Summary

I paid US$1,115 in recruitment fees to the agent which I borrowed from relatives at 42 percent interest rate. I was told that I would be working as a waiter in a hotel but was instead placed as a laborer in a furniture factory where I had to carry loads. It was not per my contract. My [promised] monthly salary was SAR 1200 [$346] for eight hours, but I had to work 14 hours a day. I was paid on time for the first two months but was never paid on time thereafter. When I asked my manager for my payment, he would answer, ‘Die first, and I'll pay you later.’

―A former Saudi Arabia-based migrant worker from Nepal

Migrant workers are the engine of Saudi Arabia’s massive construction boom. There are 13.4 million migrant workers in Saudi Arabia, representing 42 percent of the country’s population. Yet despite their indispensable contributions, Human Rights Watch has found, based on interviews with 156 current and former workers from Saudi Arabia or workers’ family members between 2023-2024, that migrant workers are facing widespread labor abuses across employment sectors and geographic regions. Saudi authorities are systematically failing to protect them from and remedy these abuses.

This blatant failure to protect migrant workers creates a near certainty that the 2034 World Cup, which the Fédération Internationale de Football Association (FIFA) has engineered to award to Saudi Arabia as the sole bidder, will be stained with pervasive rights violations. As detailed in the FIFA bidding documents, the World Cup will be the largest hosted by a single country and will entail massive new construction including 11 new and four refurbished stadiums, over 185,000 new hotel rooms and significant airport, road, rail and bus network expansion. Sports promotion is driven in large part by Saudi Arabia’s de facto ruler, Crown Prince Mohammed bin Salman, or MBS, whose Vision 2030 economic reform plan aims to transform Saudi Arabia into a “global investment powerhouse,” and to that end Saudi authorities have already invested widely in a portfolio of top-tier sports clubs and industries.

The FIFA World Cup is just one of the significant planned projects requiring massive construction under Vision 2030. Saudi Arabia’s government has been on a petro-wealth spending spree over the past half decade that has allocated hundreds of billions of dollars to develop megaprojects and self-described “giga-projects” across the country.

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Announced projects include: a 170 kilometer-long by over 320 kilometer-wide vertical “smart” city; a “Dragon Ball” theme park built on 50 hectares of land; a luxury ski resort in the middle of the desert; and the world’s longest infinity pool, suspended over 61 meters above the Red Sea. At the center of transforming these plans from management consultant-abetted fantasies to funded reality is the Public Investment Fund (PIF), the country’s sovereign wealth fund. The planned PIF investments are staggering, including an estimated $500 billion futuristic NEOM project and the $50 billion Red Sea project. Estimates by the management consultancy firm McKinsey & Company indicate that the number of construction jobs will more than triple before 2025, adding millions to the already large population of migrant workers who usually fill these positions.

The 142 migrant workers that Human Rights Watch spoke to include current and former workers based in areas from Abha in the southwest to Tabuk in the northwest of the country. The workers were employed in a wide range of sectors, including construction, hospitality, private health services, and retail. In addition, Human Rights Watch also spoke to 14 family members of workers who died in Saudi Arabia. In line with past research by Human Rights Watch over the last two decades, this research reveals that migrant workers continue to face widespread labor abuses at every point in the “migration cycle.” The abuses start from the time companies recruit workers and illegally force them to pay exorbitant recruitment fees, and they continue with employers in Saudi Arabia refusing to pay migrant workers the wages they are owed in violation of their employment contracts. At the same time, employers expose workers to serious dangers at job sites, including climate-linked extreme heat for outdoor workers. The abuses linked to extreme heat cumulatively cause lasting health harms to migrant workers and their families even after they return home, including organ failure linked to extreme heat exposure, and unexplained and uninvestigated deaths for which families receive no compensation. The government rarely holds employers to account for violations of Saudi labor law.

Human Rights Watch has been documenting the deeply problematic working and living conditions of workers for over two decades. These abuses are enabled by Saudi Arabia’s kafala, or labor sponsorship, system that ties the legal status of migrant workers to their respective sponsors (employers in Saudi Arabia). And despite several rounds of labor reforms including the much-touted 2021 Labor Reform Initiative that claimed to facilitate a worker’s ability to transfer jobs and exit the country, Saudi Arabia’s legal and regulatory framework is failing to address widespread abuses that originate from the kafala system that grants employers’ extensive control over workers’ lives. Additionally, Saudi Arabia maintains harsh restrictions on free expression, prohibits migrant workers from joining trade unions, and participating in collective bargaining or strikes. What is more, the government of Saudi Arabia has weak capacity or will to implement existing labor protections for migrant workers. In an extreme case, in 2023, a worker who was trapped in abusive conditions was beaten and his phone smashed by his employer after calling for help on social media. These concerns were also reflected in a forced labor complaint filed by the global trade union Building and Wood Workers’ International Union (BWI) at the International Labor Organization (ILO) in 2024 against the Saudi Arabian government about the exploitative living and working conditions of its migrant workforce.

Even at these giga-projects’ nascent stages, this report reveals that PIF-funded businesses and projects are among those exploiting and abusing migrant workers, including in NEOM, a PIF-funded giga-project that is being built in the northwest of Saudi Arabia and includes futuristic projects such as “The Line.” A construction worker employed in a NEOM project told Human Rights Watch, “I level the ground. I dig. I do everything that I am assigned to. The tasks keep changing.” Despite his role in laying the foundations for a multibillion-dollar futuristic city, he has experienced woefully inadequate labor protections, and his employer has paid him much less than he was contractually promised while being charged over $1,000 in illegal recruitment fees. “I was promised SAR 1,000 [$267 per month], but I am getting paid SAR 800 [$213 per month].”

Another worker employed in a NEOM project told Human Rights Watch, “I was promised SAR 1,200 [$320] basic salary, but I am paid SAR 800 [$213]. They promised me an indoor waiter job, but I am working as an outside construction laborer. I paid [over $1,200] in recruitment fees which I borrowed informally so I have no option but to accept these terms of employment. Who do I blame? The company? The recruiter? Or my fate?”

Existing vulnerabilities are further amplified in a context where announced megaprojects often have unrealistic completion deadlines. Many are based in locations far from traditional urban centers. In these locations, migrant workers have even less access to support structures such as their embassies or migrant community groups. The ambitious targets set by Saudi authorities on projects often have tight and unrealistic deadlines which can lead employers to demand that workers continue to work even under dangerous conditions, such as extreme heat, and to fail to provide workers the breaks and other measures that would offer them some health and safety protections. The former CEO of NEOM, for example, previously said, “We are in a race with time.” A worker who was employed as a supervisor in a NEOM project said, “My job is to set targets for workers. Tasks must be completed within a fixed timeline, which puts undue pressure on workers.” Another construction worker employed in a NEOM project said, “They give us a daily target, which we have to meet anyhow. The supervisor does not treat us well. They make us overexert ourselves. We cannot stop during work hours. We have to continuously work.”

Multiple workers interviewed also faced severe job mobility restrictions despite the fact that Saudi Arabia’s most recent and highly touted migrant labor reforms, introduced in 2021 and known as the Labor Reform Initiative (LRI), claimed specifically to address this chronic abuse. Saudi authorities have stated that the LRI had “facilitated worker mobility” and given workers “the right to change employers under certain conditions.” In practice, however, the relevant regulations are insufficient and poorly enforced, and as a result, employers continue to interfere with workers’ ability to change jobs. One worker employed at a labor supply company said that his boss compelled him and his colleagues to sign an agreement, upon arriving in Saudi Arabia, to pay SAR 12,000 ($3,200) if they chose to transfer employers.

Similar abuses are also prevalent in high profile PIF-backed projects. A worker employed by a company that works on PIF-funded projects said that his employer prohibited him from transferring jobs. A father of two children, he said he was promised a cleaning job at a basic salary of SAR 1,000 ($213) for which he was required to pay over $1,250 in recruitment fees. Once in Saudi Arabia, his employer violated the terms of his existing contract and compelled him to sign a new contract at a significantly lower salary of SAR 600 ($160) while making him work in construction. He told Human Rights Watch, “If everyone had protested, I would have too, but no one dared to speak up. At such a low salary, I don’t feel like I am here to earn and save, but just to pass time.”

Saudi Arabia boasts about initiatives like the LRI, including at critical global platforms like the 2023 United Nations Human Rights Council Universal Periodic Review, in submissions to the World Trade Organization, and in bidding documents for the 2034 FIFA World Cup. Saudi authorities and boosters use these announced reforms to deflect criticism of its human rights and migrant worker rights’ record and promote the country as a progressive and attractive labor market. A worker employed in a NEOM project told Human Rights Watch, "It does not matter if the law is flexible if the employers are not flexible." Human Rights Watch documented numerous examples of employers blatantly violating these reforms with impunity, including by prohibiting workers from transferring jobs when they are eligible to do so according to the law. Human Rights Watch also wrote to Saudi authorities about the measures they took to hold companies that unlawfully prohibited worker from transferring jobs and information on job transfer request denials and received limited responses.

The construction related to the 2034 World Cup is unprecedented in size and scale and expected to take until 2032 to complete. Under FIFA’s human rights policies, countries bidding to host games must commit to strict human rights and labor standards. In the introduction to FIFA’s “Key Principles of the Reformed Bidding Process,” FIFA President Gianni Infantino writes: “Whoever ends up hosting the FIFA World Cup must … formally commit to conducting their activities based on sustainable event management principles and to respecting international human rights and labour standards according to the United Nations’ Guiding Principles.” FIFA has so far failed to apply these principles in the bidding process for the 2034 World Cup.

