Global Slavery Index
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Disempowered, dehumanised, deported: Life under the kafala system

Beirut, Lebanon, September 2020. A former domestic worker from Sierra Leone uses her mobile phone while waiting to be repatriated. Multiple crises in Lebanon, have left a significant number of migrant workers in a humanitarian crisis and at increased risk of exploitation. Photo Credit: Aline Deschamps. Getty Images.

The promise of decent wages and steady employment attracts many migrants from countries throughout Africa and Asia to the Arab States. However, the reality often differs substantially once in country and under the kafala (sponsorship) system, a restrictive work permit system that ties migrant workers to their employer.1 By placing control over entry, exit, work, and residence in the hands of employers, the system leaves migrant workers vulnerable to exploitation and modern slavery,2 particularly in domestic work,3 construction,4 hospitality,5 and sectors where seasonal work is common.6 Variations of the kafala system exist in Jordan, Lebanon, and the GCC countries — Bahrain, Kuwait, Oman, Qatar,7 Saudi Arabia, and the UAE. Collectively, the Arab States region is home to more than 24 million migrant workers,8 comprising over 40 per cent of the labour force — the highest share of any region.9

“I wish I knew that going to work there, I didn’t have to pay any money to process any documents because my employer was to do everything. And if I fully knew that I was supposed to work as a housemaid, be locked up and denied free movement or be a prisoner, I shouldn’t have gone there. I knew nobody working in Lebanon. I signed a contract when I got to Lebanon but did not understand the terms of the contract. I didn’t know who the employer was.” 34-year-old Cameroonian female survivor of domestic servitude

What is the kafala system?

The kafala system is a set of laws and policies that delegate responsibility for migrant workers to employers, including control over their ability to enter, reside, work, and, in some cases, exit the host country.10 Workers typically cannot leave or change jobs prior to completion of their contract, before a certain time period, or without permission from their employer. Those who do leave may run the risk of arrest and deportation for the crime of absconding.11 The system also limits the ability of exploited workers to access justice. In practice, a worker who leaves their job not only risks losing their means of earning an income, but also risks becoming an illegal migrant. This threatens their ability to pursue legal action against their employer and recover any income they are owed. If deported, workers may also face bans on returning to the country to work.12 Legal redress is made even more difficult by prolonged, expensive court processes, limited legal assistance, and the absence of interpreters.13 Some employers reportedly create additional barriers to justice; for example, by levelling false allegations of theft against migrant workers in retaliation for leaving14 or filing false absconding reports with law enforcement to avoid paying wages owed.15 Migrant workers can be deported even where no evidence exists to support the accusations, while employers enjoy impunity.16

Modern slavery experiences in Lebanon and Kuwait

Female migrant domestic workers face specific challenges under the kafala system. Globally, patriarchal norms that devalue domestic labour as “women’s work” confine women within the household and make them less visible to authorities.27 In high-income countries, domestic work is typically performed by low-paid female migrants who fill gaps in care driven by the curtailing of social welfare. These workers are subject to constant surveillance and face higher risks of gender-based violence, discrimination, and exploitation within their employer’s households. With their movements heavily restricted, it is even more difficult for victims to leave situations of abuse.

In 2020, Walk Free interviewed 30 female survivors of domestic servitude who were exploited in Lebanon and Kuwait. Respondents came from six countries, including Cameroon, Ethiopia, Ghana, Kenya, the Philippines, and Sierra Leone, and were employed in Kuwait and Lebanon, where strict versions of the kafala system operate. While migrants do not require an exit permit to depart Lebanon or Kuwait, all other elements of the kafala system are present. In Lebanon, migrants cannot leave their job without their employer’s permission28 and in Kuwait, domestic workers must receive approval from the Ministry of Interior and Labour Court to transfer jobs without consent from their employer.29 Getting this approval requires workers to leave their employer’s household, which can lead to accusations of absconding and result in deportation:30 seeking help is not without significant risks for migrant domestic workers.

The interviews highlighted the difficulties women faced when seeking to leave their situation. Three-quarters of respondents had limited or no access to a phone in at least one household where they worked, and more than half reported having their movements restricted, including by being locked inside places of employment or monitored on camera. Half of all respondents physically escaped their household, and five women were subsequently arrested by police despite having experienced abuse and mistreatment by their employers. At least nine respondents were deported or repatriated after leaving their workplace, however this number is likely higher given not all respondents reported how they returned home.

“After I escaped, [my employers] told me that I had been reported to police for having stolen money from the home. Shortly afterwards, the police showed up and arrested me…When the day of my flight arrived, I wasn’t even allowed to collect my possessions. I was still owed four months’ salary and returned empty-handed.” 23-year-old Ghanaian female survivor of domestic servitude

Perceived or actual lack of protection prevented victims leaving situations of exploitation. Respondents reported that a lack of assistance from embassies, consulates, employment agencies, police, and beliefs that they could not turn to authorities were barriers to seeking help. While it is unclear how some respondents returned home, several were assisted by civil society organisations or family members, while few others had the cost of their tickets home paid for by their employers and agents. In one instance, a worker in Kuwait was required to pay her employer to be allowed to leave. For some workers, returning was further complicated by unpaid wages and confiscation of passports. When specifically asked if their documents were seized, all respondents in Cameroon reported that their passports were seized in Lebanon, where the practice is not outlawed,31 and in Kuwait, where passport withholding is illegal.32

“I didn’t go to police because they always support their citizens and will always treat my escape as a breach of contract. That was what my employer told me. I got to a church owned by a Ghanaian and they also told me they can’t be of help since I’ve breached a contract…I was arrested by police on the street, the Kuwait government paid for my flight.” 31-year-old Cameroonian female survivor of domestic servitude

Almost two-thirds of respondents paid fees to brokers in their country of origin or transit, including in Ethiopia and Guinea, where domestic laws prohibit workers being charged recruitment fees.33 Payment of fees increases risk of debt bondage in the Gulf states, where workers are forced to work for little or no pay in order to repay recruitment and related fees.34 While Kuwait35 and Jordan36 prohibit charging recruitment fees to migrant domestic workers, and the remaining kafala countries prohibit charging recruitment fees to all migrant workers,37 exorbitant fees are still passed on in practice.38 To cover these costs, some respondents borrowed money from family or arranged to pay the money when they began their job, which typically carried the false promise of a good salary and ultimately led to situations of debt bondage. Many respondents were also deceived about the nature and conditions of the work, with more than a third of them being promised an entirely different form of employment than domestic work. Among respondents in Cameroon, just under half did not sign a contract and some respondents signed contracts in a language they did not understand. Meanwhile, two Ethiopian migrant workers reported being encouraged to travel despite a temporary ban on labour migration to Gulf states being in effect at the time.

“I think Lebanese law needs to change so that we may have our rights protected. I wouldn’t have had to escape.” 33-year-old Ethiopian female survivor of domestic servitude

Most migrant workers reported having very little to no knowledge about the destination country prior to travelling. Respondents in Cameroon were asked further questions on what would have been helpful for them in preparing for work. The most common response was knowing the true nature and conditions of the work. When the remaining respondents (those in Ethiopia, Ghana, Kenya, the Philippines, and Sierra Leone) were asked what support they needed but did not receive, the most common responses focused on greater support from embassies, employment agencies, or police.

Impact of COVID-19

The situation worsened for many migrants during the COVID-19 pandemic, with reports of wage theft in the construction,39 hospitality, and manufacturing sectors in Gulf countries,40 largely driven by order cancellations, weakened labour protections (allowing employers to reduce wages), and dismissal or repatriation of workers without pay.41 Migrants from countries in Asia and Africa are often recruited to work in these sectors by a complex network of local brokers, recruitment agents, friends, and relatives.42 They may receive limited or inaccurate information about the nature of the work and be required to pay substantial recruitment fees to migrate through informal and formal channels, thereby increasing their risk of debt-bondage and exploitation in the destination.43 During the pandemic, some migrants reportedly defaulted on loan repayments due to wage theft and were subsequently arrested in the UAE,44 while several migrant workers in Qatar were deported before receiving their wages.45 Construction workers were physically abused after requesting their unpaid salaries in Saudi Arabia,46 where the government also allowed a temporary 40 per cent pay reduction in the private sector.47 Lockdowns intensified social isolation and vulnerability among domestic workers in private households48 and compounded difficulties in sending remittances home.49 Some domestic workers in Lebanon were abandoned outside their consulates by employers who said they can no longer afford to pay them.50

The state of reform

The five elements of the kafala system present across countries in the Arab States are set out in Table 17.51

