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On 20 May 2025, Sheikh Maktoum bin Mohammed bin Rashid Al Maktoum – First Deputy Ruler of Dubai, Deputy Prime Minister, and Minister of Finance of the UAE – issued Decision No. 2 of 2025 in his capacity as Chairman of the Financial Audit Authority (FAA).
The Decision establishes formal, enforceable protections for public sector employees in Dubai who report financial or administrative violations, or who cooperate with the FAA during the course of its investigations. It represents the most recent addition to the UAE’s developing whistleblower landscape and forms a key part of Dubai’s broader commitment to financial integrity and public sector accountability.
Background and Legal Basis
The Decision is issued under Law No. 4 of 2018, which established the Financial Audit Authority and sets out the entities subject to its oversight. The FAA is the independent body responsible for auditing and overseeing the financial and administrative performance of Dubai government entities, and it has broad powers to investigate violations within those entities.
The Decision sits within the wider context of the UAE’s evolving whistleblowing landscape. While the DIFC introduced its whistleblowing regime in 2022 and the ADGM followed with its Regulations in 2024, the onshore UAE – including Dubai’s public sector – had until this point lacked a dedicated, formal framework for protecting those who report wrongdoing within government entities. Decision No. 2 of 2025 addresses that gap, at least within the FAA’s jurisdiction.
Scope: Who Does It Apply To?
The Decision applies to employees of entities defined as “Subject Entities” – that is, entities subject to the FAA’s oversight and control under Law No. 4 of 2018. These include:
- Dubai Government Departments
- public agencies and corporations
- government authorities and councils, including those supervising Special Development Zones and free zones such as the Dubai International Financial Centre
- any other entities affiliated to the Dubai Government
Protection applies to employees whose reports or statements regarding violations are accepted by the FAA in accordance with Law No. 4 of 2018. It also extends to employees requested to provide testimony during administrative investigations related to such violations.
What the Decision Covers
The Decision enables employees to report financial and administrative violations – as defined under the FAA Law – and to provide testimony during FAA investigations, without being subject to any form of pressure or retaliation. Its stated aims are to:
- safeguard public funds and uphold the financial and economic integrity of the Emirate
- support the effective detection and disclosure of financial and administrative violations
- protect the employment status of employees who submit reports or provide testimony
- establish clear procedures and conditions for requesting protection
- create the legal and procedural frameworks necessary to encourage employees to report violations
Protections Offered
The Decision provides two categories of protection: employment protection and confidentiality protection.
On employment protection, the Decision safeguards the position of employees who report violations or provide testimony. Where an employee believes they have suffered adverse employment action as a result of their disclosure or testimony, they retain the right to file a grievance against the relevant entity under applicable legislation – even in cases where the FAA has decided not to implement formal protection measures under the Decision.
On confidentiality, the Decision is unequivocal: all reports submitted to the FAA are treated with strict confidentiality. Employees of the FAA are expressly prohibited from disclosing, sharing, or revealing any data or information contained in reports submitted to the authority under any circumstances. Investigators conducting administrative investigations are required both to possess appropriate expertise relevant to the nature of the case, and to fully uphold the principle of confidentiality – ensuring whistleblowers are not exposed to harm as a result of their disclosure.
Requesting Protection
The Decision defines the procedures and conditions under which an employee may formally request protection. The Director General of the FAA is responsible for issuing the implementing decisions required to give effect to these procedures. Where the FAA accepts a report or testimony, appropriate protection measures are determined based on the nature and assessed risk of each case.
The Decision in the Context of UAE Whistleblowing Law
As noted in our pages covering the DIFC and ADGM regimes, the UAE still lacks a single, comprehensive federal whistleblowing law. The developing landscape instead consists of a series of jurisdiction- and sector-specific frameworks, each with its own scope and requirements. Decision No. 2 of 2025 is an important addition to that landscape – it is notable as the first dedicated whistleblower protection framework for Dubai’s broader public sector, extending beyond the DIFC’s freezone boundary to the entities that form the core of Dubai’s government architecture.
Other relevant developments in the onshore UAE space include the UAE Central Bank’s whistleblowing policy for employees reporting concerns anonymously, and the UAE Ministry of Finance’s Wajib platform – a mobile application allowing individuals to confidentially report financial or administrative misconduct within UAE government entities. Together, these measures indicate a consistent direction of travel towards greater transparency and accountability at the federal and emirate level, even in the absence of a unified legislative framework.
