On November 1, 2025, Kuwait's Public Authority for Manpower moved its wage compliance framework onto real-time digital infrastructure. For HR and payroll teams in Kuwait's private sector, that means new requirements around salary transfers, working hours reporting, and portal integration - all in effect now.
This guide covers:
Where relevant, we have drawn comparisons with other GCC frameworks, as they add useful context to Kuwait's specific requirements.
Kuwait introduced its Wage Protection System in 2015 under the framework of Private Sector Labour Law No. 6 of 2010. All six GCC countries now operate WPS frameworks. The first launched in the UAE in 2009; Oman, the most recent, launched in 2023. While they share the same underlying purpose of ensuring timely electronic payment of private sector wages, the way each country has designed its system reflects distinct regulatory priorities.
In Kuwait, the WPS is administered by the Public Authority for Manpower (PAM) in coordination with the Ministry of Social Affairs and Labour. Private sector employers with five or more employees are required to pay wages electronically through a local Kuwaiti bank, directly into each worker's accredited bank account. The transferred amount must match the employee's registered work permit record, and the full trail must be visible through PAM's systems.
A structural feature that sets Kuwait apart from some of its GCC neighbours is how compliance is measured. In Saudi Arabia, for example, a company is considered compliant if a threshold percentage of its total workforce, between 90 and 95 percent depending on company size, receives wages correctly. This gives employers some aggregate buffer. Kuwait does not work this way. Compliance in Kuwait is assessed at the individual worker level, meaning a violation is triggered for each employee whose salary is not paid correctly and on time. There is no company-wide percentage that absorbs individual shortfalls. Qatar uses a similar per-employee logic. For HR teams managing large headcounts in Kuwait, this means the accuracy of every individual's payroll record matters at month-end, not just the aggregate outcome.
The Sahel app, Kuwait's national digital labour platform, adds another dimension to this. It sends automatic notifications to individual employees when a salary shortfall is recorded, along with the employer's stated reason. Workers have a direct channel to contest that reason without going through the HR team first. This makes the quality of PAM justification letters consequential in a way that purely system-level WPS monitoring does not.
From November 1, 2025, PAM requires full integration of all salary approvals and transactions with the AS'HAL Salary Portal. This is the primary mechanism through which PAM monitors wage compliance in real time. Across the GCC, countries have built equivalent digital infrastructure for this purpose. Saudi Arabia uses the Mudad platform, Qatar operates a centrally administered WPS portal through the Ministry of Labour, and the UAE upgraded its system in June 2026 to include real-time monitoring through Al Etihad Payments. AS'HAL is Kuwait's equivalent, and it now extends beyond salary tracking to include working hours and employment data.
The specific requirements under the mandate are as such:
Failure to comply, or to provide acceptable justifications for discrepancies, may result in suspension of the company's PAM file. A suspended PAM file affects work permit renewals and new hire approvals across the entire company, not just for the employees whose salary triggered the issue.
Published in Kuwait's Official Gazette on September 14, 2025 and effective from November 1, Resolution No. 15 of 2025 ends the paper-based system for recording working hours in Kuwait's private sector. This is part of a broader regional trend. Qatar's WPS already flags violations where submitted overtime hours exceed statutory limits. Bahrain's enhanced WPS, rolled out from early 2026, similarly centralises payroll and working hours data into a single portal. Kuwait's Resolution No. 15 moves in the same direction, replacing manual records with mandatory electronic submission through AS'HAL.
Employers must now submit the following electronically:
These records must be kept current. PAM can take legal action against employers who do not comply, up to and including partial or full suspension of the employer's labour file.
The working hours requirement is also directly connected to wage compliance. Kuwait's WPS can flag violations where submitted overtime hours are inconsistent with what Labour Law permits. Employers who submit working hours data that does not reconcile with what they are paying create a compliance exposure on two fronts at once. The data going into AS'HAL needs to be accurate, not just filed on time.
Kuwait Labour Law No. 6 of 2010 requires monthly-paid workers to receive wages at least once a month, and workers paid on a daily, hourly, or weekly basis to be paid fortnightly. PAM has built a specific deadline structure on top of this:
To put this in regional context:
For employers currently processing payroll on the 8th or 10th of the month, the 5th deadline is a genuine process change. Attendance cutoffs, deduction approvals, variance reviews, and bank submission all need to fit into a shorter window. The buffer needs to be built into the process itself, not into the calendar intention.