What is alarming based on an analysis of Saudi Arabia’s submissions for the FIFA 2034 World Cup bid including its Human Rights Strategy, is that the Saudi government fails to acknowledge these widespread abuses of migrant workers or demonstrate concrete measures to address them, and the accompanying report that should be an independent human rights assessment serves more as a whitewashing exercise. The bidding process raises serious questions about Saudia Arabia’s commitment to ensure the human and labor rights of the millions of workers required to build the infrastructure for the 2034 World Cup. It also makes a mockery of FIFA’s commitment contained in its Human Rights Policy to include human rights requirements as part of the consultation and bid process phases for the World Cup.

The reality of widespread, extensively documented migrant rights abuses in Saudi Arabia, the government’s apparent unwillingness to implement meaningful and effective migrant labor protections, and hundreds of billions of dollars in planned, time-sensitive construction projects that could expose migrant workers to dangerous conditions is a perfect storm that could lead to the 2034 FIFA World Cup and other planned giga-projects becoming major human rights catastrophes. While Saudi authorities have the primary obligation to protect human rights, including labor rights, businesses also have internationally recognized responsibilities to respect human rights and avoid complicity in abuses. International companies flocking to Saudi Arabia to profit from contracts on giga-projects risk causing, contributing to, and being directly linked to migrant workers’ rights abuses endemic in Saudi Arabia unless they undertake robust due diligence, including adequate prevention, mitigation, and remediation measures in their own business operations as well as in relation to their business partners in Saudi Arabia.

Companies must emphasize the proper enforcement of laws in place to protect workers, but compliance alone does not guarantee worker protection given that many laws in Saudi Arabia are inadequate by design and fail to offer sufficient protection to workers. Saudi Arabia, for example, prohibits outdoor work for a few pre-defined hours during summer months even when it can be dangerously hot outside the midday ban hours and months. Under Saudi labor law, only deaths or injuries that are classified as work-related are compensated. In the majority of workers’ injuries and deaths, however, Saudi authorities fail to conduct an adequate investigation, instead attributing these to “natural deaths” or “cardiac arrests.” As a result, most workers receive no compensations. Human Rights Watch believes that compliance with such inadequate regulations alone does not allow FIFA or other global companies to escape their responsibility for the pervasive violations of workers’ rights under international norms, as well as its obligations under international human rights instruments. 
 

Recommendations

To the Government of Saudi Arabia

Reforms to Address Systematic Failures in Saudi Arabia’s Labor Governance System

• Dismantle the kafala system in full, making the state the sponsor for migrant workers, and ensuring that migrant workers’ entry, residence, and work visas are not tied to employers.

• In the interim until the kafala system is abolished, impose strict penalties on employers who fail to issue or renew (with migrant workers’ approval) residence permits of migrant workers in a timely manner and ensure that any delay in making or renewing such permits during this interim period does not result in workers being penalized for the lack of up-to-date documentation through no fault of their own.

• Remove all requirements for migrant workers to obtain employers’ consent to transfer sponsors.

• Penalize employers who demand bribes from migrant workers in exchange for issuing or renewing residence permits, for transferring sponsorships, or issuing exit visas to leave the country.

• Publicize monthly disaggregated data on the number of migrant workers who have successfully changed jobs, as well as the number of transfers denied, with an explanation of reason for each job transfer denial.

• Eliminate all exit visa requirements for migrant workers, including the need to notify Saudi authorities prior to departure.

• Penalize employers who misuse the exit visa, including to hinder migrant workers’ job mobility.

• Enforce the prohibition on the confiscation of workers’ passports and investigate any alleged abuses of workers by employers.

• Ensure that all workers have received and signed enforceable employment contracts in a language that they understand and that the contract they signed before migrating to Saudi Arabia is the same one that is registered with the government.

• Penalize employers who falsely report workers as “discontinued from work” or issue exit visas as a retaliatory measure. Ensure affected workers have adequate knowledge, time, support, and resources to reverse false charges against them or to find alternate employment in Saudi Arabia, as well as ensure that affect workers’ outstanding dues, including end of service benefits, are paid.

• Invest in and promote nationwide awareness campaigns and training programs, including online programs to inform workers about their rights. Such programs should include “how-to” guides for using online government platforms like Qiwa and Absher and explain how workers can file complaints. Provide this information in languages commonly spoken by migrant workers, including English, Malayalam, Tamil, Telugu, Kannada, Bangla, Urdu, Hindi, and Nepali.

• Amend Saudi law to guarantee all workers, including migrant workers, the right to free expression, assembly and association, the right to join trade unions and participate in collective bargaining, and the right to peacefully strike.

• Provide free and independent access to human rights groups to monitor the situation of migrant workers including to worker camps.

• Verify that companies are not hiring workers off the record or using other tactics such as hiring them on different job categories or allowing work permits to expire in order to meet their Saudization goals. Employers who are found guilty of such practices should be penalized.

• Collect and publish key economic figures and indicators on poverty rates in country, including data on migrant workers.

• Ensure that the validity period of a government-issued migrant worker’s residency (iqama) card matches the duration of worker’s signed employment contract to limit employer’s disproportionate power over migrant workers and to reduce the uncertainty faced by workers regarding their job security and legal residency in the country.

Reforms to Address Wage Theft

• Strengthen the Wage Protection System (WPS) to ensure timely payment of workers. State authorities should immediately take action against employers after receiving WPS notifications about wage delays. This includes increasing the personnel resources, presence and capacity of the WPS to ensure they can effectively and speedily monitor and resolve cases of wage abuses.

• Introduce and implement a non-discriminatory living minimum wage for migrant workers that allows workers a decent standard of living for themselves and their families. Saudi authorities should also set up a committee that periodically reviews the minimum wage levels so that it guarantees a living wage. Typically, governments and employers should account for the following costs at a minimum to calculate a living wage: a basic food basket and meal preparation costs, health care, housing and energy, clothing, water and sanitation, essential transportation, children’s education, and important discretionary expenses relevant to the national context.

• Ensure that all forms of migrant worker wage theft victims have access to adequate remedy that enables them to receive their unpaid wages and other benefits when employers fail to pay them.

• Investigate, prohibit, and penalize companies that “warehouse” migrant workers, a practice whereby companies recruit more workers than they can meaningfully engage in their projects and do not pay them their contractually owed wages. Employers should pay workers full salaries throughout their employment, even if they do not have work available for them.

• If employers are unable to keep migrant workers employed due to unforeseen economic conditions, these employers should allow migrant workers to pursue employment elsewhere, as well as paying them all outstanding salaries, gratuities, a month’s notice, redundancy payments, and/or other early termination payments, along with airfare if the migrant worker wishes to return home.

• Require all clients including Saudi state entities and multinational businesses to pay all contracting businesses in a timely manner. Additionally, the Saudi authorities should require all contractors to pay their subcontractors according to the schedules set out in the contract and ensure that non-complying clients or contractors face sanctions.

Reforms to Address Recruitment Fee Abuse

• Investigate and prosecute employers, Saudi-based recruiting agencies, and subcontractors that violate the law requiring employers to cover all costs associated with a migrant workers’ recruitment and ensure that violators face appropriate penalties.

• Require companies to provide verification that they have covered the costs and fees associated with a workers’ recruitment. Interview migrant workers, ideally outside of job or accommodation sites, during labor inspection visits to confirm that they have not paid recruitment fees.

• Ensure that companies take all possible due diligence and monitoring measures to ensure that the recruitment agencies and subcontractors they partner with, in Saudi Arabia and abroad, are not charging workers recruitment fees or costs for travel, visas, employment contracts, or any other prohibited fees.

• Ensure that workers who have paid fees have access to recruitment cost reimbursement mechanisms.

• In addition to increased government regulation and scrutiny of employers’ treatment of migrant workers, ensure that government fees imposed for hiring migrant workers do not perversely incentivize employers’ exploitation of these workers, such as by shifting hiring costs to workers, refusing to renew worker’s residency permits, and prohibiting workers from transferring jobs.

Reforms to Strengthen Heat and Health Protections

• Ensure appropriate heat protection for workers, including by enforcing guidelines that impose work stoppages during extreme heat conditions as determined by the Wet Bulb Global Temperature index. Ensure workers have adequate access to cold water, shaded rest areas, air-conditioned transportation during commutes, proper nutrition, and accommodations that support their ability to rest, rehydrate and recover.

• Saudi authorities should ensure that all foreign migrant workers in the country have life insurance protections, with the insurance premiums/contributions covered by the authorities or employers, not by the workers themselves.

• Ensure that all deaths of workers are properly investigated and certified, and families of the deceased have access to adequate compensation.

• Make public data on migrant worker deaths, disaggregated by age, sex, occupation, nationality, and cause.

• Coordinate with public health experts, including the World Health Organization, to jointly formulate evidence-based health protection measures, including measures specifically designed to address the health impact of exposure to extreme heat. The recently established National Council for Occupational Safety and Health (NCOSH) should invest in evidence-based research and policymaking.

To the Saudi Public Investment Fund

• The PIF should create a fund for reimbursement of recruitment fees for workers in PIF-based projects and operate the fund until the Government directly sponsors workers’ visas.

• Develop and implement a policy on human rights due diligence in consultation with relevant rightsholders such as independent workers unions and other stakeholders and aligned with UN Guiding Principles on Business and Human Rights.

• Carry out human rights due diligence on all PIF-backed projects to identify actual and potential adverse human rights harms and ways to prevent, mitigate, and remediate them.

• Require primary contractors for PIF-funded projects to conduct regular and ongoing due diligence on subcontractors’ companies to have a better understanding of labor conditions.

• Set up mechanisms for remediation if violations of migrants’ rights are detected.

• Introduce a strong whistleblower policy for workers and subcontractors to report employer abuses and malfeasance and hire independent staffers who can promptly investigate the complaints.

