Qatar's New Law Concerning Persons with Disabilities

The one-year deadline for facility modifications, the new and immediate duty to provide reasonable accommodations and the strict privacy protections mean that businesses must act now to avoid the fines and penalties associated with failing to comply with the new requirements.

This note addresses some of those primary issues from an employment/labor, privacy and real estate perspective.   Of particular note for landlords and or business owners is the fact that they will have one year from 6 October 2025 to introduce any necessary facility modifications.

The detail

Qatar has introduced Law No. 22 of 2025 Concerning Persons with Disabilities (the “Law”), which came into effect on 6 October 2025, marking a significant evolution in Qatar's approach to disability rights and workplace inclusion. This new legislation repeals the previous Law No. 2 of 2004 and introduces comprehensive obligations for businesses operating in Qatar to ensure inclusion, equality and accessibility for persons with disabilities across public and working life.   

In this briefing note we address the employment, privacy and core real estate considerations flowing from the introduction of the Law.

What is the effect of the Law?

The Law establishes enhanced statutory entitlements and protections for people with disabilities living and working in Qatar across multiple domains including:

• Personal liberty, freedom of movement, and personal security, with prohibition of all forms of violence or exploitation;
• Right to privacy and non-interference in personal affairs, with prohibition on publishing health or rehabilitation information without free and informed consent;
• Equal opportunities, including employment opportunities for persons in line with their abilities, qualifications, and rehabilitation across all sectors of the labor market, with a new positive duty on employers to make reasonable accommodations to enable individuals to perform their work and the right for an individual not to be deprived of any benefits or rights generally granted to employees in the entities in which they work;
• The right to access without obstacles, buildings, facilities, technological systems and means of communication; 
• Educational opportunities at all stages commensurate with abilities, with reasonable accommodations required; and
• Healthcare and rehabilitation services commensurate with the extent of disability, including preventive, therapeutic, health, and psychological services.

Who is protected under the Law?

The Law defines a "Person with Disability" as ‘any person who has a long-term physical, mental, intellectual, or sensory impairment that prevents full and effective participation in society’, with an impairment considered long-term if ‘it is not expected to disappear within a period not less than 12 months from the start of treatment and rehabilitation’. 

Action point: This broad definition means businesses must consider hidden health conditions and not focus on an individual proving a disability to preventing discrimination, but rather proactively assess accessibility to their services, premises and IT presence and assume that the duty to make reasonable accommodations applies in most cases - therefore prioritising inclusion.

What does this mean and what are the risks of non-compliance?

Any act or omission that entails discrimination or inequality on the basis of disability is unlawful, and a failure to make reasonable accommodations is now deemed a form of discrimination. The Law does not address what, if any, recourse a disabled person may have in terms of a personal claim relating to disability discrimination and so this remains to be seen. 

Violating the new Law attracts significant penalties, including fines of up to 100,000 QAR (equivalent of circa $27,500)and or imprisonment of up to six months.  Penalties can also apply to both individual managers and companies. In certain cases, such as those involving neglect, exploitation, and or abuse, imprisonment can be for up to five years and fines of up to QR 500,000 could be imposed. 

Aside from the penalties set out in the Law, there is also a reputational risk for businesses, both internally within the business and externally, if a business is found to have been discriminatory.

The duty for employers to make reasonable accommodations – a closer look

One of the most significant and new requirements for businesses is the positive duty to provide reasonable accommodations in recruitment and employment, so that persons with disabilities can access jobs on an equal basis, perform their roles effectively, and access employment opportunities, benefits and rights without disadvantage. "Reasonable accommodations" are any adjustments necessary to ensure enjoyment of rights without undue burden. In practice, this means:

• at recruitment, selection, and onboarding, employers must consider adjusting their recruitment processes and assessments so that candidates with disabilities can demonstrate their capability on an equal basis; and 
• during employment, employers must make timely modifications to duties, policies, equipment, schedules, or environments and ensure that employees with disabilities are not deprived of any rights or benefits generally granted to employees.

