Abu Dhabi Court of Cassation (General Assembly), Request No. 5 of 2025 (Labour), decision of 18 December 2025
Federal Decree-Law No. 9 of 2024 replaced Article 54(9) of the Labour Law: claims are now barred two years after the employment relationship ends, instead of one year after each right fell due. Under Articles 6 and 7 of the Civil Transactions Law, the new period governs every limitation period not yet complete when it came into force. But for the time before the amendment, the start date remains the one fixed by the old text, namely the date each right fell due, not the end of employment.
The Labour Chamber asked the General Assembly to settle how the 2024 amendment to the limitation rule for employment claims applies to rights that arose before it. Article 54(9) of Federal Decree-Law No. 33 of 2021 on the Regulation of Labour Relations originally provided that no claim for a right under the decree-law would be heard after one year from the date the right fell due. Article 1 of Federal Decree-Law No. 9 of 2024 replaced that text: claims are not heard after two years from the end of the employment relationship.
The General Assembly applied Articles 6 and 7 of the Civil Transactions Law on the temporal effect of limitation rules. Article 6 provides that new provisions on limitation apply from their entry into force to every limitation period not yet complete, but that the old provisions govern the start, suspension and interruption of limitation for the period before the new provisions took effect. Article 7 deals with a new period that is shorter than the old one. Reading these together, the two-year period introduced in 2024 applies to every claim whose limitation period had not run out under the old Article 54(9). For the period before the amendment, however, the start date of limitation remains the date on which the right fell due, as the old text provided, and not the end of the employment relationship, which is the start date under the new text.
The General Assembly adopted that principle as the binding rule for the Abu Dhabi courts.
Employers and employees with claims spanning the 2024 amendment (unpaid wages, allowances or other rights that fell due during employment) cannot assume that every claim runs from the termination date. For rights that fell due before the amendment, time ran from their due date, with the new two-year length applying if the old one-year period had not yet expired. The decision fixes how Abu Dhabi courts compute these periods.
| Article 54(9) of Federal Decree-Law No. 33 of 2021 on the Regulation of Labour Relations, before and after its amendment — text of article 54 |
| Article 1 of Federal Decree-Law No. 9 of 2024 amending certain provisions of Federal Decree-Law No. 33 of 2021 |
| Articles 6 and 7 of Federal Law No. 5 of 1985 (Civil Transactions Law) — text of articles 6, 7 Decided under this law; it has been replaced by Civil Transactions Law 2025. |
| Article 9 of Abu Dhabi Law No. 6 of 2024 on the Abu Dhabi Judicial Department |
“من تاريخ الاستحقاق، باعتباره التاريخ الذي كان يحدده النص السابق، وليس من تاريخ انتهاء العلاقة”Short quotation from the judgment as published by the court. The full judgment is on the court’s official service.
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