• As Saudi authorities work to improve labor conditions, the PIF should take a leading role in adopting and implementing strong migrant worker protections in line with international standards and act as a model for other Saudi-based entities.

To FIFA

• Postpone any announcement that the World Cup would go to Saudi Arabia, until migrant workers’ and women’s rights, press freedom, and other human rights are protected.

• Make public the time-bound, binding guarantees, protections, sanctions, and remedies that FIFA sought and those it obtained to ensure the rights of migrant workers in Saudi Arabia, in order to make certain that another FIFA World Cup will not be tainted by egregious human rights abuses.

• Before announcing a decision on awarding the 2034 World Cup, FIFA should press Saudi Arabia to engage with human rights stakeholders and allow independent human rights independent monitoring withing the country.

• Engage in meaningful stakeholder engagement including with migrant worker communities in Saudi Arabia and with independent human rights groups before the World Cup is awarded to Saudi Arabia and throughout the lead up to the event;

• Formally and publicly raise with Saudi authorities key workers’ rights issues, including recruitment fees that workers pay and inadequate implementation of laws meant to prohibit workers from being charged such fees, wage theft, restrictions that ban or effectively prohibit workers from free association, collective bargaining, and strikes, exit permit requirements, and difficulties to change jobs despite initiatives such as the Labor Reform Initiative. Seek concrete commitments for legal reform and their enforcement on these issues

• Ensure that the bidding and awarding process of mega-events keeps human rights risks at the center.

To Migrant Origin Country Governments

• Strengthen embassy support across Saudi Arabia, including in isolated areas that are distant from the urban city centers. Utilize social media and other online tools and coordinate with diaspora groups to increase reach among migrant workers especially to educate them about their rights, laws and how they can access the available support resources.

• Engage with Saudi authorities to strengthen consular access to detention facilities and ensure origin country embassy officials frequently visit detained workers to ensure they have access to space, food, water, adequate medical treatment, sanitation, and legal support. Under the Vienna Convention on Consular Relations of 1969, Saudi Arabia in under an obligation to inform any foreign national detained by its law enforcement of their right to seek consular assistance and notify the consulate without delay. Consular officers have a right to visit their detained nationals in custody, communicate with them, and arrange legal representation.

• Engage with Saudi authorities and persuade them to impose a non-discriminatory minimum living wage that applies to all workers from all nationalities in all sectors.

• Migrant origin countries should collectively raise concerns through regional platforms such as the Colombo Process and the Abu Dhabi Dialogue and demand better protections on issues of shared concern among migrant workers of different nationalities such as uncompensated deaths, wage abuses, and exorbitant recruitment fees.

• Increase engagement and dialogue with international companies doing business in Saudi Arabia to raise concerns faced by migrant workers and urge them to adopt better policies throughout their operations while also using their leverage over Saudi authorities to improve overall labor standards.

To Businesses Engaging in PIF-Backed Projects

• Conduct thorough and independent human rights due diligence prior to engaging in any business activities with PIF and its subsidiaries or entering into any contracts with local firms to execute projects, in line with the UN Guiding Principles on Business and Human Rights and make public the findings.

• Obtain written commitments from contractors and subcontractors funded by the PIF that they will engage in responsible recruitment and employment practices, in accordance with the protections of international labor laws.

• Conduct independent monitoring and inspection of hiring and wage payment practices of companies, and living and working conditions of migrant workers, and ensure that migrant workers are paid on time and in full as per their contracts.

• Remediate harms suffered by migrant workers at worksites related to their businesses and make public the findings.

• Implement all possible due diligence and monitoring measures to ensure workers have not paid recruitment fees. This can be done for example by obtaining information from partners in Saudi Arabia and recruitment agents in migrant origin countries verifying that workers have not been charged such fees. This information can also be corroborated with workers themselves. Set up reimbursement mechanisms in instances when workers have paid fees and penalize and terminate relationships with partners that charge workers fees or mislead workers regarding conditions of employment.

• Ensure that company staff or any sub-contracting company or intermediaries do not retain workers’ passports or other identity documents, that all workers receive and sign enforceable employment contracts in a language that they understand prior to their migration, and that these are the same contracts that are registered with the authorities, that all workers employed maintain valid residency permits, and that workers’ rights to transfer sponsors or exit the country are respected.

• Make public commitments to protect the rights of all migrant workers associated with company-linked projects.

• Use leverage publicly and privately with Saudi authorities to ensure they fully implement and enforce their labor reforms and introduce new reforms in cases when existing labor laws are not adequate to protect migrant workers.

• Disclose and update companies’ lists of contractors and subcontractors periodically to ensure that a company is not doing business with any contractors or subcontractors that continue to charge workers recruitment fees, mislead workers regarding conditions of employment, and/or steal wages from workers.

• Provide safe channels for workers to make complaints about unfavorable working or living conditions, including through anonymized and accessible channels, in languages that workers speak, and ensure that such channels exist also for workers in sub-contracting companies.

• Introduce a strong whistleblower policy for workers and subcontractors.

To FIFA Sponsors

• FIFA’s sponsors and corporate partners should use their financial leverage to insist on human rights due diligence and stakeholder consultation before FIFA awards the 2030 and 2034 World Cups and throughout the period leading up to and during the events. Sponsors should set up a remedy fund that could compensate migrant workers and their families for wage abuses, injuries, and deaths building World Cup infrastructure.

Methodology

Between March 2023 and September 2024, Human Rights Watch conducted telephone and in-person interviews with 142 current and former migrant workers from Bangladesh, India, Nepal, Pakistan, and the Philippines, and 14 family members of deceased workers from India, Bangladesh and Nepal, about their recruitment and employment in Saudi Arabia. Human Rights Watch also conducted online focus group discussions with a dozen Saudi Arabia based migrant community leaders. Human Rights Watch also conducted interviews with: current and former origin country embassy officials and NGO workers with extensive experience assisting distressed workers in Saudi Arabia; migrant origin country-based recruiters who recruit for companies in Saudi Arabia; and journalists who have covered migrant rights issues in Saudi Arabia. All interviewees provided verbal or written informed consent to participate, and no compensation was provided for any interviews.

Human Rights Watch also reviewed relevant documents, including death certificates of several workers who died in Saudi Arabia, details of recruitment practices, including a review of job vacancy postings, relevant emails and WhatsApp exchanges between origin country-based recruiters and their Saudi-based clients, and employment contracts of migrant workers.

Information on salary was recorded in Saudi Riyal (SAR), whereas recruitment fees were recorded in workers’ home country currencies including Indian Rupee (INR), Nepali Rupee (NPR), Pakistani Rupee (PKR) and Filipino Pesos (PHP). A US dollar conversion is provided.

Due to accessibility and security challenges, not all interviewees were able to be asked the full set of questions regarding the spectrum of abuses they faced. Human Rights Watch interviewed a diverse range of workers, both current and former, including as to occupation, legal status, and seniority level. Researchers also interviewed workers who had experienced chronic illnesses, including organ failure, after working in Saudi Arabia.

The report builds from and makes reference to previous Human Rights Watch reporting on rampant migrant rights abuses in Saudi Arabia. The research took place in two phases.

During the first phase, the research was focused on geographic diversity of worksites, speaking to workers employed across Saudi Arabia, including the cities of Riyadh, Dammam, Tabuk, and Khobar. Over 20 dialysis patients or families of deceased migrant workers were also interviewed. Collectively, these interviews provided a background understanding of serious abuses migrant workers experience in Saudi Arabia’s labor market and the lack of government protections from exploitation.

In the second phase, researchers identified workers specifically engaged in either PIF-linked projects such as NEOM and the Red Sea Project or employed by companies that are either backed or partially owned by PIF or serve other PIF-backed companies. This includes the Saudi Manpower Supply Company (SMASCO), the Saudi Binladin Group and over two dozen contractors or subcontractors working at several NEOM and Red Sea Projects. The first round of interviews helped take stock of the broad situation of migrant workers across the country and in multiple sectors, whereas the second round of interviews helped researchers better understand the situation of migrant workers specifically on PIF-backed projects that are in their nascent stages.

In November 2024, Human Rights Watch wrote to the PIF, NEOM Company, Red Sea Global, Saudi Binladin Group, SMASCO, Saudi Oger, and Mohammed al-Mojil Group (MMG) as part of this research. Human Rights Watch also wrote to Saudi authorities, including the Ministry of Human Resources and Social Development, the National Council for Occupational Safety and Health, Takamol Holding that owns the Qiwa platform, and to Saudi Arabia based migrant origin country embassies, including those of the Philippines, Pakistan, India, and Bangladesh. Human Rights Watch also wrote to FIFA and FIFA’s corporate sponsors of the World Cup including AB InBev/Budweiser, Adidas, Coca-Cola, McDonalds, and Visa. A compilation of the letters is presented in the report appendix, and company responses are referenced in the report text.

On November 27, Human Rights Watch received a response from Ministry of Human Resources and Social Development indicating that they are collecting information to Human Rights Watch’s queries and will share a response after December 4. On November 30, Human Rights Watch received a response from NEOM saying they initended to respond in the near future. Human Rights Watch will update the report with relevant responses from the Ministry and NEOM when we receive them.

On November 20, 2024, Takamol Holding replied to Human Rights Watch regarding questions about the Qiwa platform. Separately, on the same date, the National Council for Occupational Safety and Health (NCOSH) replied to Human Rights Watch’s questions on heat-related protections for migrant workers. In November, AB InBev/Budweiser, Adidas, McDonalds, and Visa responded in writing, and all including Coca-Cola agreed to meet on concerns about tournament-related labor abuses.

