Nisna K Muhammed

In a progressive move underscoring its commitment to fiscal discipline and public sector accountability, the Emirate of Dubai has introduced a significant legal reform aimed at protecting whistleblowers employed in public entities. Through Decision No. 2 of 2025, issued under the authority of the Financial Audit Authority (FAA), Dubai lays down a structured and enforceable regime to insulate employees who report internal financial or administrative misconduct from professional retaliation or personal risk.

This decision, grounded in the powers granted under Law No. 4 of 2018 (as amended), serves a dual purpose: protecting those who act in good faith to report violations, and enhancing the integrity of governance within entities under FAA oversight. By empowering employees to disclose irregularities and provide testimonies without fear of reprisal, the Emirate not only strengthens internal compliance mechanisms but also signals a zero-tolerance approach towards misuse of public resources.

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At its core, the decision affirms the legal right of public sector employees to engage with the FAA confidentially, including by submitting reports or participating in investigations. Importantly, the law places a positive obligation on investigative officers to maintain strict confidentiality and ensure that the whistleblower’s identity and the information shared remain secure. Any breach of this duty carries serious implications for the individuals responsible.

What sets this regulatory development apart is its clear articulation of procedural safeguards. Employees seeking protection must meet defined eligibility criteria, and the FAA retains the discretion to determine whether the reported information meets the legal threshold for protection. Furthermore, the decision shields employment status, meaning that retaliatory actions, such as termination, demotion, or adverse performance evaluations against whistleblowers, are expressly prohibited.

Additionally, investigators assigned to review such disclosures must possess subject-matter expertise and demonstrate a high degree of impartiality and discretion. This ensures that whistleblower complaints are not only protected but also professionally assessed and acted upon.

The decision is not a symbolic gesture, but it carries immediate legal effect and will be published in the Official Gazette, cementing its enforceability.

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From a legal perspective, this move reflects an increasing regional trend towards institutionalising whistleblower protections, bringing Dubai more closely in line with international standards on anti-corruption and public sector transparency. It also addresses a historical concern among public employees, the fear of reprisal for raising red flags, which often silenced potential disclosures.

Going forward, it will be critical to monitor how the FAA operationalizes this framework, particularly in terms of response timelines, the criteria for granting protective status, and the effectiveness of confidentiality protocols. Nonetheless, the foundation has been laid. By converting moral encouragement into a legal guarantee, Dubai sends a resounding message that safeguarding public interest begins with protecting those who dare to speak out.