Table 17: Status of key elements of the Kafala system, by country
Country Employer must sponsor entry into country Employer controls residency / work permit Employer must grant permission for workers to change / leave job  Employer can report worker for absconding Employer must grant permission for worker to exit country
Bahrain52
Under reforms introduced in December 2022, visit visas can no longer be converted into a work permits, meaning migrants cannot obtain a work permit without exiting Bahrain.53
The vocational work permit allows workers to self-sponsor in designated professions. It is unclear if domestic workers are eligible.54
Vocational work permit holders can transfer labour registration centres after a minimum of 30 days from initial registration.55 Excluding domestic workers,56 other migrants can transfer after one year with three months’ notice.57
Before the Flexi-Permit was cancelled in October 2022, permit holders could not have absconding cases filed against them.58 It is unclear whether the new permit allows absconding charges to be filed. Other migrant workers can be punished for absconding.59
Oman60
Visit visas may be converted into a work visa without the worker having to exit Oman, however granting of the work visa depends on the employer.61
Migrant workers can transfer jobs without permission after completion of their contract.62
United Arab Emirates63
Free zone workers are sponsored by the free zone authority rather than an employer.64 Visit visas may also be converted without the worker having to exit the UAE.65
Requirement for permission is waived in certain circumstances, such as contract expiry or non-payment of wages.66 Domestic workers may end their contract without consent if their employer violates legal obligations. They can transfer employers upon expiry of the contract.67
Kuwait68
Migrants can change jobs after three years and 90 days’ notice without permission.69 Excludes domestic workers, who require approval from the Ministry of Interior and Labour Court to transfer jobs without consent from their employer.
Lebanon70
Qatar71
Migrant workers can transfer jobs under certain conditions and at least one or two month’s notice.72
Almost all migrant workers can depart without permission; however, employers can apply to have up to 5 per cent of certain employees to require prior approval.73 Domestic workers must give 72 hours’ notice.74
Saudi Arabia75
Migrants can transfer employers upon completion of their contract, or after one year under certain conditions.76 Domestic workers can transfer in some cases such as abuse.77
Migrant workers can apply to exit the country without their employer’s permission.78 This does not apply to domestic workers.79
Jordan80
Migrants can terminate unlimited term contracts with one month’s notice;
However, they may be required to compensate the employer. Limited term contracts can be terminated under certain conditions without permission or upon expiry. Excludes certain categories such as agricultural workers.81

Rating scale: = In force = partially in force  not in force

Forms of tied visa programs operate in several other countries globally, and these systems similarly increase migrant workers’ vulnerability to exploitation.82 However, the various iterations of the kafala system involve some of the most restrictive conditions and are present in countries which have among the highest concentrations of migrant workers in the world.83 Over the past decade, countries that uphold kafala have faced significant criticism due to the pervasive abuse of migrant workers under the system, with major international events such as the Qatar 2022 FIFA World Cup and Dubai World Expo 2020 drawing global attention to the issue.84 Several countries have instituted reforms, some in response to mounting international pressure, yet no country has abolished kafala entirely, with vestiges of the system undermining reform efforts.

Qatar represents one example in which preparations for the FIFA World Cup since 2010 have drawn attention to grave migrant worker abuses in the construction, hotel, and security sectors.85 Amid mounting criticism in 2017,86 Qatar agreed to undertake a technical cooperation program with the ILO,87 seeking to align laws and practices with international labour standards.88 Promisingly, in 2020 Qatar ceased requiring exit permits for workers excluded from the scope of the labour law, including migrant domestic workers, expanding upon a similar 2018 amendment.89 Qatar also removed No-Objection Certificate (NOC) requirements, allowing workers to change jobs without permission from their employer under certain conditions.90 However, these positive reforms have been undermined by gaps in implementation and protections. In practice, the system is not only difficult for migrant workers to navigate, but many are unaware of their right to leave,91 and even if they are they still face the threat of retaliation from their employers who may file false allegations of theft or absconding.92 As reports of abuse persisted in the lead-up to the World Cup, human rights organisations continued to call for the government to enforce reforms and for FIFA and the Supreme Committee for Delivery and Legacy (the body responsible for delivering the event) to strengthen due diligence and monitoring,93 as well as establish a scheme to remediate harms caused.94 While global attention was brought to the issue following the games, it has not been followed by any meaningful commitment or action by FIFA and the Qatari government, with impacted migrant workers still struggling to access compensation.95

Several other countries have implemented limited reforms to increase job mobility in recent years. In 2021, the government of Oman removed its NOC requirement, allowing workers to transfer jobs without their employer’s permission upon completion of their contract.96 Saudi Arabia’s 2021 Labour Reform Initiative similarly allows workers to change jobs or leave the country without employer consent;97 however, workers must complete one year of their contract and migrant domestic workers, among others, are excluded from this protection.98 Under 2016 reforms allowing workers to transfer jobs in the UAE, workers must complete their contract or provide advance notice to avoid an employment ban, and may be required to compensate their employer.99 As in Qatar, absconding is punishable in each of these countries and places migrant workers at risk of arrest or deportation for leaving abusive workplaces.

Even in Bahrain, which previously had the most sweeping reforms to the kafala system, gaps in protections persisted.100 In 2017, the government introduced the Flexi-Permit, allowing migrant workers to freely change jobs and leave the country without facing possible charges of absconding.101 This granted greater freedom than had ever been seen under the kafala system, yet the steep price of the permit deterred those eligible from self-sponsoring102 and permit-holders lacked defined labour protections under the law.103 Rather than address these shortcomings in line with civil society recommendations,104 Bahrain abandoned the system entirely in October 2022,105 replacing it with a program that allows workers to self-sponsor within designated professions.106 Under the new system,107 workers must obtain a vocational work permit through a certified registration centre, effectively privatising the process.108 While the reforms purport to strengthen protections for migrants, those with irregular status from October 2022 are not eligible for the permit (unlike the Flexi-Permit system).109 Further, workers must still bear the cost of the permit and can no longer obtain commercial registration.110 The reforms were passed amid pressure from the business community, which was driven by fears that freelance migrant workers posed a threat to local businesses, and due to a government push to nationalise their workforce in a bid to move away from reliance on migrant workers.111

Several countries in the region still grapple with strong opposition to comprehensive reforms due to perceived economic benefits of the kafala system and entrenched discriminatory attitudes towards foreign workers.112 In 2020, prior to the installation of a new government in Lebanon, a new standard unified contract was proposed to allow migrant workers to change employers after one month’s notice, among other protections.113 However, the contract was swiftly struck down by the Shura Council, Lebanon’s highest administrative court, after the Syndicate of Owners of Recruitment Agencies in Lebanon claimed that the contract violated the labour law and would adversely affect domestic worker recruitment, a lucrative trade in Lebanon.114

The government of Jordan has taken the least action to reform the kafala system. Jordan currently maintains all elements of the kafala system, whereby migrant workers typically cannot enter or exit the country or transfer jobs without written employer consent.115 While the government has made some attempts to curb illegal practices of unscrupulous recruitment agents and improve protections,116 there is a lack of capacity and will to enforce the regulations.117

Recommendations for host governments

  1. Dismantle kafala by expanding coverage of national labour laws to include all workers and. ensuring migrant workers can freely enter, reside, and exit the country, and leave or transfer jobs without employer consent.

  2. Strengthen monitoring and regulation of recruitment agencies and high-risk sectors by increasing resources and capacity of labour inspectorates and conducting unannounced labour inspections. In addition, operate reporting mechanisms with whistle-blower protections to allow workers to freely report grievances.

  3. Strengthen criminal justice responses, including the provision of free legal and interpretation services, and provide systematic, regular training on victim identification for police and first responders to ensure no victims are detained and deported. Provide training for prosecutors and the judiciary on related legislation to support access to justice, including timely compensation for survivors.

  4. Address underlying discriminatory and xenophobic attitudes towards migrant workers that increase their vulnerability to modern slavery across all sectors.

  5. Ratify international conventions including the ILO Domestic Workers Convention, 2011 (No. 189), and the ILO Protocol of 2014 to the Forced Labour Convention, 1930.

Recommendations for sending governments

  1. Introduce and enforce laws to prohibit charging of recruitment fees to employees and register and monitor local recruitment agencies for deceptive practices, ensuring contracts are made available in a language migrants can understand.

  2. Pursue and strengthen bilateral labour agreements to protect migrant workers (rather than implementing labour migration bans) and cooperate with other sending countries to advocate for common standards for the protection of workers, in consultation with migrant workers, survivors, and civil society.

  3. Strengthen the capacity of embassies in receiving countries to support survivors, including through deployment of trained labour attachés, and make survivor funds accessible to all migrant workers, regardless of their status.

  4. Launch targeted information campaigns and formal training to ensure prospective migrants are informed of the risks, their rights, and support services available in the destination country, and support and engage with returned migrant workers to inform policies and decision-making.

View the overview of the Arab States regional findings.