Context of Saudi Arabia’s Migrant Labor Abuses

Saudi Arabia hosts 13.4 million migrant workers, with Bangladeshis, Indians, and Pakistanis forming the three largest foreign nationalities.[1] According to government statistics from Bangladesh and Pakistan, over 498,000 Bangladeshis and 426,951 Pakistanis traveled for employment to Saudi Arabia in 2023.[2] These numbers are expected to surge as Saudi Arabia ramps up its recruitment for the preparation and delivery of the myriad megaprojects linked to Vision 2030, a multi-billion dollar program backed by Saudi crown prince Mohammed Bin Salman reportedly aimed at diversifying the country’s economy and rehabilitating its image.[3] Yet despite plans to increase the migrant workforce, workers are facing widespread rights abuses from the time they are recruited in their home countries to when they leave Saudi Arabia, and the consequences of these abuses may continue long after they return home.

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The Enduring Kafala (Sponsorship) System

Human Rights Watch has been documenting migrant worker abuses in Saudi Arabia for over two decades.[4] Testimonies from workers collected in 2023-2024 as part of this report reflect similar vulnerabilities and violations to those documented in research from almost two decades ago.[5] Migrant workers are governed under the abusive kafala (sponsorship) system, which ties workers to their sponsors for their residency and work permits. Despite removing the term kafala from Saudi Arabia’s Labor Law in 2000 and multiple rounds of labor reforms, including the Labor Reform Initiative (LRI) in 2021, migrant workers are still beholden to their employers to facilitate entry, residence, and employment in the country. [6]

Saudi Arabia’s prohibitions on trade unions and strikes gives employers even more unchecked power over workers.[7] In workplaces that employ more than 100 Saudi workers, workers’ committees are allowed to be formed, but migrant workers are barred from 
joining them.[8]

Prevalence of Labor Supply Companies in Managing Workers

Many companies who ultimately employ the workers, instead of assuming the role of direct sponsors, opt to meet their human resource needs through scores of Saudi-based “labor supply companies.” These labor-supply companies oversee various tasks pertaining to a worker’s recruitment and employment such as visa and work permit processing, travel arrangements, accommodations and meals for a certain fee, and act as the workers’ primary sponsors. Human Rights Watch research shows that many labor supply companies expose workers to abuse and are more likely to be exploited than their “direct hire” counterparts, even for identical jobs. During recruitment, workers are often misled to believe that they are hired by the main company rather than a labor supply sub-contractor. Moreover, while they sign employment contracts that stipulate regular work and salary, labor supply companies often fail to provide workers with regular work or pay. As per interviews, workers are made to switch jobs, sectors of work, or worksites frequently, violating the terms of their employment contract with impunity.

Many labor supply companies are also notorious for “warehousing,” a practice whereby they hire more workers than needed for a particular period, and then often fail to pay the contractually agreed wages of “warehoused” migrant workers as required by the Saudi labor law. With the rapid expansion of major construction projects in Saudi Arabia, the labor market’s reliance on labor supply companies will also increase.

Limits of Saudi Arabia’s Labor Policy and Modernization Reforms

The Saudi government has prioritized digitizing its public services. The Ministry of Human Resources and Social Development launched a new online employment contract service through its Qiwa platform, launched in 2019, that enables employers and workers to access and update employment contracts online.[9] This platform is linked to all aspects of a migrant worker’s recruitment and employment in Saudi Arabia, including for visa issuance, contract management, and transfers or terminations. Absher is another online government platform introduced in 2015 that provides a wide range of services, including facilitating workers’ exit from the country.[10] While online portals like Qiwa and Absher have indeed moved many of the administrative procedures online, interviews conducted by Human Rights Watch reveal that these online portals have not resolved the long-standing control employers wield over migrant workers for multiple reasons including gaps in oversight, the employer’s failure to comply with established procedures, the government’s failure to hold companies accountable for violations, and workers often lacking relevant awareness, relevant languages, and technological facility to access these systems. One worker who was unable to change his jobs because his employer did not approve his change request on Qiwa platform said, “Online or offline, the employer has to approve, don’t they?... They claim big reforms but, on the ground, the employer has the final say.” Migrant workers, especially low-paid ones, also face administrative, technological, and information barriers when using these online platforms. 

As part of Vision 2030, Saudi Arabia has also prioritized employing Saudi nationals. [11] Saudi Arabia’s nationalization program, known as Nitaqat (in Arabic, “bands”), requires companies operating in Saudi Arabia to hire a certain share of Saudi nationals that varies depending on industry and occupation.[12] Companies are assessed based on five bands i.e., “Platinum, High Green, Mid Green, Low Green, and Red” that reflect the current percentage of Saudi hires.[13] These color bands determine the business’s access to government services, including the ease with which they can hire foreign workers. For example, companies in the “red zone” are unable to apply for new visas, use transfer visas, renew work permits, or open new branches or facilities. 

Regardless of companies’ Nitaqat color band status, the overall costs of recruiting foreign workers has also increased due to Saudi authorities charging higher levies on companies for hiring foreign workers. In 2017, Saudi Arabia implemented a monthly expat dependent levy on the sponsoring company that started at SAR 100 ($27) and progressively increased to SAR 400 ($106) by 2020.[14] Similarly, expat levies introduced in 2012 increased from SAR 400 ($106) in 2018 to SAR 800 ($212) in 2020 with a SAR 100 ($27) discount to companies where Saudi nationals exceeded expat hires.[15] There are a few exemptions such as for companies with less than nine employees.[16] The expat levies also contribute to Saudi Arabia’s non-oil government revenues. Media analysis estimated that labor costs in construction subsequently increased by 20 per cent as a result of these levies.[17] This cost is being reconsidered by the government in an effort to attract more skilled talent, as per media reports.[18]

Human Rights Watch’s research found that these restrictions and increased costs to hire foreign workers can in turn increase the risk of business abuses because they incentivize companies to refuse to pay for workers’ residency and work permits, which they are legally obligated to provide, or turn to labor supply companies in order to fulfil their human resource needs to avoid the extra expenses that the restrictions can impose.

Whitewashing of Saudi Migrant Reality and FIFA 2034 World Cup

Saudi authorities have used various tactics in an attempt to rehabilitate their image to deflect from the global perception of the Saudi state as a severe and persistent human rights abuser. Human Rights Watch has reported on the government’s multi-billion dollar campaign to host entertainment, cultural, and sporting events to gain public favor, including by hosting a range of media celebrities, golf tournaments, boxing and wrestling matches, and the Formula 1 Grand Prix.[19] The Saudi government appears to have determined that hosting global celebrities and hosting major entertainment and sporting events and companies is a powerful means to launder its reputation and convince international investors to invest in the country despite pervasive human rights violations.

On July 29, 2024, Saudi Arabia submitted its bid to host the 2034 World Cup. This ultimate soccer tournament will be the brightest jewel yet in Saudi Arabia’s “sportswashing” crown.[20] The oil-rich country has been determined to buy the halo effect of hosting sport’s largest and most popular event, hoping this will wash away its poor human rights reputation.[21]

A review of the World Cup 2034 bidding documents including the bid book, the Human Rights Strategy, and the Independent Context Assessment shows that these documents ignored key, well-documented risks workers face and misrepresent the harsh realities faced by migrant workers in Saudi Arabia.[22] These assessment reports appear to be a blatant attempt at whitewashing Saudi Arabia’s egregious human rights record, many of the costs of which will be borne by migrant workers and their families.

The Human Rights Strategy is based largely on the findings of the “Independent Context Analysis,” a mandatory FIFA process which was a severely flawed exercise based solely on desk research and interviews with Saudi authorities and without any consultation or engagement with migrant workers, civil society, or human rights organizations. The Human Rights Strategy was a perfunctory summary of existing laws and cherry-picked ratified treaties. Glaring omissions include Saudi Arabia’s ban on migrant workers joining unions, engaging in collective bargaining, or participating in protests, the dangerous health risks of workers’ exposure to extreme heat and the inadequacies of existing protections, and rampant wage theft, among others. These documents highlight how the Labor Law has been revised six times in the last 11 years, including in March 2021 as part of the Labor Reform Initiative (LRI), but the bidding documents do not address the problematic provisions that remain in the law or the government’s failure to enforce the law adequately. What is more, in its FIFA bid documents, the government does not acknowledge that, despite these reforms, migrant workers continue to face rampant abuses while employers continue to carry out egregious abuses with impunity.

Limits of Migrant Origin Support Systems in Saudi Arabia

The size of Saudi Arabia, the largest country in the Gulf Cooperation Council by a significant margin, and the large migrant workforce spread across the country makes it challenging for migrant worker origin countries’ embassies to extend support to their distressed citizens.

The risks for migrant workers increase if they are working on PIF-backed projects such as NEOM in northwest Saudi Arabia in isolated areas. The usual formal and informal support networks that migrant workers rely on, such as embassies and well-established migrant diaspora groups, already struggle to support distressed workers in Saudi Arabia due to the huge number of migrant workers scattered across the country. For instance, just three origin countries—Bangladesh, India, and Pakistan—are responsible for supporting almost six million migrant workers in Saudi Arabia. A worker subcontracted to a NEOM project who paid $1,155 in recruitment fees but was paid SAR 700 ($186) per month instead of the agreed SAR 800 ($212) told Human Rights Watch, “Who will listen to our grievances? We are in the desert. The recruiter is back home. The embassy is in Riyadh.”

