Can someone work in the UAE as an independent contractor without a permit?

No. Article 6(1) of Federal Decree-Law No. 33 of 2021 states that it is not permissible to undertake work in the UAE, and that an employer may not recruit or employ any worker, except after obtaining a work permit from the Ministry of Human Resources and Emiratisation in accordance with the Decree-Law and its Implementing Regulation.

How does the UAE treat project-based engagements?

Article 7(1)(c) of Federal Decree-Law No. 33 of 2021 recognises temporary work, defined as work whose execution requires a specific period or is based on a certain task and ends on its completion. That is a named work pattern inside the labour law rather than a way out of it, and Article 52 leaves the end of service mechanism for non-full-time patterns to the Implementing Regulation.

If we subcontract work, who is liable to the people doing it?

Article 11 of Federal Decree-Law No. 33 of 2021 allows an employer to outsource any of its original works or part of them to another employer, and makes the second employer solely liable for the rights of the workers undertaking that work under the Decree-Law, unless the two employers agree otherwise.

Independent Contractor Agreement in the UAE

In the UAE the contractor line is drawn by permits, not by the label on the document. Article 6 of Federal Decree-Law No. 33 of 2021 makes it unlawful to work in the country, or for an employer to engage a worker, without a permit from the Ministry of Human Resources and Emiratisation, and Article 7 pushes non-standard arrangements into named work patterns rather than out of the labour system. Where the relationship is genuinely commercial, Federal Decree-Law No. 50 of 2022 supplies the default terms.

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Governing law

Whether an engagement sits inside the labour system is decided by Articles 3, 6 and 7 of Federal Decree-Law No. 33 of 2021. A genuinely commercial services or agency relationship between merchants is governed instead by Federal Decree-Law No. 50 of 2022 promulgating the Commercial Transactions Law.

Federal Decree-Law No. 33 of 2021, Arts. 3, 6 and 7 [2021 text as published; the available official English consolidation does not reflect Federal Decree-Law 20/2023]

What a independent contractor agreement has to contain in the UAE

It is not permissible to undertake work in the UAE, and an employer may not recruit or employ any worker, except after obtaining a work permit from the Ministry under the Decree-Law and its Implementing Regulation.
Federal Decree-Law No. 33 of 2021, Art. 6(1) [2021 text as published; the available official English consolidation does not reflect Federal Decree-Law 20/2023]
The statutory work patterns are full time, part time for one or more employers, temporary work whose execution requires a specific period or is based on a task and ends on its completion, and flexible work whose hours or days change with workload, plus any further pattern set by the Implementing Regulation.
Federal Decree-Law No. 33 of 2021, Art. 7(1) [2021 text as published; the available official English consolidation does not reflect Federal Decree-Law 20/2023]
The Decree-Law does not apply to employees of federal and local government entities, employees of the armed forces, police and security, or domestic workers, so an engagement in those categories is outside the private-sector labour regime entirely.
Federal Decree-Law No. 33 of 2021, Art. 3(2)
An employer may outsource any of its original works, or part of them, to another employer, and that second employer is then solely liable for the rights of the workers performing the work unless the parties agree otherwise.
Federal Decree-Law No. 33 of 2021, Art. 11
Where a merchant carries out business or services for a third party related to his commercial activities, he is deemed to have done so for consideration unless otherwise established, and the consideration is set by custom or, failing custom, by the court.
Federal Decree-Law No. 50 of 2022, Art. 71

What catches drafters out

Part-time, temporary and flexible engagements are inside the labour law, not outside it. Article 52 leaves the mechanism for end of service benefits for foreign workers on work patterns other than full time to the Implementing Regulation, so a non-full-time engagement still generates statutory entitlements.
Federal Decree-Law No. 33 of 2021, Art. 52 [2021 text as published; the available official English consolidation does not reflect Federal Decree-Law 20/2023]
The employer may not pass recruitment or employment fees and costs to the worker, directly or indirectly, so cost-shifting clauses drafted as contractor expenses do not survive if the relationship is an employment one.
Federal Decree-Law No. 33 of 2021, Art. 6(4) [2021 text as published; the available official English consolidation does not reflect Federal Decree-Law 20/2023]