Endnotes

1Kalush, R, Saraswathi, V, Mohamed, A & Fousdeen, F 2019, Lived Experience of Migrant Women: Qatar, Bahrain, and Kuwait, Migrant-Rights.Org, p. 14. Available from: https://respect.international/wp-content/uploads/2019/12/Lived-Experience-of-Migrant-Women-Quatar-Bahrain-and-Kuwait.pdf. [2 February 2022].
2Joudo Larsen, J, McCormack, S & Husn, HA 2015, The Other Migrant Crisis: Protecting Migrant Workers against Exploitation in the Middle East and North Africa, International Organization for Migration, pp. 13-14. Available from: https://publications.iom.int/system/files/pdf/other_migrant_crisis.pdf. [2 November 2020]; Cockayne, J 2021, Developing Freedom: The Sustainable Development Case for Ending Modern Slavery, Forced Labour and Human Trafficking, United Nations University, p. 218. Available from: https://www.developingfreedom.org/wp-content/uploads/2021/01/DevelopingFreedom_MainReport_WebFinal.pdf. [2 February 2022]; Motaparthy, P 2015, ‘Understanding Kafala: An archaic law at cross purposes with modern development’, Migrant-Rights.Org, 11 March. Available from: https://www.migrant-rights.org/2015/03/understanding-kafala-an-archaic-law-at-cross-purposes-with-modern-development/. [13 February 2022].
3Amnesty International 2020, ‘Why do you want to rest?’: Ongoing abuse of domestic workers in Qatar. Available from: https://www.amnesty.org/en/wp-content/uploads/sites/9/2021/05/MDE2231752020ARABIC.pdf. [30 November 2021]; Amnesty International 2019, ‘Their house is my prison’: Exploitation of migrant domestic workers in Lebanon. Available from: https://www.amnesty.org/en/wp-content/uploads/sites/9/2021/05/MDE1800222019ARABIC.pdf. [30 November 2021]; McQue, K 2021, ‘Alone in Oman: Covid worsens abuse for trafficked women’, The Guardian, 23 March. Available from: https://www.theguardian.com/global-development/2021/mar/23/alone-oman-covid-worsens-abuse-trafficked-women-africa. [30 November 2021.
4Equidem 2020, The Cost of Contagion: The human rights impacts of COVID-19 on migrant workers in the Gulf, pp. 24-25. Available from: https://www.equidem.org/assets/downloads/1837_Equidem_The_Cost_of_Congation_Report_ART_WEB.pdf. [30 November 2021]; Business & Human Rights Resource Centre 2018, From Unacceptable Risks to Shared Prosperity: Building Human Rights into Jordan & Lebanon’s Construction Sector, pp. 8-9. Available from: https://media.business-humanrights.org/media/documents/files/Jordan_Report_FINAL_WEB.pdf. [13 February 2022].
52020, ‘Restaurant workers driven to starvation in Saudi’, Migrant-Rights.Org, 4 August. Available from: https://www.migrant-rights.org/2020/08/restaurant-workers-driven-to-starvation-in-saudi/. [13 February 2022]; Business & Human Rights Resource Centre 2019, Inhospitable: How hotels in Qatar & the UAE are failing migrant workers. Available from: https://media.business-humanrights.org/media/documents/files/Gulf-Hotels-Briefing.pdf. [13 February 2022].
62018, ‘Death and Desolation: Shepherds and Farmworkers in Saudi Arabia’, Migrant-Rights.Org, 16 May. Available from: https://www.migrant-rights.org/2018/05/death-and-desolation-shepherds-and-farmworkers-in-saudi-arabia/. [7 April 2022]; Razzaz, S 2017, A Challenging Market Becomes More Challenging: Jordanian Workers, Migrant Workers and Refugees in the Jordanian Labour Market, International Labour Organization, pp. 9-12, 52-55. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_556931.pdf. [7 April 2022].
7While significant reforms have occurred in Qatar, such as removal of the No Objection Certificate and allowing migrant workers to change jobs without permission from their employer, elements of the kafala system remain in place and undermine claims that kafala has been abolished. For example, migrant workers can be criminalised for absconding. See: International Labour Office 2019, Monitoring compliance with international labour standards: the key role of the ILO Committee of Experts of the Application of Conventions and Recommendations, International Labour Organization, p. 51. Available from: https://www.ilo.org/wcmsp5/groups/public/—ed_norm/—normes/documents/publication/wcms_730866.pdf. [26 August 2022].
8Includes kafala countries plus Iraq, Occupied Palestinian Territories, Syria, and Yemen.
9International Labour Office 2021, ILO Global Estimates on International Migrant Workers: Results and Methodology, International Labour Organization, pp. 30-31. Available from: https://www.ilo.org/wcmsp5/groups/public/@dgreports/@dcomm/@publ/documents/publication/wcms_808935.pdf. [26 August 2022].
10Motaparthy, P 2015, ‘Understanding Kafala: An archaic law at cross purposes with modern development’, Migrant-Rights.Org, 11 March. Available from: https://www.migrant-rights.org/2015/03/understanding-kafala-an-archaic-law-at-cross-purposes-with-modern-development/. [13 February 2022]; Begum, R 2020, ‘What Will it Take for Saudi Arabia to Abolish Abusive Sponsorship System?’, Human Rights Watch, 30 October. Available from: https://www.hrw.org/news/2020/10/30/what-will-it-take-saudi-arabia-abolish-abusive-sponsorship-system. [13 February 2022].
11Clyde & Co 2020, Comparison of Absconding laws in the GCC, Migrant-Rights.Org. Available from: https://infogram.com/comparison-of-absconding-laws-in-the-gcc-1h7v4pzolky86k0. [20 February 2022]; Saraswathi, V 2020, ‘Huroob, Runaway, Absconding: Trapping migrants in extreme abuse’, Migrant-Rights.Org, 30 September. Available from: https://www.migrant-rights.org/2020/09/huroob-runaway-absconding-trapping-migrants-in-extreme-abuse/. [28 July 2022].
12Act No. 21 of 27 October 2015 which regulates the entry, exit of expatriates and their residence, 2015 (Qatar) 26; UAE Government Portal 2020, Labour ban, Government of the United Arab Emirates. Available from: https://u.ae/en/information-and-services/jobs/labour-ban. [20 February 2022]; Act No. 19 with regard to the Regulation of the Labour Market, 2006 (Bahrain) art 36; Labour Law and its Amendments, 1996 (No. 8) (Jordan) 12; Zahra, M 2019, The Legal Framework of the Sponsorship Systems of the Gulf Cooperation Council Countries: A Comparative Examination, Gulf Labour Markets and Migration. Available from: https://gulfmigration.grc.net/media/pubs/exno/GLMM_EN_2019_04.pdf. [13 April 2022]; 2021, ‘Saudi Arabia: Labor Reforms Insufficient’, Human Rights Watch, 25 March. Available from: https://www.hrw.org/news/2021/03/25/saudi-arabia-labor-reforms-insufficient. [16 February 2022]; Foreigners’ Residence Law, 1995 (Oman); General Directorate of General Security n.d., The expulsion from Lebanon, Government of Lebanon. Available from: https://www.general-security.gov.lb/en/operations/details/147. [13 April 2022].
13Personal communication; Tamkeen 2020, Under the Microscope: Analysis of Human Trafficking Cases in Jordan, pp. 74-77. Available from: https://ps.boell.org/sites/default/files/2021-05/Under_The_Microscope_–_Analysis_of_Human_Trafficking_Cases_in_Jordan.pdf. [15 February 2022]; International Labour Organization & The Legal Agenda 2020, The labyrinth of justice: Migrant domestic workers before Lebanon’s courts, International Labour Organization, pp. 19-20. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_777078.pdf. [2 February 2022]; Amnesty International 2019, All Work, No Pay: the Struggle of Qatar’s Migrant Workers for Justice. Available from: https://www.amnesty.org/en/wp-content/uploads/2021/05/MDE2207932019ENGLISH.pdf. [16 May 2022].
14As above; 2016, ‘‘I Was Sold’: Abuse and Exploitation of Migrant Domestic Workers in Oman’, Human Rights Watch, 13 July. Available from: https://www.hrw.org/report/2016/07/13/i-was-sold/abuse-and-exploitation-migrant-domestic-workers-oman. [28 February 2022]; Amnesty International 2020, ‘Why do you want to rest?’: Ongoing abuse of domestic workers in Qatar, pp. 60-61. Available from: https://www.amnesty.org/en/wp-content/uploads/sites/9/2021/05/MDE2231752020ARABIC.pdf. [30 November 2021].
152020, ‘Kuwait drops all ‘absconding’ cases reported during Covid-19 crisis’, Migrant-Rights.Org, 9 July. Available from: https://www.migrant-rights.org/2020/07/kuwait-drops-all-absconding-cases-reported-during-covid-19-crisis/. [20 February 2022]; 2020, ‘Qatar: Significant Labor and Kafala Reforms’, Human Rights Watch, 24 September. Available from: https://www.hrw.org/news/2020/09/24/qatar-significant-labor-and-kafala-reforms. [2 November 2020]; 2021, ‘Saudi Arabia: Labor Reforms Insufficient’, Human Rights Watch, 25 March. Available from: https://www.hrw.org/news/2021/03/25/saudi-arabia-labor-reforms-insufficient. [16 February 2022].