Limitations and Considerations
The Decision is specific to the public sector entities within the FAA’s jurisdiction. It does not extend protections to employees of private sector organisations operating in Dubai, nor does it impose compliance obligations on private employers. For private sector organisations, the most directly relevant UAE frameworks remain the DIFC regime (for DFSA-regulated entities) and the ADGM Regulations (for ADGM-registered entities).
It is also worth noting that, as with other elements of the UAE’s onshore legal environment, the Decision exists alongside the confidentiality obligations imposed by the UAE Labour Law (Federal Decree Law No. 33 of 2021) and the UAE Penal Code (Federal Decree Law No. 31 of 2021). Navigating these overlapping frameworks requires careful consideration, and organisations operating across both freezone and onshore environments should seek appropriate legal advice.
Conclusion
Decision No. 2 of 2025 is a clear signal that Dubai is committed to extending whistleblower protections across its public sector – not just within its financial freezones. For government entities, agencies, and corporations under the FAA’s oversight, the message is straightforward: employees who report financial and administrative violations will be protected, and the FAA takes seriously its obligation to maintain confidentiality and prevent retaliation. As the UAE continues its reform programme and prepares for FATF evaluation in June 2026, measures such as this one are likely to be viewed as evidence of meaningful, institutional progress.
Our Recommendation
The Decision creates formal protection for employees who report to the FAA – but it does not, in itself, create an internal reporting channel within the entities it covers. In practice, employees of Dubai government entities and public corporations will be more likely to use a safe, accessible reporting channel within their organisation before escalating to an external regulator. An independently operated whistleblowing service provides exactly that – a trusted, confidential route that sits between the employee and the formal enforcement process, allowing concerns to be surfaced, assessed, and addressed at an early stage. For organisations within the FAA’s jurisdiction that are considering how to build reporting culture alongside the protections the Decision provides, Safecall offers a proven, internationally recognised solution.
Comment Safecall peut vous aider
Safecall provides anonymous reporting channels – including dedicated telephone hotlines and secure online portals – that allow employees to raise concerns confidentially, 24 hours a day, 7 days a week, 365 days a year, across more than 150 countries and in over 175 languages and dialects, including Arabic. Our call handlers have 25 or more years of interview experience each, and our case management platform provides a comprehensive, auditable record of all disclosures and subsequent actions.
All data is held securely in the UK and our systems are fully GDPR compliant – providing Dubai public sector entities with the assurance that sensitive disclosure data is handled to the highest international standards. Safecall supports organisations in building not just the infrastructure for reporting, but the culture that makes it effective.
Références
[1] Dubai Financial Audit Authority, Resolution No. 2 of 2025 Concerning Employment Protection of Public Sector Whistleblowers (official text): https://dlp.dubai.gov.ae/Legislation%20Reference/2025/Resolution%20No.%20(2)%20of%202025%20Concerning%20Employment%20Protection%20of%20Public.pdf
[2] Gulf News, Dubai: New Decision to Protect Whistleblowers Announced (May 2025): https://gulfnews.com/uae/dubai-new-decision-to-protect-whistleblowers-announced-1.500134022
[3] Arabian Business, Dubai Introduces New Law to Protect Financial Whistleblowers (May 2025): https://www.arabianbusiness.com/industries/banking-finance/dubai-introduces-new-law-to-protect-financial-whistleblowers
[4] Mondaq / Habib Al Mulla, Dubai’s Fiscal Integrity Is Strengthened by New Whistleblowing Legislation (June 2025): https://habibalmulla.com/articles/dubais-fiscal-integrity-is-strengthened-by-new-whistleblowing-legislation/
[5] Fast Company Middle East, New Dubai Rules Protect Financial Whistleblowers and Reinforce Transparency (May 2025): https://fastcompanyme.com/news/new-dubai-rules-protect-financial-whistleblowers-and-reinforce-transparency/
[6] Herbert Smith Freehills Kramer, Updates to UAE Whistleblowing Protections (October 2025): https://www.hsfkramer.com/notes/middle-east/2025-posts/updates-to-uae-whistleblowing-protections
[7] Dubai Law No. 4 of 2018 on the Establishment of the Financial Audit Authority
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