Business and Human Rights in Qatar: The Legal Framework and What Companies Are Expected to Do

Compliance with human-rights standards can no longer be characterised as a matter of voluntary policy for companies operating in the State of Qatar, because the principal obligations that were once described as international expectations are now embodied in binding domestic legislation and are enforced through inspection, administrative sanction and, in certain cases, criminal liability.

The legislative foundation remains Law No. 14 of 2004 promulgating the Labour Law, as subsequently amended, which governs contracts of employment, working hours, leave, occupational health and safety, and the termination of the employment relationship. That foundation has been substantially reinforced over the past decade. Law No. 1 of 2015, amending certain provisions of the Labour Law, introduced the Wage Protection System, under which wages must be transferred to the worker's account with a financial institution within the State within the periods prescribed by the Law and its implementing decisions, and non-compliance exposes the employer to administrative penalties, including the suspension of transactions with the competent ministry.

A further series of reforms addressed the conditions under which workers may leave the State and change employer. Law No. 13 of 2018, amending Law No. 21 of 2015 regulating the entry, exit and residence of expatriates, removed the requirement that workers subject to the Labour Law obtain an exit permit from the employer, and Law No. 19 of 2020 subsequently removed the requirement of a no-objection certificate as a condition of moving to a new employer. In parallel, Law No. 17 of 2020 determining the national minimum wage for workers and domestic workers established a non-discriminatory minimum wage of QAR 1,000 per month, together with allowances of not less than QAR 300 for food and QAR 500 for accommodation where these are not provided in kind by the employer, with effect from 20 March 2021. Domestic workers, who fall outside the general scope of the Labour Law, are governed by Law No. 15 of 2017 on domestic workers, while the most serious forms of exploitation are addressed by Law No. 15 of 2011 on combating trafficking in human beings, which carries substantial custodial penalties and fines.

For the majority of commercial enterprises, practical exposure arises in three distinct areas. The first is recruitment and worker welfare, which requires, among other matters, that the employment contract be documented and authenticated in accordance with the Labour Law, that the worker be charged no recruitment fees, and that wages be paid on time through the Wage Protection System. The second is accommodation and working conditions, including compliance with the standards prescribed for workers' housing and with the ministerial decisions restricting outdoor work during the summer months. The third is the supply chain, in which a company may be held answerable, whether contractually, reputationally or before a public authority, for the practices of its subcontractors, manpower suppliers and recruitment agents.

International standards operate alongside these domestic requirements rather than in substitution for them. The United Nations Guiding Principles on Business and Human Rights, endorsed by the Human Rights Council in 2011, articulate the corporate responsibility to respect human rights through a policy commitment, human-rights due diligence and access to remedy, and Qatar's continuing technical cooperation with the International Labour Organization has aligned much of the domestic framework with those principles. Companies that supply goods or services into the European market should also note Directive (EU) 2024/1760 on corporate sustainability due diligence, the effect of which is that a contracting counterparty established in the European Union will increasingly require its suppliers in the State to evidence their own policies, grievance channels and audit records.

A defensible compliance position is generally built upon four elements, each of which should be documented and capable of being produced to an inspector, a financier or a counterparty on request. There should be a human-rights policy approved at board level and communicated throughout the organisation; a risk assessment that identifies the points at which the business, its subsidiaries and its suppliers come into contact with workers in vulnerable positions; operational controls that translate the policy into practice, including contract review, wage monitoring, accommodation inspection and supplier screening; and a grievance mechanism that is accessible to workers in a language they understand, together with records demonstrating that complaints received have in fact been investigated and resolved.

Undertakings that treat these requirements as a documentary formality tend to discover the deficiency at the least convenient moment, whether in the course of a labour inspection, during the disclosure phase of a dispute, or upon the evaluation of a tender in which compliance evidence carries determinative weight. Where the framework is established at an early stage, and maintained as a matter of routine governance rather than reconstructed under pressure, the cost of compliance is materially lower and the legal position of the company is considerably stronger.