16International Labour Organization & The Legal Agenda 2020, The labyrinth of justice: Migrant domestic workers before Lebanon’s courts, International Labour Organization, p. 13. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_777078.pdf. [2 February 2022]; Tamkeen 2020, Under the Microscope: Analysis of Human Trafficking Cases in Jordan, pp. 54-55. Available from: https://ps.boell.org/sites/default/files/2021-05/Under_The_Microscope_–_Analysis_of_Human_Trafficking_Cases_in_Jordan.pdf. [15 February 2022].
17Dito, M 2013, ‘Kafala: Foundations of Migrant Exclusion in GCC Labour Markets’, in OH AlShehabi, A Hanieh & A Khalaf (eds) Transit States: Labour Migration and Citizenship in the Gulf, p. 79. Pluto Press. Available from: ISBN 9781783712205.
18Convention on the Rights of the Child (CRC) 1989, (resolution 44/25), opened for signature 20 November 1989, entered into force 2 September 1990, art. 20(3).
19Rotabi, KS, Bromfield, NF, Lee, J & Sarhan, TA 2017, ‘The Care of Orphaned and Vulnerable Children in Islam: Exploring Kafala with Muslim Social Work Practice with Unaccompanied Refugee Minors in the United States’, Journal of Human Rights and Social Work, vol. 2, pp. 16-24. Available from: DOI:10.1007/s41134-017-0027-2. [11 July 2022].
20Jureidini, R & Hassan, SF 2019, ‘The Islamic Principle of Kafala as Applied to Migrant Workers: Traditional Continuity and Reform’, in Leiden (ed) Migration and Islamic Ethics, pp. 92-109. Brill, The Netherlands. Available from: https://doi.org/10.1163/9789004417342_007. [7 July 2022].
21AlShehabi, OH 2019, ‘Policing labour in empire: the modern origins of the Kafala sponsorship system in the Gulf Arab States’, British Journal of Middle Eastern Studies, vol. 48, no. 2, pp. 291-310. Available from: DOI:https://doi.org/10.1080/13530194.2019.1580183. [7 July 2022].
22As above; Kanchana, R 2018, ‘Is the Kafala Tradition to Blame for the Exploitative Work Conditions in the Arab-Gulf Countries?’, in M Chowdhury & RS Irudaya (eds) South Asian Migration in the Gulf, pp. 61-79. Palgrave Macmillan, Cham. Available from: DOI:10.1007/978-3-319-71821-7_4. [8 July 2022].
23AlShehabi, OH 2019, ‘Policing labour in empire: the modern origins of the Kafala sponsorship system in the Gulf Arab States’, British Journal of Middle Eastern Studies, vol. 48, no. 2, pp. 291-310. Available from: DOI:https://doi.org/10.1080/13530194.2019.1580183. [7 July 2022].
24As above.
25Jureidini, R & Hassan, SF 2019, ‘The Islamic Principle of Kafala as Applied to Migrant Workers: Traditional Continuity and Reform’, in Leiden (ed) Migration and Islamic Ethics, pp. 92-109. Brill, The Netherlands. Available from: DOI:https://doi.org/10.1163/9789004417342_007. [7 July 2022].
26See for example: Hourany, D 2022, ‘Beyond the Kafala system’, Now Lebanon, 6 February. Available from: https://nowlebanon.com/beyond-the-kafala-system/. [26 August 2022].
27Mehzer, Z, Nassif, G & Wilson, C 2021, Women Migrant Domestic Workers in Lebanon: A Gender Perspective, UN Women, p. 4. Available from: https://www2.unwomen.org/-/media/field%20office%20arab%20states/attachments/publications/2021/06/migrant-workers-rights-are-womens-rights-june16-2021-final2.pdf?la=en&vs=1249. [2 February 2022]; Ferrant, G, Pesando, LM & Nowacka, K 2014, Unpaid Care Work: The missing link in the analysis of gender gaps in labour outcomes, Organization for Economic Cooperation and Development, p. 1. Available from: https://www.oecd.org/Dev/Development-Gender/Unpaid_Care_Work.Pdf. [11 February 2022]; Kalush, R, Saraswathi, V, Mohamed, A & Fousdeen, F 2019, Lived Experience of Migrant Women: Qatar, Bahrain, and Kuwait, Migrant-Rights.Org, pp. 8, 12. Available from: https://respect.international/wp-content/uploads/2019/12/Lived-Experience-of-Migrant-Women-Quatar-Bahrain-and-Kuwait.pdf. [2 February 2022].
28International Labour Organization 2019, Regulatory Framework Governing Migrant Workers: Lebanon, p. 3. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/legaldocument/wcms_728264.pdf. [21 February 2022].
29International Labour Organization 2021, Regulatory Framework Governing Migrant Workers: Kuwait, p. 3. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_776524.pdf. [21 February 2022].
30Personal communication.
312020, ‘Lebanon takes crucial first step towards dismantling Kafala in Lebanon’, International Labour Organization, 10 September. Available from: https://www.ilo.org/beirut/media-centre/news/WCMS_755008/lang–en/index.htm#:~:text=BEIRUT%20%E2%80%93%20(ILO%20News)%20Lebanon,and%20elsewhere%20across%20the%20region. [2 February 2022].
32Government of Kuwait 2019, National report submitted in accordance with paragraph 5 of the annex to Human Rights Council resolution 16/21 – Kuwait A/HRC/WG.6/35/KWT/1, United Nations Human Rights Council, p. 18. Available from: https://undocs.org/A/HRC/WG.6/35/KWT/1. [01 July 2021]; ILO Fairway Project 2019, Kuwait: Regulatory framework governing migrant workers, International Labour Organization, p. 2. Available from: https://www.migrant-rights.org/wp-content/uploads/2019/10/FAIRWAY-Factsheet-GCC.pdf. [02 July 2021].
33Ethiopia’s Overseas Employment Proclamation, 2016 (Proclamation No. 923/2016) (Ethiopia) 10; Law L/2014/072/CNT of January 10, 2014 on the Labor Code of the Republic of Guinea, 2014 (Guinea) 110.5.
34Cockayne, J 2021, Developing Freedom: The Sustainable Development Case for Ending Modern Slavery, Forced Labour and Human Trafficking, United Nations University, p. 216. Available from: https://www.developingfreedom.org/wp-content/uploads/2021/01/DevelopingFreedom_MainReport_WebFinal.pdf. [2 February 2022].
35International Labour Office 2018, Findings from the global comparative study on the definition of recruitment fees and related costs, p. 2018. Available from: https://www.ilo.org/wcmsp5/groups/public/—ed_protect/—protrav/—travail/documents/meetingdocument/wcms_646693.pdf. [02 July 2021].
36Regulation No. 12 of 2015 regulating the organisation of Private Recruitment Agencies for the Recruitment of Non-Jordanian Domestic Workers, 2015 (Jordan) 7.
37In Bahrain, article 23(C) of Act No. (19) (2006) With Regard to The Regulation of the Labour Market prohibits employers obtaining benefit from an employee in return for issuing a work permit, however, the Act does not explicitly prohibit on-charging recruitment fees to workers. For legislation prohibiting recruitment fees in kafala countries see: Act No. 19 With Regard to the Regulation of the Labour Market, 2006 (Bahrain) arts 23 & 24; Fundamental Principles and Rights at Work 2016, Intertwined: A study of employers of migrant domestic workers in Lebanon, International Labour Organization, p. 18. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_524149.pdf. [16 February 2022]; Law No. 14 of 2004 Regulating Employment, 2004 (Qatar) 33; Ministerial Resolution No. (1205) for 2013 Licensing and Regulation of Private Recruitment Agencies,  (United Arab Emirates) 6; International Labour Organization 2019, Regulatory Framework Governing Migrant Workers, p. 1. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/legaldocument/wcms_728262.pdf. [16 February 2022]; Oman Labour Law Issued in accordance with the Sultan’s Decree no. 35/2003, 2003 (Oman) 20; Mohamed, A 2021, ‘The Flexi Permit Experiment: No Kafala, but poor labour practices persist’, Migrant-Rights.Org, 12 April. Available from: https://www.migrant-rights.org/2021/04/the-flexi-permit-experiment-no-kafala-but-poor-labour-practices-persist/. [2 February 2022]; International Labour Organization 2019, Labour mobility between Asia and the Arab States: Sharing of experiences and progress under the Bali Declaration with specific focus on women migrant workers, p. 55. Available from: https://www.ilo.org/wcmsp5/groups/public/—asia/—ro-bangkok/—sro-bangkok/documents/publication/wcms_754661.pdf. [4 July 2021].
382021, ‘Saudi Arabia: Labor Reforms Insufficient’, Human Rights Watch, 25 March. Available from: https://www.hrw.org/news/2021/03/25/saudi-arabia-labor-reforms-insufficient. [16 February 2022]; Pattisson, P 2021, ‘G4S migrant workers ‘forced to pay millions’ in illegal fees for jobs’, The Guardian, 18 January. Available from: https://www.theguardian.com/global-development/2021/jan/18/g4s-migrant-workers-forced-to-pay-millions-in-fees-for-jobs#:~:text=An%20investigation%20into%20G4S’s%20recruitment,for%20G4S%20in%20the%20UAE. [16 February 2022]; Jureidini, R 2017, ‘Transnational Culture of Corruption in Migrant Labour Recruitment’, in M McAuliffe & MK Solomon (eds) Ideas to Inform International Cooperation on Safe, Orderly and Regular Migration, pp. 1-10, IOM, Geneva. Available from: https://publications.iom.int/system/files/pdf/transnational_culture.pdf. [7 July 2022].