Officials at embassies of countries where migrant workers come from and migrant worker leaders told Human Rights Watch they struggled to support distressed workers for various reasons including the sheer volume of workers requiring help, the fact that workers are spread over large distances, an inadequate number of personnel and financial resources, unclear Saudi legal provisions that make it challenge for embassy staff to navigate effectively in support of impacted workers, and barriers related to language and technology. One migrant leader who supports migrant workers in distress and coordinates with his country’s embassy told Human Rights Watch, “If it was one or two workers in distress, helping them would be manageable. But when hundreds of workers are stranded at once, it becomes difficult to support them.”

As a result, employers are often able to exert even more control on workers located in remote areas, making these workers more vulnerable to labor violations and increasing the risk that these abuses will neither come to light nor be investigated by government officials.
 

Widespread Migrant Worker Abuses

Illegal Recruitment Fees and Wage Theft

Illegal, Exorbitant Recruitment Fees

Migrant workers are vulnerable even as they arrive in Saudi Arabia because they have to pay exorbitant, illegal recruitment fees to secure their jobs. Out of the 130 migrant workers whom Human Rights Watch asked about recruitment fees, only two people said they did not pay recruitment fees to obtain their employment in Saudi Arabia. 128 migrant workers reported that they paid recruitment costs ranging from $600 to as high as $2,422 to recruiters in their country of origin.

As per a nationally representative survey in Bangladesh, Bangladeshis migrating to Saudi Arabia pay an average of $3,715 in recruitment fees, which is almost twenty times higher than the average wage of $188 per month they can earn in Saudi Arabia.[23] Under Saudi Arabia’s Labor Law, employers are legally obligated to pay recruitment fees and other related recruitment costs (e.g., work permit, exit and re-entry visas, return airfare after contract completion), and those who do not can be fined up to $2,665 per violation.[24] However, Human Rights Watch’s research shows that Saudi authorities rarely hold employers to account for refusing to pay the costs associated with hiring foreign workers.

Workers interviewed for this research told Human Rights Watch that they borrowed money to cover recruitment fee costs at usurious annual interest rates of up to 42 percent, or pledged assets such as their homes to afford the otherwise unaffordable fees. Debt bondage is a form of forced labor under international labor standards.[25] Most workers said they were not provided receipts for the recruitment fees they paid, and those that did receive receipts said they grossly understated the actual amount. One Indian worker said, “I was told to record a video testimony by the recruiter saying I haven't paid the agent a single penny. I needed the job, so I lied.”[26]

Research by Human Rights Watch has found that hiring companies in migrant host countries like Saudi Arabia drive up recruitment fee costs.[27] They often refuse to pay recruiters in full or at all for their services, and sometimes even levy additional commissions on recruiters in exchange for job orders. Recruiters are sometimes even expected to cover costs such as the employer's travel and accommodation for interview trips to origin countries. The “employer pays” principle breaks down when the employer refuses to cover the costs and is not held to account.

Human Rights Watch reviewed a Saudi-based job demand letter that illustrated this dynamic in practice. The demand letter was circulated among recruitment agencies for construction jobs in Saudi Arabia that included welders, pipe fitters, painters, and “helpers,” with salaries ranging from SAR 900 ($240) for “helpers” to SAR 2,400 ($640) for “pipe/structure fabricators.” The Saudi-based company asked the recruiter to offer “commissions per visa.” It stated, “[Hiring] company does not provide joining air ticket and agency fees.” All these costs that employers refuse to pay are ultimately charged by recruiters to migrant workers as recruitment fees in clear violation of Saudi Arabia’s labor laws.[28]

Human Rights Watch has found in previous research regarding recruiters bringing migrant workers to Gulf states, including Saudi Arabia and Qatar, that even when hiring companies cover recruitment costs, subcontractors in host countries or recruiters in origin countries often “double dip” and charge both the hiring employer and workers in the absence of strong due diligence and oversight mechanisms by the hiring employer. Based on Human Rights Watch interviews and other research, Saudi authorities and migrant origin countries have continued to fail in adequately monitoring such activities.[29]

It is possible for employers to adopt ethical recruitment practices, in which migrant workers do not pay recruitment fees. Human Rights Watch reviewed documents of a Saudi Arabia-based employer who does basic due diligence in recruiting workers. The documents revealed that the employer interviewed newly recruited migrant workers and asked if they had paid recruitment fees in their home countries. One worker reported that he did pay, and in response the company ensured that their recruitment partner reimbursed the migrant worker’s family for the recruitment fee costs, in this case, SAR 1,500 ($399).[30] This case and previous research by Human Rights Watch demonstrates how employer due diligence and the credible threats of recruiters losing potential business can be a powerful way of reducing recruitment fee abuses that migrant workers are illegally compelled to pay.[31]

Recruiters Human Rights Watch spoke to, however, said they were not optimistic that recruitment practices of Saudi Arabia-based employers, even for high profile projects like those linked to the PIF, would improve in the foreseeable future because some of the Saudi-based companies have documented track records of engaging in unethical recruitment practices, and Human Rights Watch’s research for this report indicates that some companies continue to do so.[32] Indeed, workers employed by labor supply companies that are involved in several Red Sea and NEOM projects said they paid up to $1,260 in recruitment fees.

A former worker supplied to a Red Sea Project said that in his group of nine workers deployed by the same recruiter, recruitment fees ranged between $873 to $1,100 for the same job. Likewise, another worker employed on a NEOM project said, “NEOM does not question contractors whether their workers have paid recruitment fees.”[33] According to him, NEOM’s only concern is contractors’ and subcontractors’ ability to mobilize the required number of workers and complete tasks on time, without conducting any due diligence on the circumstances under which workers are recruited.

Unpaid or Delayed Wages

Companies steal wages and other benefits from workers in different ways, including non-payment, underpayment, and arbitrary deductions. Human Rights Watch spoke to one Indian returnee who worked in Saudi Arabia for 12 years who said he was owed over $39,000 in cumulative unpaid wages and end of service benefits. Another worker from India who was owed SAR 8,500 ($2,266) as end-of-service benefits said, “The company assured me they would deposit my end-of-service benefits into my account… my friend was a witness to this arrangement and acted as the guarantor.”[34] Even after three years, he has not received his dues.[35]

Employers often unilaterally change the terms of employment, including by substituting contracts with different terms than those the worker agreed to before migrating to Saudi Arabia. At least six workers Human Rights Watch interviewed said they were made to sign contracts in Arabic after arriving to Saudi Arabia which they did not understand, while at least 47 said they were given jobs or benefits different from what they had contractually agreed upon prior to departure. Out of 112 migrant workers whom Human Rights Watch asked about wage theft, 69 said they experienced payment delays while 71 said they experienced non-payment or under-payment of contractually owed wages and overtime benefits.[36]

Multiple workers employed by labor supply companies that are involved in several Red Sea and NEOM projects told Human Rights Watch that their overtime benefits kick in only after 10 hours of daily work and not eight, as per Saudi law. One worker supplied to a Red Sea Project site said, “When you work for 12 hours a day, labor supply companies contracted in the project either pay for two hours overtime or four hours overtime. It varies on the company.”

At least 17 workers Human Rights Watch spoke to were compelled to return home prematurely before the end of their contract, sometimes within months of being employed, despite outstanding loans linked to their recruitment fees as they faced abuses in Saudi Arabia such as companies that falsely advertised their identity (e.g., telling migrant workers they were a well-known international company but in reality were a local labor supply company), non-payment of wages, and lack of work.

The widespread wage theft by Saudi Arabia-based employers – and in some instances, origin country recruiters – that Human Rights Watch documented unambiguously violates the country’s labor laws, which stipulate that wages must be paid regularly every month, and deductions from wages are prohibited unless required by the law.[37] The law also states that workers are entitled to overtime payments of 1.5 times their normal wages after eight hours of work and specifies that these payments should be electronically deposited into workers’ bank accounts through Saudi Arabia’s Wage Protection System (WPS).[38]

The WPS, which was instituted in 2013, requires companies to transfer salaries to workers in full by the ninth of every month. Saudi Arabia’s Ministry of Human Resources and Social Development (MOHRSD) oversees the WPS and is able to monitor every salary transfer, and the ministry also requires companies to share additional data that demonstrates on-time payments.[39] Despite the WPS being advertised as an effective mechanism to address widespread wage abuses, in practice it has worked at best as a monitoring system since wage violations remain pervasive across Saudi Arabia.

According to Saudi law, non-compliant employers are supposed to face penalties, including fines and a suspension from being issued work permits for foreign workers. However, no migrant workers interviewed were aware that authorities imposed these or other penalties on their non-compliant employers, nor did these interviewed workers say that they received remedy for non-payment of wages.[40] Media reports indicate that Saudi authorities have imposed penalties on companies over the years due to their non-compliance.[41]

The WPS remains ineffective at ending employer wage theft practices, as evidenced by the continuing widespread nature of such abuses. As the group Migrant-Rights.org documented, in 2023 Saudi authorities reduced the size of fines levied on employers for wage theft in order to “support the stability of businesses and ensure their growth.”[42]

Saudi Arabia also does not have an effective mechanism to ensure payment of workers’ wages when employers fail to pay.[43] Two companies — Saudi Oger and MMG — recently announced that tens of thousands of workers who were laid off in 2016 could register for years of overdue wages, and while it is a positive move, access has been rife with problems and the announcement came almost a decade late.[44]

There are scores of current and former migrant worker wage theft victims who have not received their contractually owed dues. The construction conglomerate Saudi Binladin Group (SBG) laid off tens of thousands of workers in 2016 and sent them back home without pay.[45] One Filipino worker said he was owed SAR 4,500 ($1,200) and that he had relied on his friends for food and living support before he left Saudi Arabia.[46] He told Human Rights Watch, “I need [my dues] badly because I have two children, one is two years old and the other seven months old… I don't have work now... I have no idea how to process or where I can get my unpaid salary from SBG.”

