The Financial Audit Authority (FAA) has issued three new regulatory decisions, published in Dubai Official Gazette, Issue No. 719 dated 27 May 2025, aimed at enhancing public sector governance and accountability. These decisions introduce new protections for whistleblowers, streamline procedures for minor criminal investigations, and establish a unified framework for disciplinary and grievance mechanisms within FAA-regulated entities.
1- Decision No. (2) of 2025: Whistleblower Employment Protection Introduced
The Financial Audit Authority (FAA) has issued Decision No. (2) of 2025 to regulate the procedure and mechanisms for public service whistleblowers while filing reports and the associated employment protections for the same. The objective of this structured framework is focused on the protection of public funds, protection of job status in administrative decisions and regulation of procedure for employees.
One of the key features includes the establishment of a dedicated register for accepted and archived requests without the fear of retaliation (Article 6). Protection measures are clearly set out, including confidentiality of the whistleblower’s identity upon submission of the protection request and a prohibition on any retaliatory administrative action unless the report is found to be malicious or amounts to a criminal offence (Article 7). This move is intended to enhance transparency and accountability in the workplace, while safeguarding individuals who report misconduct in good faith as well as providing a safe pathway to express grievances against decisions and procedures against subject entities (Article 8).
2- Decision No. (3) of 2025: Streamlining Investigations into Minor Criminal Offences
Decision No. (3) of 2025 sets out objective criteria to determine whether a case involving minor criminal offences should be escalated to the Public Prosecution or handled administratively. The key considerations include absence of financial harm to public funds, lack of intent, or abuse of position (Article 2). The decision further states that any investigation into the violation must meet the criteria of Article 2 and where the resolution must be preserved by the decision of the Director General with the investigation deposited in the special registrar prepared by the authority. If a decision is made to preserve the investigation, it should include a description of the committed violation, its seriousness and any resulting damages associated with it (Article 3).
The decision further highlights that the provisions of the resolution must not prejudice the FAA to re-start any investigation procedures (Article 4) holding the Executive Director responsible for issuance of executive decisions (Article 5) with this decision being effective from the publication of the Official Gazette (Article 6). When an investigation is closed, the FAA is required to issue a reasoned decision, which must be recorded in a dedicated register (Article 3). This framework seeks to optimise the use of legal resources and expedite resolution of low-risk matters.
3- Decision No (4) of 2025: On the Approval of the Work System of the Central Violations Committee and the Grievance Committee at the Financial Audit Authority
The FAA has issued Decision No. (4) of 2025, which establishes the operating procedures for the Central Violations Committee and the Grievance Committee. This decision introduces a unified procedural framework for handling disciplinary and grievance matters within FAA-regulated entities. The scope of this decision covers to employees under the control of the FAA as well as officials of the corporations and businesses governed by the FAA particularly those holding title of ‘Executive Director’. The primary objective of the decision is to impose a disciplinary penaltyies in a manner that safeguards the rights and obligations of the employee (Article 2) as well as outlines the obligations, requirements and powers of the Violation’s Committee (Article 3). It encourages the Violations Committee to conduct sessions and decisions requiring the presence of members and the need to record and reason minutes of the meeting (Article 5).
The decision also assigns and allocates a rapporteur for the Violations Committee which is selected from employee of the FAA appointed by the Director General of the FAA. Their key responsibilities range from sending invitations, preparing relevant agendas for the Violations Committee, notifying employees of the date of the session scheduled, preparation of the register of violations and any other duties assigned by the chairman of the Violations Committee (Article 6). The decision outlines the procedures for considering ad deciding on the violation which includes notifying the subject entity in writing of the violation attributed to the employee and allowing the employee to review all documents related to the investigation (Article 7), the data that should be included in the administrative investigation record such as details of violation, statements of defence and witnesses and signature of the employee and chairman (Article 8). The decision provides greater clarity towards the imposition and implementation of the penalty such as the penalty being imposed on relevant grounds and to correspond to the nature and severity of the violation committed (Article 9).
The third chapter of the decision outlines the key requirements of Grievance Committee members ensuring that they are not members of the Violation Committee, and the need for the job grades of the Chairman of the Grievance Committee to not be less than the job grade of the employee filing for the grievance (Article 10). The Decision also highlights the powers of the Grievance Committee has regarding the conduct of supplementary investigations, hearing of statements and seeking assistance without granting the right to vote in deliberations (Article 12). Note that the deadline for filing an application of grievance is 15 working days from the date of notification of the employee of the decision subject matter of the grievance (Article 13). There are also repercussions for failure to attend sessions (Article 17) as these legislative provisions are binding on both the employee and the employer with confidentiality as the paramount consideration (Article 21 & 22).
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For more information on how any of these developments may affect your organisation or your clients, please contact Suneer Kumar, Head of Corporate Practice on suneer@alsuwaidi.ae and Vida Grace Serrano, Corporate Senior Associate on Vida@alsuwaidi.ae.
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