The Middle East conflict is ongoing and has moved from headline risk to operational reality for companies with employees on the ground. The work is urgent: duty of care obligations, payroll continuity, employment law complexity and the question of whether their current workforce structure can hold.
This playbook covers what to prioritise and how to act.
What Does ‘Duty of Care’ Mean for Employers with Staff in the Middle East?
Duty of care is both a legal obligation and a practical responsibility. Under UK law (Health and Safety at Work Act 1974) and US law (OSHA 1970), employers must take reasonable steps to protect the health, safety and welfare of employees, including those working internationally. When geopolitical risk escalates, ‘reasonable steps’ means actively assessing and responding to conditions on the ground, not waiting for a formal government travel advisory.
In practice, this covers four immediate areas:
Employee Safety and Communications
Establish a clear protocol for reaching every employee in affected locations. Know where they are, whether they have dependents locally and what their preferred evacuation route would be if required.
Mental Health and Psychological Support
Ongoing conflict creates sustained stress for employees in the region and for colleagues with family ties there. Access to employee assistance programmes is a legitimate duty of care issue.
Travel Advisories and Visa Status
Government travel advisories affect insurance cover, duty of care exposure and in some cases employees’ legal right to remain in-country. Monitor these in real time.
Evacuation Planning
Every company with employees in conflict-adjacent zones should know who is responsible for triggering an evacuation and what the process is.
How Do You Maintain Payroll Continuity When Geopolitical Conditions Deteriorate?
This is the question global payroll/HR directors and CFOs are already asking. The answers depend on how your workforce is structured in the region.
If you are running payroll through a local entity, banking disruptions are your primary risk. Currency controls may be imposed in conflict-affected economies and the window between a deteriorating situation and a banking freeze can be short. Payroll contingency planning should include an identified alternative payment mechanism, clarity on whether employees’ local bank accounts can receive international transfers and pre-authorized backup payroll cycles.
If you are using an Employer of Record (EOR), your provider absorbs a significant amount of this risk operationally but you still need to understand their continuity protocols and ensure your contract specifies what happens to payroll obligations if they cannot make in-country payments.
What Happens to Your HR and Payroll Systems if the Cloud Goes Down?
In March 2026, Iranian drone strikes directly hit two AWS data centre facilities in the UAE and one in Bahrain. The strikes took down multiple availability zones simultaneously. Banking, payments, enterprise and consumer services experienced prolonged outages, with AWS warning that recovery would be extended.
For companies with HR, payroll and HRIS platforms hosted in or routed through these regions, this is now a concrete operational risk. The implications are:
Payroll Runs Can Fail
If your payroll platform depends on a cloud region that is offline, scheduled payroll cycles cannot be processed. Companies without a manual backup process have no fallback.
Employee Data May Be Inaccessible
HRIS platforms, onboarding and offboarding workflows and compliance documentation all depend on cloud infrastructure. A regional outage can leave HR teams without access to the systems they need.
Data Localization Rules Create a Double Bind
UAE Federal data protection law requires that certain employee and business data be stored locally for some sectors (e.g. healthcare, finance). If your disaster recovery backup must also stay in-region to comply and that region is physically compromised, your data resilience is structurally limited. Seek legal advice on whether backup copies in a secondary region satisfy your compliance obligations.
Insurance May Not Protect You
Standard business interruption insurance policies typically exclude acts of war. Cloud providers have invoked force majeure provisions for state-level attacks, limiting their SLA liability. Companies that have never reviewed their war risk coverage should do so now.
Identify which HR and payroll processes have no manual fallback and build one before you need it. Review your cloud architecture for regional concentration risk. Ask your payroll and HR platform providers directly what their documented continuity plan is if a regional facility is taken offline.
What Are Your Legal Obligations before Restructuring or Exiting a Middle East Workforce?
This is where companies most frequently underestimate their exposure. Employment law in the Middle East is not uniform, and the obligations attached to workforce restructuring vary significantly by market.
If You Have a Local Entity
You cannot simply close operations and stop paying employees. Most GCC jurisdictions require formal entity dissolution processes, regulatory notification periods and in many cases government approval for mass redundancies. End-of-service gratuity (EOSG) obligations are legally mandated and must be settled before exit.