Unlike in other jurisdictions, such as in the United Kingdom (“UK”), where the duty to make adjustments only arises when an employer knows or ought reasonably to know that an individual is disabled, the duty to make adjustments under the new Law does not include this ‘knowledge’ requirement.  On the face of it this means that the duty to make accommodations  an unconditional and positive, proactive, obligation upon businesses, meaning that businesses need to actively assess and consider whether any accommodations are necessary and adapt working practices to comply.

Action points: Businesses should:

• Establish a person or team responsible for compliance, likely involving HR, facilities, legal and, potentially, occupational health.
• Conduct comprehensive audits of employment practices and policies.
• Develop or align existing policies in relation to reasonable accommodations, privacy and non-discrimination.
• Begin and maintain continuous training programmes for managers and staff.
• Regularly review compliance with privacy and non-discrimination requirements.

Businesses will also likely need to invite individuals to confirm if they require any reasonable accommodation/s to participate in a recruitment process and also consider how and when information relating to an individual’s disability and or any accommodations that they require will be collated and stored for both third parties and for existing employees (see Privacy Considerations below).

What may reasonable accommodations include?

Reasonable accommodations should be tailored to the individual, proportionate to the job’s inherent requirements, and effective in removing specific barriers faced by the individual. They may include:

• Physical and environmental modifications such as accessible workstations, ramps, lifts, ergonomic seating, height-adjustable desks, tactile signage, and accessible restrooms;
• Assistive technologies and digital accessibility measures, including screen readers, magnifiers, captioning, speech-to-text tools, alternative input devices, and accessible software interfaces that comply with recognized standards;
• Work organisation changes such as reallocating marginal tasks, offering flexible hours or phased return-to-work schedules, modifying shift patterns, altering pace or quotas where appropriate, or allowing remote or hybrid arrangements where that does not compromise safety or essential job performance;
• Role-specific adjustments such as alternative testing methods in assessments, job coaching, task breakdowns, or changes to communications protocols (for example, providing sign language interpretation or materials in Braille); or
• Health and safety adaptations, including customized PPE, reduced exposure to specific hazards, or engineered controls informed by risk assessment.

Action points: Businesses should record decisions, the rationale for chosen accommodations, and any alternatives considered, to demonstrate diligence and fairness.  The Law does not provide detail of what, if any, justification will be permissible for not implementing accommodations, however, having an internal note and record of the considerations will, in our view, be critical.

Businesses also need to carefully and proactively audit all employment practices in the context of the duty to make reasonable accommodations, even when applying the current provisions of the labour law. Taking, for example, Article 82 of the labour law, which permits termination of an employee’s employment at the end of the twelfth week of sick leave if a competent physician certifies that the employee is unable to resume work. In light of the new duty to provide reasonable accommodations and the express prohibition on denying accommodations, employers arguably should no longer apply Article 82 automatically where, or if, the employee’s sickness absence relates to a disability. It will be interesting to see whether amendments are made to the labour law and or any other laws in time, to reflect/complement this duty and the obligations set out in the new Law.

How can occupational health help employers meet their legal duty to make reasonable accommodations?

Businesses already have a legal duty to provide a safe  workplace and Qatar’s National Guidelines for Occupational Health Assessment provide useful guidance and a practical, legally compliant framework.  This framework, together with utilising support from occupational health specialists will play a crucial role in helping employers comply with their legal duty to make reasonable accommodations, by assisting employers with identifying needs and implementing accommodations in a way that protects both the worker and the organisation. Four elements are especially useful:

1. Risk assessment and job hazard analysis

Occupational health professionals can work with businesses to conduct risk assessments and job hazard analyses that identify barriers posed by tasks, tools, environments, and processes. Risks can then be controlled through elimination/substitution, engineering controls, safe work methods and training, PPE, and health surveillance. These controls often function as accommodations when adapted to a worker’s disability, for example, by using engineered solutions to reduce physical exertion or vibration exposure for someone with a musculoskeletal or neurological condition.