PAM's enforcement campaigns have specifically targeted companies operating under government contracts. If your workforce falls into this category, treat the 5th as firm with no working margin.
Kuwait's enforcement framework under PAM escalates in stages. The following reflects the current published sequence:
| Trigger | Consequence |
|---|---|
| Salary not transferred by 5th, or delayed beyond 7 days from contractual due date | PAM issues warnings; legal action initiated under Kuwait Labour Law |
| Salary shortfall with no justification letter submitted to PAM | Treated as a WPS violation at the individual employee level |
| Non-compliance with AS'HAL portal or working hours reporting | Partial or full suspension of the employer's PAM file, affecting all work permit processing |
| Fines under Kuwait Labour Law No. 6 of 2010 | KD 100 to KD 1,000 per violation (approximately USD 325 to USD 3,260) |
| Repeated violations | Work permit suspension; potential criminal referral for persistent non-payment |
| Failure to submit monthly transfer receipts | Risk of blacklisting from PAM services |
One consequence worth flagging specifically: a suspended PAM file does not just affect the employees whose salary triggered the issue. It affects the company's ability to process work permits and approvals across its entire workforce. The operational exposure is broader than the individual violation.
Kuwait's WPS framework recognises that salary will not always match the registered amount in a given month. Employers can justify discrepancies in these circumstances:
In every case, the justification must be submitted to PAM in writing. This applies even for reasons as routine as a day of unpaid leave. It is worth noting how this compares across the GCC: Saudi Arabia's Mudad platform goes further than most, asking employers to justify discrepancies and then seeking the affected workers' approval through an SMS link before closing the matter. In Kuwait, the process is employer-side, but the Sahel app's direct notification to employees means workers see the shortfall and the stated reason independently. A vague or insufficiently documented justification creates the conditions for a formal dispute even when the underlying reason is entirely legitimate.
The mandatory WPS requirement covers all private sector employers with five or more employees registered under Kuwait Labour Law No. 6 of 2010, for both Kuwaiti nationals and expatriate workers.
Some categories require additional attention:
Employers operating across Kuwait's free economic zones should separately confirm applicability with their zone authority. The relationship between PAM's requirements and zone-specific regulations is not always automatically aligned.
greytHR is a full-suite HRMS used across Kuwait, the UAE, Saudi Arabia, and the wider GCC, with its payroll engine built around the compliance architecture of each country rather than adapted from a global template. For Kuwait specifically:
Whether you are closing an immediate compliance gap with the AS'HAL mandate or reviewing your broader GCC payroll infrastructure, greytHR is worth a close look.
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No. The mandatory requirement covers private sector employers with five or more employees under Labour Law No. 6 of 2010. Smaller employers are not subject to the same enforcement framework.
The 5th is PAM's operational deadline for transfers. The 7-day rule is the enforcement threshold: payment delayed beyond seven days from the contractual due date becomes a legal offence under Kuwait Labour Law.
Yes. Any salary reduction, including for unpaid leave, requires a formal justification letter to PAM. The reason does not need to be complex, but the submission is mandatory.
Sahel notifies employees directly of any shortfall and the stated reason. A vague or unsupported justification is visible to the employee and can prompt a formal complaint immediately.
The same rules apply, but PAM's enforcement campaigns have repeatedly targeted government contract employers. Treat the 5th-of-month deadline as firm with no working margin.
The employer. Kuwait places full legal responsibility for timely payment and WPS compliance on the employer, regardless of who prepares the payroll.
Yes. Kuwait's gratuity entitlements differ by contract type and service duration. greytHR calculates end-of-service benefits for both fixed-term and unlimited contracts without manual intervention.
Within 24 hours of the bank transfer completing. Employers should monitor this proactively rather than waiting for PAM to flag a discrepancy.
greytHR is a full-suite HR and payroll software trusted by 30,000+ businesses and 3.25 million users across 25+ countries, including in the GCC. Carrying a 3-decade legacy, greytHR brings the entire employee lifecycle - from onboarding attendance and payroll to compliance, performance, and exit - into a single system. With built-in compliance automation, AI-powered capabilities, dedicated customer support and a mobile-first experience, greytHR helps modern HR teams move away from administrative work into strategic work, keeping HR functions scale and future-ready, always.