39Equidem 2020, The Cost of Contagion: The human rights impacts of COVID-19 on migrant workers in the Gulf. Available from: https://www.equidem.org/assets/downloads/1837_Equidem_The_Cost_of_Congation_Report_ART_WEB.pdf. [30 November 2021].
40Migrant Forum Asia 2021, Crying Out for Justice: Wage Theft Against Migrant Workers during COVID-19, p. 26. Available from: http://mfasia.org/migrantforumasia/wp-content/uploads/2021/04/MFA_Crying-Out-for-Justice_04.12.pdf. [30 November 2021].
41As above, pp. 4-5; ILO Migration Advisory Group (Arab States) 2021, COVID-19 Pandemic: Wage protection of migrant workers in the Arab States, International Labour Organization. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/briefingnote/wcms_803052.pdf. [13 April 2022].
42Azad, A 2019, ‘Recruitment of Migrant Workers in Bangladesh: Elements of Human Trafficking for Labor Exploitation’, Journal of Human Trafficking, vol. 5, no. 2, pp. 130-150. Available from: https://www.tandfonline.com/action/showCitFormats?doi=10.1080/23322705.2017.1422091. [17 December 2020]; Five Corridors Project 2021, Nepal to Kuwait and Qatar: Fair recruitment in review, Fair Square, pp. 17-21. Available from: https://fivecorridorsproject.org/uploads/C2_3_Nepal_Kuwait_Qatar-report.pdf. [16 May 2022].
43As above.
44Migrant Forum Asia 2021, Crying Out for Justice: Wage Theft Against Migrant Workers during COVID-19, p. 8. Available from: http://mfasia.org/migrantforumasia/wp-content/uploads/2021/04/MFA_Crying-Out-for-Justice_04.12.pdf. [30 November 2021].
452020, ‘Qatar: Migrant workers illegally expelled during COVID-19 pandemic’, Amnesty, 15 April. Available from: https://www.amnesty.org/en/latest/news/2020/04/qatar-migrant-workers-illegally-expelled-during-covid19-pandemic/. [11 February 2022].
46Equidem 2020, The Cost of Contagion: The human rights impacts of COVID-19 on migrant workers in the Gulf, p. 7. Available from: https://www.equidem.org/assets/downloads/1837_Equidem_The_Cost_of_Congation_Report_ART_WEB.pdf. [30 November 2021].
472020, ‘Saudi Arabia allows businesses to reduce workers wages without consent’, Migrant-Rights.Org, 7 May. Available from: https://www.migrant-rights.org/2020/05/saudi-arabia-allows-businesses-to-reduce-workers-wages-without-consent/. [11 February 2022].
48Begum, R 2020, ‘Domestic Workers in Middle East Risk Abuse Amid COVID-19 Crisis’, Human Rights Watch, 6 April. Available from: https://www.hrw.org/news/2020/04/06/domestic-workers-middle-east-risk-abuse-amid-covid-19-crisis. [11 February 2022]; Redfern, C 2021, ‘‘I want to go home’: Filipina domestic workers face exploitative conditions’, The Guardian, 27 January. Available from: https://www.theguardian.com/world/2021/jan/27/domestic-workers-philippines-coronavirus-conditions. [11 February 2022].
49Donovan, L 2021, ‘Female migrant workers and the families they support are being abandoned by the money-transfer industry’, Fortune, 15 July. Available from: https://fortune.com/2021/07/15/covid-migrant-workers-women-domestic-work-remittances-money-transfers/. [2 February 2022].
50Ramadan, T 2021, ‘‘Lebanon is a prison’: Migrant domestic workers struggle to leave collapsing Lebanon’, L’Orient Today, 16 September. Available from: https://today.lorientlejour.com/article/1274970/lebanon-is-a-prison-migrant-domestic-workers-struggle-to-leave-collapsing-lebanon.html. [2 February 2022].
51Begum, R 2020, ‘What Will it Take for Saudi Arabia to Abolish Abusive Sponsorship System?’, Human Rights Watch, 30 October. Available from: https://www.hrw.org/news/2020/10/30/what-will-it-take-saudi-arabia-abolish-abusive-sponsorship-system. [13 February 2022].
52Employer must sponsor entry into country: Act No. 19 With Regard to the Regulation of the Labour Market, 2006 (Bahrain) art 24Resolution No. (1) of 2022 regarding assigning some tasks of the Labor Market Regulatory Authority to labor registration centers, 2022 (Bahrain) art. 5.Employer controls residency / work permit: Kaur, H 2017, ‘Flexible work permit launched’, Labour Market Regulatory Authority, 24 July. Available from: http://blog.lmra.bh/en/2017/07/24/flexible-work-permit-launched/#more-3469. [1 August 2022]; Act No. 19 With Regard to the Regulation of the Labour Market, 2006 (Bahrain) arts 23 & 24; Migration Policies in the Arab Region 2022, Change in work permit management for domestic workers, UNESCWA. Available from: https://migrationpolicy.unescwa.org/node/3647. [29 August 2022].Employer must grant permission for workers to change / leave job: Act No. 19 With Regard to the Regulation of the Labour Market, 2006 (Bahrain) art 25; Order No. 79 of 2009 with regard to the Procedures for Transfer of a Foreign Worker to Another Employer, 2009 (Bahrain) arts 2 & 3; Order No. 15 of 2011 With Regard to Amending Paragraph (A) of Law No. 19 of 2006 Concerning the Regulation of the Labour Market, 2011 (Bahrain) art 3; Labour Market Regulatory Authority 2022, Expatriate Employee Transfer, Kingdom of Bahrain. Available from: https://lmra.bh/portal/en/page/show/194. [1 August 2022]; Law No. 36 of 2012 with regard to the promulgation of the labour law in the private sector, 2012 (Bahrain) art 2(b)(1).Employer can report worker for absconding: Law No. 36 of 2012 with regard to the promulgation of the labour law in the private sector, 2012 (Bahrain) art 107; Labour Market Regulatory Authority 2022, Expatriate Employee Absence From Work Notification, Government of Bahrain. Available from: https://lmra.bh/portal/en/page/show/188. [29 August 2022].Employer must grant permission for worker to exit country: Labour Market Regulatory Authority 2022, Flexi Permit, Kingdom of Bahrain. Available from: https://lmra.bh/portal/en/page/show/325. [11 October 2021]; Decision No. 87 of 2006 concerning the Issuance of a Residence Permit Allowing its Holder to Leave and Return to the Country for Multiple Trips (Bahrain), arts 1 – 2.
53Resolution No. (1) of 2022 regarding assigning some tasks of the Labor Market Regulatory Authority to labor registration centers, 2022 (Bahrain) art. 5.
542022, ‘Bahrain launches new Labour Registration Program to replace Flexi-Permit’, Migrant-Rights.Org, 12 December. Available from: https://www.migrant-rights.org/2022/12/bahrain-launches-new-labour-registration-program-to-replace-flexi-permit/. [20 December 2022].
55Labour Market Regulatory Authority 2022, General Questions for the Labour Registration Program, Kingdom of Bahrain. Available from: https://lmra.bh/portal/en/page/show/428. [20 December 2022].
56Law No. 36 of 2012 with regard to the promulgation of the labour law in the private sector, 2012 (Bahrain) art 2(b)(1); Labour Market Regulatory Authority 2022, Expatriate Employee Transfer, Kingdom of Bahrain. Available from: https://lmra.bh/portal/en/page/show/194. [1 August 2022].
57Act No. 19 with regard to the Regulation of the Labour Market, 2006 (Bahrain) art 36; Order No. 79 of 2009 with regard to the Procedures for Transfer of a Foreign Worker to Another Employer, 2009 (Bahrain) arts 2 & 3.
58Mohamed, A 2021, ‘The Flexi Permit Experiment: No Kafala, but poor labour practices persist’, Migrant-Rights.Org, 12 April. Available from: https://www.migrant-rights.org/2021/04/the-flexi-permit-experiment-no-kafala-but-poor-labour-practices-persist/. [2 February 2022].
59Human Rights Watch 2012, For a Better Life: Migrant Worker Abuse in Bahrain and the Government Reform Agenda. Available from: https://www.hrw.org/report/2012/09/30/better-life/migrant-worker-abuse-bahrain-and-government-reform-agenda#_ftnref276. [29 August 2022]; Clyde & Co 2020, Comparison of Absconding laws in the GCC, Migrant-Rights.Org. Available from: https://infogram.com/comparison-of-absconding-laws-in-the-gcc-1h7v4pzolky86k0. [20 February 2022].
60Employer must sponsor entry into country: Royal Oman Police 2022, Work Visa. Available from: https://www.rop.gov.om/english/dg_pr_visas_employment.html. [29 August 2022].Employer controls residency / work permit: Royal Decree No. 16/95 issuing the Foreigners Residence Law, 1995 (Oman); Al Barwani, A & Baxter, R 2020, Doing Business in Oman: Overview – Omanisation, Thomson Reuters Practical Law. Available from: https://uk.practicallaw.thomsonreuters.com/w-007-5872?transitionType=Default&contextData=(sc.Default)&firstPage=true#co_anchor_a722207. [29 August 2022].Employer must grant permission for workers to change / leave job: Ministerial Decision 157/2020 Amending Some Provisions of the Executive Regulation of the Foreigners Residency Law, 2020 (Oman).Employer can report worker for absconding: Ministry of Manpower Ministerial Decision No. 270 of 2018 (Oman) art 5.Employer must grant permission for worker to exit country: International Labour Organization 2021, Regulatory framework governing migrant workers: Oman, p. 3. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_776526.pdf. [1 August 2022].