If You Are Using an EOR
Your exit is governed by both your EOR contract and local labour law minimum entitlements. Understand your liability exposure before any restructuring decision.
Non-Resident Payroll (NRP) as a Bridge
Transitioning employees to NRP (available in some countries only) arrangements can reduce in-country exposure while structural decisions are made, provided local tax residency and contract obligations are handled correctly.
Emergency Checklist: Six Priorities for HR and Finance Leaders
People Safety
- Up-to-date register of all employees and their locations in affected areas
- Employee emergency contacts on file and reachable
- Named individual responsible for employee welfare in each country
- Government travel advisories reviewed in the last 30 days
Payroll and Benefits
- Payroll provider’s documented business continuity plan reviewed
- Alternative payment mechanism identified if local banking is disrupted
- End-of-service gratuity (EOSG) balances are calculated and documented
- Benefits validity confirmed if employees temporarily relocate
Legal and Compliance
- Minimum notice periods and termination obligations confirmed under local law
- Force majeure provisions in employment contracts reviewed
- Legal counsel briefed on current workforce exposure
Entity or EOR Decisions
- Legal process for reducing headcount or winding down operations confirmed
- EOR provider crisis continuity and exit protocols reviewed
Communications
- Employees in the region know who to contact in an emergency
- Leadership has communicated the company’s position and support clearly
IT and Cloud Systems Continuity
- Cloud and payroll platform regional dependencies identified. Know which systems route through Middle East cloud regions.
- Manual backup payroll process documented and tested.
- Data localisation obligations reviewed against disaster recovery architecture – confirm whether backups in a secondary region are compliant.
- Business interruption and war risk insurance coverage reviewed (standard policies typically exclude acts of war).
- Cloud and payroll provider force majeure and SLA provisions reviewed. Understand your recourse if infrastructure is physically compromised.
Restructuring or Relocating: Understanding Your Options
Not every escalation warrants an exit. But having assessed the situation, some companies will conclude that reducing in-country exposure is appropriate.
Stay and Monitor
For some GCC markets (Qatar, Saudi Arabia, UAE), the risk calculus may be very different from active conflict zones. Operational continuity could be the right call in the immediate term, with enhanced monitoring and contingency planning.
Relocate Regionally
Greece and several other European countries have absorbed significant numbers from the impacted countries. Transitioning employees to a regional hub preserves talent while reducing direct exposure.
EOR as a Bridge
Transitioning employees to an EOR arrangement in a neighbouring jurisdiction can provide operational continuity while structural decisions are made.
Full Restructuring
If exit is unavoidable, the sequence matters. Payroll obligations must be honoured, EOSG calculated and paid and entity dissolution managed in compliance with local regulatory requirements.
Frequently Asked Questions
What are my legal obligations if conflict escalates near where my employees are based?
You have a duty of care under most national employment laws to take reasonable steps to protect employee safety, including assessing risks, communicating clearly, providing support and where necessary, facilitating relocation or evacuation.
Can I stop paying employees if I cannot operate in a country due to conflict?
Generally, no. Payroll obligations do not cease because of operational disruption. Force majeure clauses in employment contracts are narrowly construed in most jurisdictions. Seek legal advice before making any unilateral decision to suspend payroll.
How long does it take to legally exit a local entity in a Middle East market?
This varies significantly by country. UAE free zone dissolution can take weeks; mainland entity dissolution typically takes months and requires regulatory approvals. Saudi Arabia has a formal liquidation process requiring multiple government approvals. Always engage local legal counsel before initiating an exit.
What should we do if our HR or payroll platform goes offline during a crisis?
Identify in advance which payroll and HR processes have no manual fallback and build one before you need it, for example, a basic emergency payroll process using exported data. Ask your platform providers for their documented continuity plans for regional cloud outages, including those caused by physical infrastructure damage. Review whether your data localisation obligations prevent you from holding backup copies in a secondary region and take legal advice on how to resolve that conflict.
If you have employees in the Middle East, preparation matters. Schedule a consultation with our team. We’ll help you secure payroll, meet your duty of care obligations and keep your operations running when conditions change.
