Whistleblowing and Compliance in the UAE: Expert Insights from S&B Consulting

A New Era of Accountability

Whistleblowing in the UAE is evolving rapidly. Once considered a culturally sensitive or little-discussed concept, it has now become an integral part of the country’s broader push toward stronger corporate governance and ethical business conduct.

As organizations across the region adapt to new regulatory frameworks and rising stakeholder expectations, whistleblowing systems are emerging as essential compliance tools. 

To better understand how these changes are reshaping the business landscape, we spoke with Manish Bucha, Managing Partner at S&B Consulting, a leading risk advisory firm based in the UAE. 

Manish shared his perspective on the current regulatory environment, the challenges companies face, and how technology is helping businesses ensure integrity and compliance.

Evolving Whistleblowing Landscape and Regulations

According to Manish, the UAE is experiencing a significant transformation in how organizations view whistleblowing.

“Traditionally, the concept of internal reporting was limited and often culturally sensitive,” he explains. “However, the UAE’s ongoing governance reforms and focus on corporate transparency have elevated whistleblowing as a key component of ethical business conduct.”

This shift is being driven by a combination of public- and private-sector initiatives. Government bodies have introduced new legislation to encourage transparency and protect whistleblowers, while leading enterprises are adopting technology-enabled reporting mechanisms that meet international standards.

Manish highlights several key regulations shaping this change.

“Federal Decree-Law No. 31 of 2021 (Penal Code) offers protection for individuals reporting crimes in good faith,” he notes. “Dubai Law No. 4 of 2016, governing the Dubai Economic Security Centre, and the Abu Dhabi Accountability Authority regulations also contain whistleblower protection provisions. In the financial free zones, the DIFC Whistleblowing Law (2022) and the ADGM Whistleblower Protection Regulations (2024) provide robust frameworks with clear reporting and confidentiality obligations.”

Despite this progress, challenges remain. Many organizations still struggle with limited awareness, inconsistent procedures across jurisdictions, and the cultural hesitation to report wrongdoing. Building trust and confidentiality into every compliance program, Manish stresses, is critical to overcoming these barriers.

“While regulators have led the way, the private sector has become an equally strong driver,” he adds. “Multinationals and large UAE-based enterprises are implementing systems proactively to strengthen governance and meet global expectations.”

Legal Protections and Risks for Whistleblowers

Across the MENA region, whistleblowers continue to face social stigma and concerns about confidentiality.

“Fear of professional or personal repercussions still deters potential reporters,” says Manish. “Addressing these challenges requires a visible commitment to ethical behavior from senior leadership and a culture that protects integrity.”

Cultural norms also play a major role. In many organizations, loyalty to employers and an emphasis on internal resolution can discourage employees from using formal reporting channels. Yet this is beginning to change.

“As companies modernize their compliance frameworks, raising concerns through trusted channels is increasingly seen as an act of integrity, not disloyalty,” he explains. “Education and cultural sensitivity are essential to building confidence in these systems.”

Legally, the UAE offers growing protections for whistleblowers, particularly under DIFC and ADGM frameworks, which provide explicit safeguards on confidentiality and employment protection. Neighboring countries—including Saudi Arabia, Qatar, and Egypt—are also strengthening their legislation in line with international anti-corruption standards.

To ensure employees are aware of their rights, Manish recommends a holistic approach.

“Clear policies, regular communication, and ongoing training are key,” he advises. “Integrating secure technology platforms like FaceUp helps reinforce confidentiality and gives employees the confidence to speak up without fear of reprisal.”

Building Compliant Reporting Systems

The cost of ignoring whistleblowing requirements can be high.

“Non-compliance can expose companies to regulatory sanctions, reputational damage, and loss of stakeholder trust,” says Manish. “In sectors such as financial services, inadequate systems can lead to penalties and increased scrutiny from oversight authorities.”

Regulatory enforcement is also tightening across the GCC. The UAE’s Securities and Commodities Authority (SCA) regularly updates corporate governance requirements, signaling that companies are expected to maintain effective internal reporting frameworks.

“Regulators are sending a clear message that whistleblowing frameworks are a mandatory element of a sound compliance infrastructure,” he notes.

Responsibility for these initiatives typically sits within compliance, risk, or internal audit functions, supported by senior leadership and the board.

“Independent oversight and accountability are essential,” Manish emphasizes. “They ensure that reporting mechanisms remain effective, impartial, and aligned with legal obligations.”

To establish compliant systems, Manish recommends beginning with a regulatory gap assessment.

“From there, companies should develop tailored whistleblowing policies, clear reporting procedures, and employee awareness programs,” he explains. “Working with advisory firms like S&B Consulting helps ensure frameworks align with UAE and international compliance standards.”

Technology as an Enabler of Compliance

Technology plays a pivotal role in enabling secure, anonymous, and efficient reporting, as Manish states:

"Platforms like FaceUp provide centralized management, case tracking, and multi-channel accessibility—allowing employees to report concerns safely and organizations to manage cases in full compliance with data protection and whistleblowing regulations."

When combined with S&B Consulting’s expertise in governance, risk, and compliance, such tools empower companies to build a robust ethical culture and meet evolving regulatory expectations with confidence.

“Through the partnership between S&B Consulting and FaceUp, organizations gain access to a complete ethics and compliance solution—combining local regulatory expertise with world-class whistleblowing technology.”

Conclusion

As the UAE continues to evolve in terms of corporate governance and regulatory frameworks, companies must adapt by implementing robust whistleblowing systems that not only meet legal requirements but also foster a culture of transparency and trust. With the growing emphasis on accountability, it’s clear that whistleblowing frameworks are no longer just an option—they are a critical part of a company’s compliance infrastructure.

S&B Consulting is a UAE-based risk advisory firm specializing in governance, risk, and compliance across the Middle East. In partnership with FaceUp, a global whistleblowing and compliance platform, S&B Consulting helps organizations design and implement secure, transparent, and compliant reporting frameworks that strengthen integrity and align with international best practices. Together, they offer a complete solution that enables businesses to navigate evolving regulatory landscapes, maintaining compliance alongside a robust ethical culture.

With strong regulatory oversight and a growing commitment to ethical practices, the UAE is on track to become a regional leader in whistleblowing and corporate integrity—and companies that embrace these changes will be well-positioned for long-term success.

Learn more about FaceUp in the UAE