Bahrain Labour Law Insights: Winter 2025 Compliance Update

Bahrain continues to refine its employment and workplace compliance framework, and this periodic update highlights the most recent, material developments relevant to employers operating in the Kingdom.  In this edition, we cover: (i) new first aid and emergency medical care requirements introduced by Resolution No. 16 of 2025; (ii) proposed tightening of redundancy dismissal procedures currently under parliamentary consideration; (iii) recent Court of Cassation guidance on pension contributions and the enforceability of arbitration clauses in employment contracts; and (iv) the ongoing implementation and roll out of the Wage Protection System (WPS), including timing, registration, and monitoring obligations.

These changes have immediate and practical implications for HR, legal, and compliance teams across sectors.  Employers should assess their policies, payroll workflows, and dispute-resolution provisions to ensure continued alignment with Bahrain’s evolving regulatory landscape and to mitigate potential enforcement risks.

First Aid Reforms in the Workplace

The Health Ministry’s Resolution No 16 of 2025 elevated workplace first aid standards, by requiring employers to:

• establish appropriate first aid arrangements proportionate to workforce size and risk profile;
• appoint certified first-aid personnel at a ratio of at least one trained employee per 20 employees;
• designate a responsible person to maintain supplies and liaise with authorities;
• provide fully compliant first aid kits; and
• adopt a comprehensive emergency response plan detailing exit routes and nearby healthcare facilities.

These requirements should be integrated into broader health and safety frameworks, including emergency response planning and staff training calendars.

Non-compliance may attract criminal penalties, including up to three months’ imprisonment and/or fines between BHD 300 – BHD 3,000. Accordingly, employers should take all relevant steps to ensure compliance with the Resolution and consider updating their internal policies and ensuring their health and safety practices in the workplace are compliant with the provisions of this Resolution.

Parliamentary Bill to Impose Stricter Rules on Redundancy Terminations

The Bahrain Parliament has recently passed a bill to extend the advance notification period to the Ministry of Labour from 30 to 60 days for economic dismissals and tie reduced compensation to documentary proof of genuine financial hardship. Employers that do not meet the proposed conditions may be liable to pay the full termination compensation under Article 111 of the Labour Law.

If the proposed changes are implemented, employers will be required to plan further ahead and ensure financial documentation supporting the necessity of redundancies is properly maintained and readily available.

Employers contemplating restructuring should consider compiling contemporaneous financial documentation now to demonstrate genuine economic necessity and ensure readiness should the amendments be enacted.

Recent Cassation Court Judgments

Recently, the Court of Cassation has issued judgments which offer some clarity on pension contribution obligations and the adjudication of employment disputes.

One judgment provided that employees are automatically insured by operation of law, regardless of whether they have been formally registered. Employers are therefore obligated to register employees promptly and deduct contributions on time. If an employer fails to deduct the employee’s contribution at payroll but subsequently pays it as required, the employer retains a right of recourse against the employee as a personal debt subject to a 15 year limitation period, avoiding unjust enrichment of the employee.

In another judgment, the Cassation Court provided that arbitration clauses are generally valid but will not be enforced where they prejudice statutory labour rights or implicate public-order considerations. Employment disputes, especially in modest claims, may proceed before the Labour Courts notwithstanding any contractual arbitration provisions.

Employers are advised to review employment contracts for arbitration provisions and consider tiered dispute resolution clauses that preserve statutory labour rights and avoid public-order issues

The New Wage Protection System
The WPS requires all employers to pay wages through licensed banks or payment service providers regulated by the Central Bank of Bahrain, with electronic monitoring of payroll as legal proof of payment. Employers must register in the Expatriate Management System (EMS), appoint a Wage Responsible Person with a smart Bahrain or GCC ID, set up and verify sender accounts via BENEFIT integration, and maintain complete salary profiles (including bank/wallet details and fixed/variable components). Bank onboarding continues in late 2025, and full enforcement starts in February 2026.

If employers are non-compliant by the relevant enforcement date, this will affect work permit issuance, trigger enforcement action and be treated as a violation of workers’ rights. Therefore, it is important that employers’ payroll workflows and file formats are aligned with WPS specifications ahead of the February 2026 enforcement date.

How Can We Help

Al-Tamimi’s on-the-ground Employment team in Bahrain regularly advises on all aspects of employment law in the public and private sectors, with expertise spanning from corporate support to litigation assistance. Their clients include multinational and government-owned entities, local companies and other law firms both locally, regionally and internationally. Our team is well-positioned to assist employers in understanding and implementing the latest legal and regulatory developments.