Another Filipino SBG worker reported that in addition to unpaid wages, the company also did not pay for him and his colleagues’ tickets home, so he had to work for a couple of months as a cleaner to save enough money to go home. His employer still owes him SAR 5,000 ($1,333), he added, “We have been waiting for a long time [since 2016] but nothing has happened.”[47] Meanwhile, in February 2024, Bloomberg reported that the PIF is collaborating with Morgan Stanley to potentially acquire 36 percent of SBG. But many workers are still waiting for payment of their owed wages.[48]

Saudi Arabia also does not have a minimum wage for its migrant workforce, while the monthly minimum wage for Saudi nationals is SAR 4,000 ($1,066).[49] Many workers reported that it was difficult to support themselves and their families with the actual salaries they were receiving, which were often far below what they were contractually obligated to receive. These salary levels also did not comply with origin countries’ minimum referral wages, which countries like India unilaterally set as a salary “floor” for employers abroad hiring their nationals.[50] Below these levels, companies are not allowed to hire workers, and countries such as India and Nepal require companies to meet the minimum referral wage requirement t0 carry out recruitment activities in their countries.

Companies who do not follow these policies can be prohibited from future recruitment activities by origin country governments. For example, the minimum monthly referral wages for Nepali “unskilled workers” for Saudi Arabia, according to Nepal’s embassy in Riyadh, is SAR 1,000 ($267) as the basic monthly salary plus SAR 300 ($80) as a food allowance, while the Indian Embassy in Riyadh recommends a monthly minimum wage of SAR 1,500 ($400).[51] However, Human Rights Watch spoke to workers from these countries who are earning as low as SAR 600 ($160) per month despite these recommended salary minimums. As a migrant leader pointed out, “It is shocking that people are [currently] getting hired at this rate [$160]. I came to Saudi Arabia in 2007, and even then, my salary was higher than what cleaners and helpers are getting hired for by some companies.”[52]

Human Rights Watch did not receive any response from MOHRSD regarding whether Saudi authorities apply the minimum referral wages set by migrant origin countries. Takamol Holding stated that “minimum wage requirements for specific nationalities are respected through bilateral agreements and aligned with labor regulations.”

Human Rights Watch found that in practice, hiring companies and recruiters find loopholes to bypass the prescribed referral wages by engaging in contract substitution, where workers are made to sign new contracts at the actual salary rates once they arrive in Saudi Arabia or dual contracts, with the lower rate contract couriered to the employer separately.

Conversations with migrant worker leaders, recruiters, and former embassy officials reveal that it is difficult for migrant workers to address this issue. First, workers are hesitant to complain to the embassy formally because they have outstanding recruitment loans, they fear repercussions, and they approach the benefits they are receiving with a “something is better than nothing” attitude as a former origin country embassy official put it. Second, Saudi Arabia does not have a minimum wage law for migrant workers, so employers are not violating the national labor law even though workers should receive sufficient wages to provide a “decent living,” or living wage, under international human rights standards. Furthermore, they should receive equal remuneration for equal work without discrimination. However, it is often difficult for workers to prove the myriad wage abuses they experience. Employers can point to workers’ signed contracts with a lower wage and claim the workers agreed to it, even if they signed it unwillingly or under coercion.

However, if workers do complain to embassies, embassies can reach out to employers and attempt to persuade them to pay the full referral wage. Embassies can also threaten to prohibit Saudi Arabia-based employers from future recruitment drives or take the case to a Saudi court. But, as noted, workers hesitate to file a complaint against the employer given their fear of repercussions, and several workers also expressed distrust in the embassy’s ability to help them. It is also not comfortable for workers to live and work on the company’s premises while having a formal complaint against their employer. A migrant worker who was a victim of contract substitution and wage theft told Human Rights Watch, “The official of the embassy visited us at our request, but nothing else happened. The embassy representative urged us to continue working rather than leaving the company. Afterwards, we approached them, but they did not respond.”[53]

In September 2024, a Nepali worker who was part of a group of 40 employees who have been in Saudi Arabia from three to 24 months with irregular work and pay told Human Rights Watch, “We had signed a contract in Arabic after arriving to Saudi Arabia. The contract signed back home is worthless. We have not been given a copy of the Saudi contract.”[54] The Nepali worker explained that he and his fellow workers did not have access to Qiwa, Saudi Arabia’s contract management portal, and were also made to sign an agreement upon arrival that stipulated they would have to pay SAR 12,000 ($3,200) if they wanted to change jobs. They were not given a copy of this agreement. Employer requirements that force migrant workers to sign agreements that they will have to pay exorbitant sums to transfer jobs is specifically prohibited by Saudi Arabia’s most prominently advertised recent migrant labor reform, the Labor Reform Initiative. These workers were also given a residency permit length of three months, which meant that they are facing higher risk of exploitation by their employer when their legal residency expires and are particularly vulnerable to employer retaliation if they complain about wage theft or other abuse.

Wage abuse is also connected to companies’ failure to provide regular work to workers as per the terms of their contracts, which stipulate regular monthly salaries for the duration of the contract. A Saudi Manpower Solutions Company (SMASCO) employee said, “There is no [regular] work. Many in the company are sitting for three to four months without leave or salaries.”[55] Another migrant returnee from the same company echoed, “Work is irregular, with clients or agents hiring you as needed. If required, they'll employ you for one or two months, but once the work is finished, they'll send you back to the supplier. If you don’t work, you won’t get paid… I suggest people not to go to that company even by mistake. I don’t want others to suffer what I underwent there.”[56] This “warehousing” technique, whereby more workers than necessary are hired, is common among labor supply companies. Although all “warehoused” workers have employment contracts, employers often do not give work and do not provide a wage, in violation of the terms of their contract, as well as Saudi labor law.

A former SMASCO worker told Human Rights Watch, “SMASCO did not pay us on time even when the company we are supplied to sent SMASCO their dues, including our salaries, in a timely manner. SMASCO was not responsive when we inquired about our salary delays. I wanted to transfer directly to the company I was supplied to as it had better facilities, but they said that SMASCO did not allow it. We don’t know why.” He said he was originally interviewed by the client company in his home country, but it was only after he got his flight ticket that he found out that he was under SMASCO’s sponsorship. “I would have never applied for the job if I had known this earlier. The recruiter falsely assured me that only the visa is in SMASCO’s name and everything else will be handled by the client company,” he added.[57]

Testimonies from wage theft victims reveal deep-seated fears of retaliation from employers even for asking for their rightfully owed dues. A worker who signed a housekeeping job contract with a basic monthly salary of SAR 1,000 ($267) for eight hours a day, six days a week, reported being placed as a factory worker, made to work seven days a week for 12 hours a day, without any overtime benefits. He told Human Rights Watch, “When I asked [my supervisor] to let me work as per the contract, he said, ‘I have no idea about your contract. I'm your boss, you do as I say. Stay and work or leave.’”[58] Another former worker who was forced to work for 12 hours without overtime payment sought help via YouTube. He told Human Rights Watch, “For this, my phone was confiscated and smashed. A colleague and I were also beaten for posting the video by the employer…”.[59]

Workers Trapped in Abusive Conditions

In 2021, Saudi Arabia introduced the Labor Reform Initiative (LRI) that aimed to address abuses linked to migrant workers being unable to transfer jobs due to the kafala system (including from abusive employers), facilitate workers’ ability to exit the country, and ease freedom of movement for migrant workers that is essential to mitigate the risk of forced labor.[60]

Human Rights Watch previously has criticized the LRI because it excluded whole categories of workers from its protections, including the country’s 3.7 million domestic workers, as well as farmers, who are among the workers most vulnerable to abuse.[61] The labor reforms themselves have been insufficient to end existing abuses inherent in the kafala system, and Saudi Arabia’s implementation of these changes has also been abysmal.

Limits to Job Mobility

On paper, the LRI allows migrant workers to transfer sponsors once 12 months have passed since they first entered the country. The transfer can take place without the agreement of their first employer “under rules that are intended to protect both parties to the contract.”[62]

According to the US government’s 2024 Trafficking in Persons (TIP) report, the US government’s annual publication that monitors human trafficking by countries and their efforts to combat it, 305,444 foreign workers in Saudi Arabia changed employers without the consent of their current employer.[63] However, Saudi authorities have not made public either a breakdown of these numbers by sector, size, worker job category, or Nitaqat category of the company, nor how many job change requests were denied and the reasons for those denials. In their response to a Human Rights Watch question on the number of successfully completed job transfer requests, Takamol Holding wrote, “Since 2021, a total of 4,389,950 sponsor transfer requests have been submitted via Qiwa platform.” However, Takamol did not share how many transfer requests were successfully completed, nor provide a detailed breakdown on the reasons for rejected requests.[64]

An origin country embassy official said that when companies believe that a migrant worker employee plans to change jobs, they can retaliate by issuing an exit visa for the worker (in which case a worker is unable to change jobs), or accusing the worker of a crime such as theft, property damage, or non-repayment of debts. Either of these actions can block a worker’s ability to finalize their job transfer process.[65]

In practice, employers still have the final say in approving or rejecting job transfer requests.[66] One migrant leader told Human Rights Watch, "Job change is both difficult and easy, it entirely depends on your employer. The original kafeel [sponsoring employer] needs to be supportive but more often than not, they are not.”[67]

Human Rights Watch spoke to workers, including from PIF-funded companies like SMASCO, who said their employers had an implicit “no transfer policy,” and that they were “not in a position to question the company’s decisions or policies.”[68]

A worker employed in a NEOM project said that no matter the law, his labor-supply company does not allow workers to change jobs. He told Human Rights Watch, “I was told to take the exit permit, leave the country, and re-migrate to another company. They said, ‘If we let you transfer sponsorship, we will have to let others do so as well.’”[69]

Another worker reasoned, “It is also a way for companies to prevent their competitors from hiring workers they have trained or to make their competitors go through the process of hiring from origin country which is more time and cost-intensive than hiring workers who are already in Saudi Arabia.”

