As discussed in a previous bulletin (see here), the Health Insurance Law for the Emirate of Dubai (No. 11 of 2013) (Health Insurance Law) was introduced in 2014 and will be implemented in phases up until June 2016.

The end of July 2015 marked the implementation date for employers with 100 to 999 employees in Dubai. This second phase is likely to affect many employers in the Emirate. The final implementation date, for employers with fewer than 100 employees in Dubai, will be June 2016.

As a reminder, the Health Insurance Law requires employers to provide all employees with a minimum level of health insurance cover with a participating insurer. In contrast to the position in Abu Dhabi, employers in Dubai are not required to provide health insurance to an employee's dependants (where they do not sponsor them).

In the event that valid health insurance cover is not in place, employers will be liable to meet the full cost of any healthcare services provided to its employees. Financial penalties may also be imposed on employers who do not comply with their obligations under the Health Insurance Law.

Many employers already provide some form of health insurance cover to employees; however, employers affected by the recent implementation date should check that any existing health insurance scheme provides the minimum level of cover required under the Health Insurance Law and is arranged through one of the participating insurers.