61Ashok, R 2021, ‘Amended Oman law to allow conversion of visit visa to work visa’, Gulf News, 31 May. Available from: https://gulfnews.com/world/gulf/oman/amended-oman-law-to-allow-conversion-of-visit-visa-to-work-visa-1.79585578. [1 August 2022].
62Ministerial Decision 157/2020 Amending Some Provisions of the Executive Regulation of the Foreigners Residency Law, 2020 (Oman).
63Employer must sponsor entry into country: Ministerial Resolution No. (52) for 1989 The Rules and Procedures to be adopted at the Labour permits sections with respect to the recruitment of non-national Labours for the employment in U.A.E, 1989 (United Arab Emirates) art 5.Employer controls residency / work permit: Ministerial Decree No. 360 of 1997 Issuing the Implementing Regulations of Federal Law No. 6 of 1973 Regarding Entry and Residence of Foreigners, 1997 (United Arab Emirates) art 63.Employer must grant permission for workers to change / leave job: Ministerial Decree No. 360 of 1997 Issuing the Implementing Regulations of Federal Law No. 6 of 1973 Regarding Entry and Residence of Foreigners, 1997 (United Arab Emirates) art 68; Federal Law No (6) for 1973 Concerning Immigration and Residence, 1973 (United Arab Emirates) art 11; Ministerial Decision No. 826 of 2005 Regarding the Executive Regulations for the Transfer of Sponsorship, 2005 (United Arab Emirates) arts 6 & 11; Ministerial Decree No. 766 of 2015 on rules and conditions for granting a permit to a worker for employment by a new employer, 2015 (United Arab Emirates) art 1(III).Employer can report worker for absconding: Ministerial Decree No. 721 of 2006 Regarding the Procedures for Reporting Absconding Workers, 2006 (United Arab Emirates); Federal Decree-Law No. 9 of 2022 Concerning Domestic Workers, 2022 (United Arab Emirates) art. 11.Employer must grant permission for worker to exit country: International Labour Organization 2021, Regulatory Framework Governing Migrant Workers. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_776529.pdf. [29 August 2022].
64Government of the United Arab Emirates 2021, Working in Free Zones. Available from: https://u.ae/en/information-and-services/jobs/working-in-free-zones. Laubach, C 2020, A general introduction to immigration law and policy in United Arab Emirates, Lexology. Available from: https://www.lexology.com/library/detail.aspx?g=67895d6e-08cc-4faa-b021-b74a9adb8a72. [1 August 2022].
65Bedirian, R 2016, ‘No need to exit UAE to amend visit visa status’, Gulf News, 4 January. Available from: https://gulfnews.com/uae/government/no-need-to-exit-uae-to-amend-visit-visa-status-1.1648176. [15 August 2022].
66Ministerial Decision No. 951 of 2003 Regarding Investors, 2003 (United Arab Emirates) arts 5 & 6; Ministerial Decision No. 826 of 2005 Regarding the Executive Regulations for the Transfer of Sponsorship, 2005 (United Arab Emirates) arts 6 & 11; Ministerial Decree No. 707 of 2006 Regarding the Rules and Procedures for the Work of Non-nationals in the Country, 2006 (United Arab Emirates) art 13; Ministerial Decree No. 766 of 2015 on rules and conditions for granting a permit to a worker for employment by a new employer, 2015 (United Arab Emirates) art 1(III).
67Federal Decree-Law No. 9 of 2022 Concerning Domestic Workers, 2022 (United Arab Emirates) art. 18.
68Employer must sponsor entry into country: Zahra, M 2019, The Legal Framework of the Sponsorship Systems of the Gulf Cooperation Council Countries: A Comparative Examination, Gulf Labour Markets and Migration, p. 4. Available from: https://gulfmigration.grc.net/media/pubs/exno/GLMM_EN_2019_04.pdf. [13 April 2022]; Kuwaiti Amiri Decree No. 17 of 1959 issuing the Aliens Residence Law, 1959 (Kuwait) art 15 (bis).Employer controls residency / work permit: Human Rights Council 2017, Report of the Special Rapporteur on trafficking in persons, especially women and children, on her mission to Kuwait A/HRC/35/37/Add.1, United Nations, p. 6. Available from: https://www.refworld.org/docid/593a9d554.html. [30 August 2022]. Employer must grant permission for workers to change / leave job: Administrative Decision No. 842 of 2015 regarding the requirements for the transfer of labor from one employer to another, 2015 (Kuwait) art 6; Decree No. 378 of 2016 Regarding the amendment of the decision on the transfer of labor conditions, 2016 (Kuwait) art 1.Employer can report worker for absconding: Law No. 68 of 2015 on Employment of Domestic Workers, 2015 (Kuwait) art 51.Employer must grant permission for worker to exit country: Regulatory Framework Governing Migrant Workers: Kuwait, p. 3. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_776524.pdf. [21 February 2022].
69International Labour Organization 2021, Regulatory Framework Governing Migrant Workers: Kuwait, p. 3. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_776524.pdf. [21 February 2022].
70Employer must sponsor entry into country: Law of 10 July 1962 concerning the entry and stay in Lebanon as well as the exit, 1962 (Lebanon) 25; Decree No. 17561 of 18 September 1964 – regulating the work of aliens, 1964 (Lebanon) arts 2, 4 – 5.Employer controls residency / work permit: Decree No. 17561 of 18 September 1964 – regulating the work of aliens, 1964 (Lebanon) arts 6 & 7; Law of 10 July 1962 concerning the entry and stay in Lebanon as well as the exit, 1962 (Lebanon) art 36; Amnesty International 2019, ‘Their house is my prison’: Exploitation of migrant domestic workers in Lebanon, p. 14. Available from: https://www.amnesty.org/en/wp-content/uploads/sites/9/2021/05/MDE1800222019ARABIC.pdf. [30 November 2021]. Employer must grant permission for workers to change / leave job: in cases of abuse, migrant workers can inform General Security or the Ministry of Labour, who decide on sponsorship transferal; Decree No. 17561 of 18 September 1964 – regulating the work of aliens, 1964 (Lebanon) art 15.Employer can report worker for absconding: International Labour Organization & The Legal Agenda 2020, The labyrinth of justice: Migrant domestic workers before Lebanon’s courts, International Labour Organization, pp. 26-28. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_777078.pdf. [2 February 2022].Employer must grant permission for worker to exit country: International Labour Organization 2021, Regulatory Framework Governing Migrant Workers: Lebanon. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_776525.pdf. [30 August 2022].
71Employer must sponsor entry into country: Law No. 21 of 27 October 2015 which regulates the entry, exit of expatriates and their residence, 2015 (Qatar) art 4. A migrant worker entering Qatar under a work visa must have a signed employment contract with their employer. Employer controls residency / work permit: Law No. 21 of 27 October 2015 which regulates the entry, exit of expatriates and their residence, 2015 (Qatar) arts 8-16. An employer must obtain and renew residence permit for the migrant worker as per the permit procedures. Employer must grant permission for workers to change / leave job: Law No. 18 of 2020 amending certain provisions of Labour Law No. 14 of 2004, 2020 (Qatar) art 1. Workers can change/ leave jobs at any time during their contract period, with dur notice stipulated by the legal frameworks, without prior permission of their employers. Employer can report worker for absconding: Law No. 21 of 27 October 2015 which regulates the entry, exit of expatriates and their residence, 2015 (Qatar) art 19; Clyde & Co 2020, Comparison of Absconding laws in the GCC, Migrant-Rights.Org. Available from: https://infogram.com/comparison-of-absconding-laws-in-the-gcc-1h7v4pzolky86k0. [20 February 2022]. Employer has to notify the competent authority within 14 days from the date on which the worker left the employer or abstained from leaving the country following the revocation of his/her residency permit or its expiry. Employer must grant permission for worker to exit country: 2020, ‘Qatar: Significant Labor and Kafala Reforms’, Human Rights Watch, 24 September. Available from: https://www.hrw.org/news/2020/09/24/qatar-significant-labor-and-kafala-reforms. [2 November 2020]; Law No. 13 of 2018 amending some provisions of Law No. 21 of 2015, 2018 (Qatar) art 1; Interior Minister Decision No. (95) Of 2019 regarding controls and procedures for the exit of some categories of expatriates who are not subject to the labour law, 2019 (Qatar). Almost all migrant workers can leave the country temporarily or permanently without prior approval from their employer. Exceptions apply to certain groups of workers such as members of the armed forces and up to five percent of staff in key positions such as chief executive or financial officers, directors of supervising daily operations and directors of information and communication technology. 