A returnee driver who previously worked in a NEOM project said that when he attempted to change jobs, his company told him not to, saying “he would feel comfortable there eventually.”[70] He instead left, taking a final exit visa. He told Human Rights Watch, “there has been no improvement in Saudi Arabia.”

A former worker engaged in the Red Sea project through a manpower supply company told Human Rights Watch, “I wanted to transfer sponsorships, but was not allowed to. I did not have access to senior representatives of the company and my camp boss did not allow me to change it. We could not question him.”[71] He paid $993 for the job and was promised a monthly salary of SAR 1,400 ($372) but received SAR 800 ($212) with no overtime benefits. “Perhaps if the company was good, they would allow job transfers, but my labor supply was not good,” he added.

A SMASCO-sponsored worker who paid $883 for the job told Human Rights Watch, “It is difficult to transfer sponsorship from SMASCO to my current company. SMASCO does not allow it. So once my contract ends, I plan to return to my country [on an exit visa] and come back to the same [client] company’s sponsor.” On reforms in Saudi Arabia, he told Human Rights Watch, “There has been no improvement in Saudi Arabia in my opinion.”[72]

Another former SMASCO worker who struggled to change jobs and decided to instead take the exit visa option said, “The company treats you like an animal. Once you enter the camp, you cannot leave unless they find a ‘buyer’ for you.” He describes being “kept like prisoners” as they waited idly for work and were not even allowed to leave the company premises.

Migrant workers who did manage to change jobs did so only after much difficulty and incurring high costs.[73] As one migrant leader described, “changing jobs in Saudi Arabia is not impossible, but it is not easy either.”[74] While new employers are required to cover transfer fees that range between SAR 2,000 and SAR 6,000 ($533-$1,600) depending on the number of times the worker has changed sponsors, workers told Human Rights Watch that their employers demanded “an amount equivalent to the salary of the remaining months in the contract,” “two months’ salary,” or “the amount required to recruit them.”

A worker employed in a NEOM project said that he had to pay his previous employer over SAR 12,000 ($3,200) to be allowed to change jobs.[75] Another said, “I did not have to pay my old employer, but the new one made me pay SAR 8,500 [$2,266] … My original employer did not pay my end of service benefits of six years, though.”[76]

Interviews conducted by Human Rights Watch, including interviews with officials of embassies of migrant origin countries, reveal that workers also lack an awareness or and the technical know-how necessary to navigate online portals like Qiwa or the nuances of Saudi Arabia’s labor laws including about job mobility options. As one former embassy official said, “[Worker’s rights] are further adversely impacted by barriers to access because of language, technological, and information gaps workers face.”[77]

In their response on Human Rights Watch’s question about accessibility of the Qiwa platform for migrant workers, Takamol Holding wrote, “Qiwa offers its services in six different languages to cater to the diverse linguistic needs of the workforce in Saudi Arabia. Qiwa also regularly conducts workshops, with a minimum of 50 sessions held annually. Additionally, a knowledge center on the Qiwa website provides detailed service explanations, frequently asked questions, and guidelines.” 

One worker, who has lived in Saudi Arabia for over a decade, speaks Arabic and English, and understands the country’s bureaucratic processes well enough to change jobs despite an employer’s objections, told Human Rights Watch: “A simple worker cannot use Qiwa. Despite being well informed and technologically literate, I struggled very much to use Qiwa. I made sure to hand in my resignation two months in advance [as per the notice period]. When you put in your notice in advance, it limits the current employer’s ability to prevent the transfer.”[78]

In their response to Human Rights Watch’s questions on explaining the job transfer process and challenges Human Rights Watch documented migrant workers facing using Qiwa, Takamol Holding wrote, “We are aware that some employees may experience challenges due to specific contract conditions, compliance issues, or technological accessibility limitations. Qiwa and HRSD [Saudi Ministry of Human Resources and Social Development] are continuously working to address these obstacles and improve support for employees navigating the platform.”

Saudi regulations also allow migrant workers to change jobs without employer consent if there are indications of mistreatment or non-responsiveness such as an expired residency permit, three months of unpaid wages, if the company is in the Saudi Nitaqat system’s “red band,” or if the employer has two missed litigation hearings during a labor dispute.[79]

One worker said his company was listed in the Nitaqat red band for not meeting its Saudization requirements, so he did not have any problem changing his employer. He learned about the possibility of changing jobs and how to use the Qiwa system via YouTube videos and did not face challenges switching employers. “I accepted the transfer request sent by the new employer,” he told Human Rights Watch.[80]

According to migrant leaders, many companies are willing to hire jobseekers in conditions that enable them to transfer their sponsorship easily provided the workers themselves pay the associated transfer fees and for the residency permit even though this is strictly prohibited by Saudi Arabia’s labor law. However, these costs can be unaffordable for migrant workers who may have outstanding loans related to their recruitment fees and who are already facing financial hardships because of irregular work and pay, which made many of them eligible for the transfer in the first place.

Obstacles for Workers to Exit Saudi Arabia

The LRI did not remove the exit permit in its entirety, although it now allows migrant workers to request from the government an exit and re-entry visit permit or final exit permit without the employer’s permission, in addition to employees having the option to request an exit permit from their employer. If an employer does not respond to an employee’s exit permit request, in 10 days, Saudi authorities directly respond by approving or denying the permit.[81]

Requiring exit permits is a violation of the right to freedom of movement including the right to leave any country, which is guaranteed by international human rights law. Research by Migrant-Rights.org has shown how freedom of mobility remains restricted as workers are still required to pay significant fees of SAR 200 ($53.20) for a single-entry and SAR 400 ($53.20) for a multiple-entry "exit and re-entry visa", submit correct paperwork, and obtain permission from the Saudi state to obtain an exit permit.[82] Saudi Arabia is the only GCC country requiring migrant workers to pay fees for exiting and returning to the country.[83]

According to migrant community leaders and migrant workers Human Rights Watch spoke to, the majority of workers’ employers continue to apply for exit permits rather than the workers requesting it themselves through Absher. This observation is also supported by Saudi government statistics that show that only 618 foreign workers have obtained final exit permits without employer consent since the implementation of the LRI in 2021.[84]

Even though workers have the option to request exit and re-entry visas or final exit visas, they can often be reluctant to apply for it themselves given their fear of employer retaliation.

A few workers, for example, reported they cannot go home for vacations easily and the ease with which their leave gets approved “depends on their role in the company.” A worker engaged in a NEOM project said “one issue with our company is that they don't allow us to leave in case of emergencies at home, and they don't prioritize sending us home on time. They seem indifferent to our personal problems.”[85]

Another worker who faced family issues back home said his supervisor refused to let him take a vacation. He told Human Rights Watch that his supervisor declined and said that “our operations heavily depended on my presence, and we don’t have your replacement at the moment… ‘if you are not here, our work progress will suffer.’”[86] Another worker employed in a NEOM project by a company that works on several PIF-funded projects echoed a similar experience. “The availability of skilled construction workers, especially those requiring licenses to operate [machines], can be limited,” he said. “So, finding replacements delays the process of granting vacations.”[87] Instead of requesting exit and re-entry visas on their own, both workers waited for their employers to request it because they were afraid of employer retaliation.

A migrant leader noted: "Sometimes, employers renew the iqama [residency permit] of workers against their will and bar them from leaving the country for holidays or on final exit. The option to directly apply with the [Saudi] government for an exit permit can be helpful in such cases.”[88]

In their response to Human Rights Watch, Takamol Holding stated that the platform is safeguarded by two-factor authentication (one-time password (OTP) sent directly to workers’ mobile phones), which helps workers retain control of their accounts and prevents employer interference.

Migrant worker leaders and embassy officials also spoke about tactics used by some employers to trap workers against their will in the job. One migrant leader told Human Rights Watch: “My two biggest [pieces of] advice to newcomers in Saudi Arabia is not to sign anything that their employer makes them sign, especially if it is a blank paper which is more common than one expects, or to share their details such as passwords or the OTP code for Absher or Qiwa that are sent via SMS.”[89]

A former SMASCO worker from India told Human Rights Watch: “Because my contract had ended, I said that I will exit, but I was not informed my contract was extended by the company. From then on, there were many problems.”[90] Another worker said, “I requested the company to provide me an exit [visa], but they told me to [first] pay the visa fee… which was impossible for me.” 

 

According to Saudi regulations, workers who request a final exit visa in the middle of an employment contract will be permanently blacklisted from reentry to the country.[91] Employers, on the other hand, can issue final exit visas in the middle of employment contracts which require workers to leave the country within 60 days, after which they are rendered undocumented and subject to deportation. While workers can file a labor complaint to object to companies’ unilaterally issuing a final exit visa, migrant workers’ ability to file a complaint, secure a hearing, and resolve the dispute with their employer within this timeframe is difficult. Migrant-Rights.org documented cases of workers who resisted unwanted exit visas by filing complaints with the Labor Office after showing a job offer from a new employer and proof of residency in Saudi Arabia for at least a year. [92]

Human Rights Watch spoke to a worker employed in a PIF-funded project who was issued an exit visa by their employer after he expressed interest in changing his job. He told Human Rights Watch, “After being issued the exit visa, I went directly to the company office and requested management to let me transfer my employment, sharing details about the economic situation of my family and my outstanding recruitment loans. They finally agreed and canceled my exit visa.”[93] He said that the wider understanding among workers is that once a worker is issued an exit visa, there is no option but to leave the country and return on a new visa.

