Following the publication of Resolution No.6 of 2017, employers or sponsors of dependants and domestic workers have been given until 31 March 2017 to comply with Dubai Law No. 11 of 2013 (the Dubai Health Insurance Law). Failure to comply will result in severe visa sanctions and fines.

Further extension of the grace period

When it was introduced, the Dubai Health Insurance Law provided that all employers sponsoring employees for work purposes in the Emirate of Dubai and all sponsors of individuals (e.g. a husband sponsoring a wife and children) must be compliant with its provisions by 30 June 2016. Subsequently, a six month grace period was granted until 31 December 2016 as part of the supportive rather than punitive approach to ensuring compliance. However, 2% of employers or sponsors are yet to provide adequate health insurance for their employees or dependants. Therefore, the decision has been taken to extend the initial grace period until 31 March 2017. This extension was set out in Executive Council Resolution No. 6 of 2017 (the 'Resolution'), which was published in early March 2017.

Compulsory health insurance for visitors

The Resolution also provides that both employers or sponsors will be obliged to provide adequate health insurance in accordance with the Dubai Health Insurance Law to all of their visitors by 31 December 2017.

Enforcement

The Resolution reiterates that, following the expiry of the grace period, employers or sponsors who remain non-compliant will face severe visa sanctions issuance complications as well as financial penalties in line with Executive Council Resolution No. 7 of 2016. Fines will be AED 500 per month for every individual who remains without insurance, with the risk of additional fines from the General Directorate of Residency and Foreigners Affairs Dubai (GDRFA).

Tackling the issue of accessibility

Prior to its publication, a number of media reports suggested that the Resolution would require all health insurance providers to extend their medical provider networks to include Sharjah and the Northern Emirates. This would have helped address the accessibility issues which have plagued Dubai's compulsory health insurance scheme, enabling those individuals employed in Dubai but living elsewhere in the UAE (e.g. Sharjah) to access the services covered under their health insurance policy through medical providers in other Emirates, something which is presently not possible due to the limitations of the medical provider network. However, the Resolution contained no such requirement and the issue of accessibility remains a primary concern for many. Although, it may not be long before health insurance providers are required to extend their provider networks as we understand that the DHA have recently circulated an internal memo to all health insurance providers setting out that they should begin to address the issue.

The news that the DHA are actively taking steps to extend the medical provider networks is reinforced by the publication of a policy directive issued by the DHA on 12 February 2017. The directive provided that; all health insurance providers must immediately include Hatta hospital in their provider networks under direct billing for elective and emergency treatments. This was a direct response to a note on accessibility which highlighted the fact that a small population in Hatta needed to travel 50km to the nearest hospital within the conventional medical provider networks.

Conclusion

In light of the supportive approach taken to ensuring compliance with the Dubai Health Insurance Law, those who remain non-compliant following the expiry of the extended grace period can expect the applicable fines and visa sanctions to be strictly enforced.

In relation to the extension of medical provider networks, whilst the recent attention from the DHA regarding this matter demonstrate that the issue of accessibility is high on the agenda, it also reinforces the notion that perhaps soon employers and sponsors in Sharjah and the Northern Emirates may soon be obliged to provide compulsory health insurance under their own respective laws.