2. Fitness for work assessment and tailored recommendations

Occupational health assessments pre-employment, periodic, episodic (after long absence or job change), and for end-of-service evaluation of an individual’s functional capacity in the context of job demands can be extremely useful tools for employers. The guidelines emphasize that such assessments are objective, based on job-related testing and provide a clear fitness classification: fit, fit with restrictions, temporarily unfit, or permanently unfit. “Fit with restrictions” will be the operative category for reasonable accommodations and occupational health physicians may specify precisely what tasks an employee can and cannot do, for how long, and under what conditions, avoiding vague advice like “light duties”, enabling businesses to implement practicable adjustments consistent with the new Law.

3. Rehabilitation and return-to-work planning

Where disability relates to illness or injury, occupational health specialists can design phased or transitional duties, schedule modifications, equipment changes, and training to support safe, sustainable return-to-work. The national guidelines encourage time-bound plans, measurable milestones, and feedback loops that adjust accommodations as the worker recovers or stabilizes.

4. Health surveillance, confidentiality, and record-keeping

For roles involving exposure to particular hazards, occupational health surveillance programs can monitor for early signs of harm, helping employers adjust tasks or controls proactively. The guidelines require medical examinations to be conducted free of charge and during working hours, and they set strict confidentiality and record-keeping standards. Employers can receive outcome-focused advice (fitness status and restrictions) without unnecessary disclosure of medical details, protecting the worker’s privacy while enabling lawful, effective accommodations.

Action point: Businesses should consider how they can use occupational health and establish occupational health protocols for assessing and implementing accommodations.  Our experience informs that providing clear, detailed and complete information about the nature of the business, the particular role requirements and the working environment together with expressly asking the questions you need the occupational health advisor to answer greatly enhance the practical value of the report to the business.

How do employees raise concerns?

The Law contains express provision that a person with a disability, or their legal representative, has the right to submit grievances and complaints to the relevant department within the Ministry of Social Development and Family regarding any of the rights established under the Law and the decisions implementing it. Albeit, whether an individual will be able to seek compensation or any other outcome for their own benefit again remains to be seen. 

In practical terms we recommend that businesses update their internal policies to sign-post the use of internal grievance processes and procedures as a first step if an individual has concerns about their treatment.  Ideally businesses and the employee (with the support of Occupational Health where necessary) can address and resolve any concerns before a formal grievance or complaint is raised.

Action point: Businesses should review and update, or prepare  existing internal grievance procedures to ensure that they have a meaningful opportunity to address concerns before they escalate to formal external complaints.

Employment Quotas

The Law sets out that the Council of Ministers shall also issue a decision setting out mandatory employment quotas for persons with disabilities - specifying the percentage of total jobs in government entities and in the private sector that shall be allocated to persons with disabilities who hold applicable certificates or cards, and the decision shall also determine the mechanisms and procedures for implementation of this. 

This decision has not yet been published but we anticipate that given the reference to quotas that positive discrimination may be permitted in the future if it is as a step to ensure adherence with the quota requirements.

Action point: Businesses should keep a watching brief for the decision when issued,  and ensure that they know what quota/s will apply to them and also ensure that they are in a position to comply with such quotas when they are confirmed. Preparation should include building inclusive recruitment practices with accessible job descriptions and application systems, creating an interactive process with candidates and ensuring that staff are properly trained to manage the process.

Data Privacy considerations

Article 5 of the Law establishes privacy protections for persons with disabilities by specifically prohibiting the publication of information, images, or visual material concerning a person’s health condition, rehabilitation status, or any other private matter, unless free and informed consent has been obtained. This complements Qatar’s data protection regime under Law 13/2016 on the Protection of Personal Data Privacy (“PDPL”), which classifies health-related data as sensitive data and requires enhanced safeguards.

To comply with the requirements of both the Law and the PDPL, organisations that collect, process and/or disclose disability-related data (such as employers handling data on their job applicants’ and employees’ disabilities) must obtain the relevant individual’s consent and secure authorisation from the National Cyber Security Agency.

