and the legal framework implicitly assumes, you will be on the back foot in mainland courts, in DIFC, and in ADGM.
The coming concern will be the use of Ai and the regulations around it and your responses to it. Are you going to encourage, limit, suspend or punish its use?! Do you want to leave this to chances or to regulate it early on?
The deeper question is not whether employees have a “right” to read or to learn about the use of Ai or anything else. It is whether your governance model still treats visible busyness as the gold standard of productivity in an economy where the scarcest asset is not time on the clock, but judgment informed by up to date knowledge. In that world, reading on the clock or learning during working hours or exploring new technologies is not a favour you grant. It is a form of work you should be prepared legally and strategically to defend.
Everyone should have the right to learn about work during working hours. To read and develop work skills on the clock!
If your organization does not have this already in internal policy. You can reach out and we are happy to help you seal this gap.
References:
United Arab Emirates Legislations | Federal Decree-Law Regarding Reading
United Arab Emirates Legislations | Federal Decree by Law Concerning Regulating Labour Relations
Employment Law DIFC Law No. 2 of 2019
Microsoft Word - ADGM Employment Regulations 2019 (Consolidated June 2024 - Inc. Whistleblower Protection Regime)