72Ministry of Administrative Development Labour & Social Affairs 2022, Changing employers in Qatar: Key information for workers, Government of Qatar. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_754449.pdf. [1 August 2022].
73Law No 13 of 2018 amending some provisions of Law No. (21) of 2015 which regulates the entry and exit of expatriates and their residence 2018 (Qatar). Almost all migrant workers can leave the country temporarily or permanently without prior approval from their employer. Exceptions apply to certain groups of workers such as members of the armed forces and up to five percent of staff in key positions such as chief executive or financial officers, directors of supervising daily operations and directors of information and communication technology.
74Interior Minister Decision No. (95) Of 2019 regarding controls and procedures for the exit of some categories of expatriates who are not subject to the labour law, 2019 (Qatar); 2020, ‘Qatar: Significant Labor and Kafala Reforms’, Human Rights Watch, 24 September. Available from: https://www.hrw.org/news/2020/09/24/qatar-significant-labor-and-kafala-reforms. [2 November 2020].
75Employer must sponsor entry into country: Labour Law (Royal Decree No. M/51), 2006 (Saudi Arabia) art 33; Residence Regulations No. 17/2/25/1337, 1952 (Saudi Arabia) art 5.Employer controls residency / work permit: Labour Law (Royal Decree No. M/51), 2006 (Saudi Arabia) art 33; Labour Law (Royal Decree No. M/51), 2006 (Saudi Arabia) art 33; Residence Regulations No. 17/2/25/1337, 1952 (Saudi Arabia) arts 5, 11 & 12.Employer must grant permission for workers to change / leave job: International Labour Organization 2021, Regulatory Framework Governing Migrant Workers: Saudi Arabia. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_776522.pdf. [1 August 2022].Employer can report worker for absconding: Residence Regulations No. 17/2/25/1337, 1952 (Saudi Arabia) art 11; Ministerial Decision No. 310 of 1434, (Saudi Arabia) art 13.Employer must grant permission for worker to exit country: International Labour Organization 2021, Regulatory Framework Governing Migrant Workers: Saudi Arabia. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_776522.pdf. [1 August 2022].
76Ministry of Human Resources and Social Development 2020, Ministry of Human Resources and Social Development Launches Labor Reforms for Private Sector Workers, Government of Saudi Arabia. Available from: https://hrsd.gov.sa/en/news/ministry-human-resources-and-social-development-launches-labor-reforms-private-sector-workers. [1 August 2022].
77International Labour Organization 2021, Regulatory Framework Governing Migrant Workers: Saudi Arabia. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_776522.pdf. [1 August 2022]; Ministerial Decision No. 605, dated 15/5/1438 H., 2017 (Saudi Arabia).
78Ministerial Decision No. 51848 of 1442, 2020 (Saudi Arabia); Ministry of Human Resources and Social Development 2020, Labor Reform Initiative (LRI) Services Guidebook, Government of Qatar, pp. 4-6. Available from: https://hrsd.gov.sa/sites/default/files/1112020.pdf. [1 August 2022].
79Labor Law, 2006 (Royal Decree No. M/51) (Saudi Arabia) art 7; Residence Regulations, 1952 (No. 17/2/25/1337 of 1952) (Saudi Arabia) art 14.
80Employer must sponsor entry into country: Law No. 24 of 1973 on Residence and Foreigners’ Affairs 1973 (Jordan) arts 16 & 26; Labour Law and its Amendments No. 8 of the Year 1996, 1996 (Jordan) art 12.Employer controls residency / work permit: Law No. 24 of 1973 on Residence and Foreigners’ Affairs 1973 (Jordan) arts 16, 22, 26 & 34; Labour Law and its Amendments No. 8 of the Year 1996, 1996 (Jordan) art 12.Employer must grant permission for workers to change / leave job: Labour Law and its Amendments No. 8 of the Year 1996, 1996 (Jordan) arts 12, 21, 23, 26, 29.Employer can report worker for absconding: Regulation No. 90/2009 of Domestic Workers, Cooks, Gardeners and Similar Categories, 2009 (Jordan) art 5; Gordon, J 2020, The Obstacles to Decent Work for Migrants in Jordan: A Discussion with Alia Hindawi, Civil Society Knowledge Centre. Available from: https://civilsociety-centre.org/paper/obstacles-decent-work-migrants-jordan-discussion-alia-hindawi. [13 February 2022].Employer must grant permission for worker to exit country: Law No. 24 of 1973 on Residence and Foreigners’ Affairs 1973 (Jordan) art 4; Regulation No. 90/2009 of Domestic Workers, Cooks, Gardeners and Similar Categories, 2009 (Jordan) art 8.
81Labour Law and its Amendments No. 8 of the Year 1996, 1996 (Jordan) arts 12, 21, 23, 26, 29.
82For example: Hong Kong, Singapore, Taiwan.
83Gulf Labour Markets and Migration 2022, GCC: Percentage of nationals and non-nationals in employed population in GCC countries (2020), Gulf Research Center. Available from: https://gulfmigration.grc.net/gcc-emp-1-1-percentage-of-nationals-and-non-nationals-in-employed-population-in-gcc-countries-2016/. [7 July 2022]; International Labour Office 2021, ILO Global Estimates on International Migrant Workers: Results and Methodology, International Labour Organization, pp. 30-31. Available from: https://www.ilo.org/wcmsp5/groups/public/@dgreports/@dcomm/@publ/documents/publication/wcms_808935.pdf. [26 August 2022].
84Pattisson, P & McIntyre, N 2021, ‘Revealed: 6,500 migrant workers have died in Qatar since World Cup awarded’, The Guardian, 23 February. Available from: https://www.theguardian.com/global-development/2021/feb/23/revealed-migrant-worker-deaths-qatar-fifa-world-cup-2022. [2 February 2022].
852021, ‘Qatar: World Cup contractors allegedly misusing visas to recruit Nepali workers left vulnerable to contract substitution & fee-charging; incl. Supreme Committee & co. responses’, Business & Human Rights Resource Centre, 6 September. Available from: https://www.business-humanrights.org/en/latest-news/qatar-world-cup-contractors-allegedly-misusing-visas-to-recruit-nepali-workers-left-vulnerable-to-contract-substitution-fee-charging-incl-supreme-committee-co-responses/?mc_cid=f45959fa24&mc_eid=a18fa05e7c. [2 February 2022]; Business & Human Rights Resource Centre 2021, Checked Out: Migrant Worker Abuse in Qatar’s World Cup Luxury Hotels. Available from: https://media.business-humanrights.org/media/documents/2021_Qatar_Hotels_v547.pdf. [30 November 2021]; Amnesty International 2022, ‘They think that we’re machines’: Forced labour and other abuse of migrant workers in Qatar’s private security sector. Available from: https://www.amnesty.org/en/documents/mde22/5388/2022/en/. [13 April 2022].
86Cockayne, J 2021, Developing Freedom: The Sustainable Development Case for Ending Modern Slavery, Forced Labour and Human Trafficking, United Nations University, p. 221. Available from: https://www.developingfreedom.org/wp-content/uploads/2021/01/DevelopingFreedom_MainReport_WebFinal.pdf. [2 February 2022].
87ILO Project Office for the State of Qatar 2021, Progress report on the technical cooperation programme between the Government of Qatar and the ILO, International Labour Organization. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/—ilo-qatar/documents/publication/wcms_832122.pdf. [2 February 2022].
88Amnesty International 2020, Reality Check 2020: Countdown to the 2022 World Cup Migrant Workers’ Rights in Qatar, p. 7. Available from: https://www.amnesty.org/en/wp-content/uploads/2021/05/MDE2232972020ENGLISH.pdf. [31 January 2022].
89 Workers can depart without permission, however, employers can apply for up to 5 per cent of employees to require prior approval; Interior Minister Decision No. (95) Of 2019 regarding controls and procedures for the exit of some categories of expatriates who are not subject to the labour law, 2019 (Qatar).
90Interior Minister Decision No. (95) Of 2019 regarding controls and procedures for the exit of some categories of expatriates who are not subject to the labour law, 2019 (Qatar) ; Law No. 19 of 2020 amending certain provisions of Law No. 21 of 2015 related to organizing the entry and exit of expatriates and their residence 2020 (Qatar) ; Law No. 18 of 2020 amending certain provisions of Labour Law No. 14 of 2004, 2020 (Qatar) art 1,
912021, ‘Job mobility in Qatar is still a mirage despite reforms; domestic workers most affected’, Migrant-Rights.Org, 5 October. Available from: https://www.migrant-rights.org/2021/10/job-mobility-in-qatar-is-still-a-mirage-despite-reforms-domestic-workers-most-affected/. [2 February 2022]; Business & Human Rights Resource Centre 2021, Checked Out: Migrant Worker Abuse in Qatar’s World Cup Luxury Hotels. Available from: https://media.business-humanrights.org/media/documents/2021_Qatar_Hotels_v547.pdf. [30 November 2021].