The dual protection afforded by both the Law and the PDPL creates a robust safeguard against unauthorised disclosure of health-related information, ensuring that persons with disabilities maintain control over their health data and preventing potential discrimination or exploitation that could arise from unauthorised publication. By explicitly extending protection to information about rehabilitation and other private matters beyond just an individual’s health condition, Article 5 recognises the broader privacy interests of persons with disabilities and complements the data protection law's comprehensive approach to safeguarding sensitive personal data.

Violations of the privacy provisions in the Law are punishable by a fine not exceeding 50,000 QAR (circa $13,750), making compliance a serious financial imperative.

Action points: Businesses should therefore:

• Ensure that adequate privacy considerations are taken into account when developing recruitment practices and questions asked at the recruitment and or interview stage
• Establish secure systems for storing disability-related information
• Limit access to such information on a strict need-to-know basis
• Train HR and management on confidentiality obligations
• Obtain explicit consent before sharing any health or disability information
• Ensure all communications about accommodations respect the individual’s privacy

Access to facilities

Real estate and accessibility: immediate obligations and market impact

The Law adopts universal design as the guiding standard across the built environment and services, defining accessibility to include:

• Physical spaces;
• Transport;
• Facilities; and
• Information and Communication Technology.

Public bodies with legal responsibility for implementing the Law are tasked with aligning design and implementation with approved national standards. Critically, there is a one year compliance window from entry into force for government entities providing services to the public to modify existing facilities and provide reasonable accommodations, and this obligation is expressly extended to non-government entities. This one-year compliance window has commenced, meaning all such remedial actions should be taken before 5 October 2026 to comply with the Law.

Non-compliance with facility modification requirements may attract fines of up to QAR 50,000.

For businesses, the practical imperative is a staged compliance programme. It is recommended to undertake portfolio wide audits of entrances, circulation, lifts, sanitary provision, life safety systems, signage, parking and interfaces with transport, and extend the review to digital and ICT touchpoints (websites, apps, kiosks, intercoms).

The real estate market should expect closer engagement with authorities on approvals and inspections, heightened scrutiny at planning and completion, and a near term retrofit surge that may tighten contractor capacity and extend lead times.

Compared with the UK (where we have seen similar requirements under the Equality Act to make reasonable adjustments to premises), Qatar’s regime is more time bound and prescriptive, driven by the universal one year retrofit expectation and explicit administrative fines. Market effects are therefore likely to be sharper and front loaded and may include accelerated capex cycles, temporary yield softening for non-compliant stock, and a premium for newly built or swiftly remediated assets. Over time, convergence towards UK style practice is likely in substance, embedding accessibility from concept and planning, normalising inclusive design in specifications, and using asset level audits and tenant engagement to evidence “reasonableness” but with heightened attention to ICT accessibility, as part of the occupier and consumer experience.

Action points: Businesses should conduct comprehensive audits of their physical facilities and digital systems, complete facility modifications to meet accessibility requirements and implement digital accessibility measures across all IT systems.

Developers should consider:

• scoping and tendering capital works early to meet the one year deadline and deploying interim reasonable accommodations where full retrofit will require longer lead times;
• updating development briefs and design guides to embed universal design and align with approved standards; 
• ensuring that leases and fit out criteria are aligned to allocate compliance works and access rights; 
• the application of accessibility warranties, indemnities and price adjustments into transactions; and 
• incorporating compliance representations, covenants and event of default triggers into financing.

Conclusion

The objectives of the new Law are clear - to ensure full participation and enjoyment of rights by persons with disabilities and to prohibit discrimination and ensure equal opportunities. For businesses, this represents both a legal obligation and an opportunity to create more inclusive workplaces.

The one-year deadline for facility modifications, the duty to provide reasonable accommodations, strict privacy protections, and significant penalties for non-compliance mean that businesses must act now. 

By engaging occupational health professionals, conducting thorough audits, implementing comprehensive policies and ensuring that managers are aware of their obligations through training, businesses can ensure they meet their obligations under this important new legislation whilst supporting the full participation of persons with disabilities in Qatar's workforce.