92Amnesty International 2020, Reality Check 2020: Countdown to the 2022 World Cup Migrant Workers’ Rights in Qatar, p. 15. Available from: https://www.amnesty.org/en/wp-content/uploads/2021/05/MDE2232972020ENGLISH.pdf. [31 January 2022].
93Amnesty International 2022, ‘They think that we’re machines’: Forced labour and other abuse of migrant workers in Qatar’s private security sector. Available from: https://www.amnesty.org/en/documents/mde22/5388/2022/en/. [13 April 2022]; Business & Human Rights Resource Centre 2022, FIFA World Cup Qatar 2022 Parallel Portal. Available from: https://www.business-humanrights.org/en/from-us/fifa-world-cup-qatar-2022-parallel-portal/. [13 April 2022].
94Amnesty International 2022, Joint letter to Gianni Infantino: Remedy for abuse of migrant workers’ rights in Qatar. Available from: https://www.hrw.org/sites/default/files/media_2022/05/2022.05.17.Joint%20letter%20to%20Gianni%20Infantino%20re.%20remedy%20for%20labour%20abuses.pdf. [21 December 2022]; Human Rights Watch 2022, Migrant Workers Who Delivered FIFA World Cup in Qatar Suffered Harm. Tell FIFA to Pay Up Now. Available from: https://www.hrw.org/PayUpFIFA. [21 December 2022].
95Amnesty International 2022, ‘FIFA misleading world on remedy for migrant workers’, 12 December. Available from: https://www.amnesty.org/en/latest/news/2022/12/fifa-misleading-world-on-remedy-for-migrant-workers/. [21 December 2022]; Amnesty International 2022, ‘Qatar: Nepali civil society groups denounce FIFA’s continued dismissal of migrant workers’ compensation claims’, 15 December. Available from: https://www.amnesty.org/en/latest/news/2022/12/qatar-nepali-civil-society-groups-denounce-fifas-continued-dismissal-of-migrant-workers-compensation-claims/. [21 December 2022].
962020, ‘Oman eases restrictions on sponsorship transfer’, Migrant-Rights.Org, 8 June. Available from: https://www.migrant-rights.org/2020/06/oman-eases-restrictions-on-sponsorship-transfer/. [3 November 2020]; 2020, ‘Oman to scrap NOC requirement for expat workers’, Arab News, 17 June. Available from: https://www.arabnews.com/node/1690991/middle-east. [13 February 2022].
972020, ‘Saudi Arabia eases ‘kafala’ system restrictions on migrant workers’, BBC News, 4 November. Available from: https://www.bbc.com/news/world-middle-east-54813515. [5 November 2021].
982021, ‘Saudi Arabia: Labor Reforms Insufficient’, Human Rights Watch, 25 March. Available from: https://www.hrw.org/news/2021/03/25/saudi-arabia-labor-reforms-insufficient. [16 February 2022].
99Ministerial Decree No. 766 of 2015 on rules and conditions for granting a permit to a worker for employment by a new employer, 2015 (United Arab Emirates) art 1(III); International Labour Organization 2021, Regulatory Framework Governing Migrant Workers. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_776529.pdf. [29 August 2022].
100Mohamed, A 2021, ‘The Flexi Permit Experiment: No Kafala, but poor labour practices persist’, Migrant-Rights.Org, 12 April. Available from: https://www.migrant-rights.org/2021/04/the-flexi-permit-experiment-no-kafala-but-poor-labour-practices-persist/. [2 February 2022].
101Labour Market Regulatory Authority 2020, Flexi Permit, Government of Bahrain. Available from: http://lmra.bh/portal/en/page/show/325. [3 November 2020]; Mohamed, A 2021, ‘The Flexi Permit Experiment: No Kafala, but poor labour practices persist’, Migrant-Rights.Org, 12 April. Available from: https://www.migrant-rights.org/2021/04/the-flexi-permit-experiment-no-kafala-but-poor-labour-practices-persist/. [2 February 2022].
1022021, ‘Bahrain’s Flexi-Permit workers reportedly pay high residence fees and do not benefit from labour law protection’, Business & Human Rights Resource Centre, 12 April. Available from: https://www.business-humanrights.org/en/latest-news/bahrains-flexi-permit-workers-reportedly-pay-high-residence-fees-and-do-not-benefit-from-labour-law-protection/. [16 February 2022]; De Bel-Air, F 2018, Demography, Migration, and the Labour Market in Bahrain (Demography, Migration, and the Labour Market in Bahrain, Explanatory Note No 1/2019, Gulf Labour Markets and Migration, p. 6. Available from: https://gulfmigration.grc.net/media/pubs/exno/GLMM_EN_2019_01.pdf. [14 February 2022].
103Mohamed, A 2021, ‘The Flexi Permit Experiment: No Kafala, but poor labour practices persist’, Migrant-Rights.Org, 12 April. Available from: https://www.migrant-rights.org/2021/04/the-flexi-permit-experiment-no-kafala-but-poor-labour-practices-persist/. [2 February 2022].
104As above.
105HRH Prince Salman bin Hamad Al Khalifa 2022, ‘Bahrain Announces New Measures to Update Expatriate Worker Permits and Further Increase Protections’, Crown Prince, Deputy Supreme Commander of the Armed Forced and Prime Minister, 5 October. Available from: http://www.crownprince.bh/en/media-centre/news/13995/2022/10/5/Bahrain-Announces-New-Measures-to-Update-Expatriate-Worker-Permits-and-Further-Increase-Protections. [20 December 2022].
106Labour Market Regulatory Authority 2022, LMRA: The Launch of the New Labour Registration Program, Kingdom of Bahrain. Available from: http://blog.lmra.bh/en/2022/12/03/lmra-the-launch-of-the-new-labour-registration-program/. [20 December 2022]; Amir, KA 2022, ‘Switching jobs, labour recruitment made easier in new Bahrain reforms’, Gulf News, 6 October. Available from: https://gulfnews.com/world/gulf/bahrain/switching-jobs-labour-recruitment-made-easier-in-new-bahrain-reforms-1.91087912. [20 December 2022].
107Reforms to Bahrain’s Flexi-Permit system took place outside of the government response assessment period for the 2022 Global Slavery Index and are therefore not reflected in Bahrain’s government response score.
108Resolution No. (1) of 2022 regarding assigning some tasks of the Labor Market Regulatory Authority to labor registration centers, 2022 (Bahrain) art. 5; Labour Market Regulatory Authority 2022, General Questions for the Labour Registration Program, Kingdom of Bahrain. Available from: https://lmra.bh/portal/en/page/show/428. [20 December 2022].
109As above.
1102022, ‘Bahrain launches new Labour Registration Program to replace Flexi-Permit’, Migrant-Rights.Org, 12 December. Available from: https://www.migrant-rights.org/2022/12/bahrain-launches-new-labour-registration-program-to-replace-flexi-permit/. [20 December 2022].
111Labour Market Regulatory Authority 2022, ‘LMRA and Ministry of Interior Conduct Joint Inspection Campaigns’, Kingdom of Bahrain, 12 December. Available from: http://blog.lmra.bh/en/2022/12/12/lmra-and-ministry-of-interior-conduct-joint-inspection-campaigns-4/. [20 December 2022].
112Kagan, S 2017, Domestic Workers and Employers in the Arab States, International Labour Organization, pp. 6-7. Available from: https://www.ilo.org/wcmsp5/groups/public/—arabstates/—ro-beirut/documents/publication/wcms_619661.pdf. [11 February 2022]. Kalush, R, Saraswathi, V, Mohamed, A & Fousdeen, F 2019, Lived Experience of Migrant Women: Qatar, Bahrain, and Kuwait, Migrant-Rights.Org, p. 6. Available from: https://respect.international/wp-content/uploads/2019/12/Lived-Experience-of-Migrant-Women-Quatar-Bahrain-and-Kuwait.pdf. [2 February 2022].
1132020, ‘Lebanon takes crucial first step towards dismantling Kafala in Lebanon’, International Labour Organization, 10 September. Available from: https://www.ilo.org/beirut/media-centre/news/WCMS_755008/lang–en/index.htm#:~:text=BEIRUT%20%E2%80%93%20(ILO%20News)%20Lebanon,and%20elsewhere%20across%20the%20region. [2 February 2022].
114Dagher, J, Wood, D & Boswall, J 2020, Cleaning Up: The Shady Industries that Exploit Lebanon’s Kafala Workers, Triangle, p. 2. Available from: https://www.thinktriangle.net/wp-content/uploads/2020/11/Cleaning-Up-The-Shady-Industries-That-Exploit-Lebanons-Kafala-Workers-1.pdf. [2 February 2022].
115Law No. 24 of 1973 on Residence and Foreigners’ Affairs 1973 (Jordan) art 4; Regulation No. 90/2009 of Domestic Workers, Cooks, Gardeners and Similar Categories, 2009 (Jordan) art 8.
116As above.
117Fundamental Principles and Rights at Work Branch 2017, Migrant domestic and garment workers in Jordan: A baseline analysis of trafficking in persons and related laws and policies, International Labour Organization, p. 24. Available from: https://www.ilo.org/wcmsp5/groups/public/—ed_norm/—declaration/documents/publication/wcms_554812.pdf. [14 February 2022].
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