Some workers told Human Rights Watch they also fear losing access to their legally entitled end-of-service benefits if they independently apply for an exit visa. One worker said, “If the return is as per schedule and a formal process, you will be provided with end-of-service benefits, but if you [independently] use Absher for exit, you can exit but may lose end of service benefits.”[94] Furthermore, it is also still common for companies to hold on to workers’ passports, despite being prohibited by Saudi law. In the 12-million-member-strong Building and Wood Workers’ International Union (BWI) forced labor complaint to the ILO filed in 2024 against Saudi Arabia, passport confiscation was one of the significant employer violations.[95] One Nepali worker told Human Rights Watch his company demanded four months’ salary to release his passport, while another Indian worker said his company had both his passport and academic certificates which means it “gives the company the upper hand” and that he “won’t be able to quit on bad terms, as they may hold back the documents.”

Workers Denied Documentation

As already noted, employers in Saudi Arabia are legally obligated to provide their foreign employees with a residency permit. When employers refuse to do so, workers face severe restrictions on their freedom of movement and are under constant threat of arrest and deportation.

Under Saudi law, employers are required to apply for migrant workers’ residency permits, known as an iqama in Arabic, within 90 days of arrival. According to interviews, employers fail to do this for several reasons, including a cynical cost-benefit analysis that weighs the high official costs of obtaining permits to employ a foreign worker legally (over SAR 10,500, or $2,800, yearly) and the low likelihood Saudi authorities will punish them for this labor law violation, as well as “Saudization” policies that require employers to hire a mandated percentage of Saudi workers out of a company’s total workforce. If a business does not meet their “Saudization” quota, they are listed by Saudi Arabia’s Nitaqat program as being in the “red zone,” a designation that prohibits them from applying for or renewing foreign worker residency permits, as well as facing other business restrictions (e.g., prohibition from opening new branches or facilities). Migrant origin country actors have raised concerns about the high Iqama fees as one of the drivers of the undocumented status of workers in Saudi Arabia which puts them in vulnerable positions.[96]

One migrant worker whose employer denied him a residency permit sought help from his country’s embassy and is waiting for them to process his exit documents said, “My [supply] company neither gave me regular work nor pay after the first five months and used to just issue short-term iqamas [residency permits] that had to be renewed every three months. Then they asked me for SAR 2,500 [$667] to renew my iqama. When I refused to pay, they kicked me out of the [company] accommodation.”[97]

Saudi citizens are guaranteed a minimum wage of SAR 3,000 ($800) per month for public sector workers and SAR 4,000 ($1,067) for private sector workers.[98] In other words, hiring Saudi workers is significantly more costly than hiring migrant workers in many cases, but companies who do not meet their “Saudization” quotas face costly restrictions. In practice, this dynamic has created a perverse incentive to hire migrant workers without applying for their residency permits, applying only for short-term residency permits that do not match the length of their employment contracts, or to let existing migrant workers’ residency permits expire. Companies’ practice of refusing to provide up-to-date residency permits renders migrant workers undocumented through no fault of their own and vastly increases risks of exploitation, deportation, and situations that amount to forced labor.

On July 29, 2023, the Saudi Ministry of Interior announced new penalties against private entities violating the Saudi Residency Law of 1952, as amended.[99] The new penalties include fines of up to SAR 100,000 (about $26,635), imprisonment of employers for up to one year, deportation for employers who are foreigners, and a five-year ban on the company recruiting foreign workers.

Many workers leave their employers to escape abuse; sometimes they then work at other businesses, but their new employer often refuses to provide the work permit necessary to regularize their status.[100] In some cases, workers are even offered higher salaries than what they earned in their original workplace because they are not being provided their full legal rights under Saudi labor law. According to interviews with migrant leaders and embassy officials, the higher salary can act as an incentive for workers, in exchange for companies deciding not to apply for the worker’s residency permit to avoid the high costs associated with legally recruiting workers and/or to meet their mandate for hiring a designated percentage of Saudi nationals as part of their workforce but puts workers at risk.

One worker who had not been provided the documentation legally due to him and had not been paid for six months said, “[As undocumented workers] we cannot complain that we are not paid. We are forced to stay quiet. We are forced to continue working because it is difficult to let go of salary owed while working in 45 degrees Celsius temperature [outside].”[101] Another migrant leader echoed his views, “Initially, companies or ‘agents’ will attract runaway workers by offering high wages, but they will stop paying workers in full or regularly after a couple of months.”[102]

An undocumented worker described challenges he faced after being denied his legal residency permit: “Without valid documents, everything is difficult. We cannot go shopping too far from our residence. I can’t send money and have to ask friends to do it. We cannot get access to proper healthcare. Even SIM cards cannot be accessed.”[103] He reported not having access to proper healthcare even when he fractured his hand at work. He told Human Rights Watch, “The rules keep changing in Saudi Arabia. But there is no sympathy. No one cares about workers. I am only human. Tomorrow, if I fall sick, I won’t get adequate care. They will ask for my [residency permit]. That is why I want to exit. But it is difficult to exit Saudi Arabia without papers.”[104]

When employers violate Saudi law and deny workers residency permits, the workers are at risk of arrest, detention, fines, and deportation. One worker without the required permit said, "Everywhere they check your ID, so it is just a matter of time before you get caught. Even to send money home, I had to rely on the help of my documented friends.”[105]

While workers without residency permits are entitled to emergency medical care in public hospitals, they are often reluctant to seek such care because medical staff in emergency rooms are required to report them to authorities who may deport them.[106] One migrant leader said, “For non-emergency care, undocumented workers seek paid healthcare services from fellow expat doctors in their networks who have a reputation of overlooking their patients’ documentation status.”

Workers who try to escape an abusive employer risk their employers retaliating against them by filing charges of abscondment against them or submitting additional fabricated charges, such as theft or property damage, which renders them wanted by police.[107]

According to the US Trafficking in Persons (TIP) 2024 report, Saudi law no longer legally allows employers to report workers as having “absconded” as of October 2022 but rather employers can only report them as “discontinued from work.”[108] In those situations, migrant workers have 60 days to change employers or leave Saudi Arabia, after which they are subject to fines, deportation and detention. Previously, they were immediately considered undocumented.

While workers have the right to challenge false absconding charges through the MHRSD labor dispute system, it can be costly, time-consuming and difficult for workers to navigate.[109] According to analysis by Migrant-Rights.org, the 60 day grace period may not be sufficient, and there maybe instances when workers are not even able to use the full grace period to appeal or find new employment as they are not notified about the absconding report filed against them such as when their phone number is not linked to the Government system.[110]

In interviews with migrant workers including migrant leaders, no workers seemed to be aware of this important policy change. On the contraire, Focus group discussions Human Rights Watch conducted with migrant leaders and interviews with former embassy officials revealed that some workers are trapped in Saudi Arabia with false absconding or theft charges. A migrant leader who supports distressed workers said, "Workers are trapped [in Saudi Arabia] because they were slapped with theft charges amounting to thousands of dollars.”[111] He said one of the workers he was trying to support was falsely accused of taking loans from the company which the employer claimed he didn’t repay before running away.

One worker falsely accused by his employer of causing company property damage assessed at an incredibly inflated amount that would make it prohibitive for the migrant worker to be able to repay. After serving time in jail, the migrant worker thought his release meant he would be sent home. Instead, he found out that he could not leave the country. He doesn’t have a job, nor is his visa or iqama card valid. He told Human Rights Watch: “My friends offer me shelter. But even they are scared of being surveilled, so I keep switching locations. Sometimes, I sleep in someone’s vehicle or out in the open.”[112] Workers in his situation have to pay the full amount that their employers allege they borrowed, stole, or damaged in order to leave Saudi Arabia. Otherwise, they must wait for a resolution through the legal system, which can be costly and time-consuming.

Origin country embassies have been overwhelmed with facilitating the exit of thousands of undocumented workers from Saudi Arabia whose employers have not provided the required residency permits or failed to renew them, according to interviews with embassy employees.

Detained workers without valid residency permits often languish in deportation centers.

One worker without a residency permit recalled his ordeal after being caught in 2023, "After being jailed for 17 days, I was finally deported… At one point, I felt like I was on the brink of death. Eventually, I was able to secure a return ticket and left with a few other undocumented workers. We were handcuffed during the journey, and some members of our group even had to return barefoot.”[113]

Another worker hired as a driver said his employer neither issued his residency permit nor helped him obtain his driving license. After driving for 16 months without a license and staying off the authorities’ radar, he was caught and jailed for 26 days. He said, “They just gave us a piece of roti (bread) and inedible lentils twice daily, and half-cooked rice once a day. We drank water from the toilet. I grew weaker by the day but had to force feed myself to stay alive no matter what.” He was finally deported. He described his final journey back home: “Unlike everyone around me at the airport, I came home empty-handed. I did not have money even for bus fare so had to walk to my acquaintance's hotel from the airport in the middle of the night to seek shelter.”[114]

Risks to Migrant Workers’ Health and Safety

Saudi Arabia launched the National Strategic Occupational Health and Safety Program in 2017, which led to the National Council for Occupational Safety and Health (NCOSH), a body created by Saudi Arabia’s Council of Ministers, established in 2022.[115] NCOSH declared that their strategic direction for Saudi Arabia is to “become a global leader and source for building, developing, and applying OHS [occupational health and safety] regulations.”[116] 

NCOSH wrote in a response to Human Rights Watch that the council “comprises 14 government entities and oversees national occupational health and safety efforts” and it claimed that, “Over the past six years, compliance with occupational health and safety standards has significantly improved. Injury rates have decreased by 30.7%, and fatality rates by 70.6%, despite the rapid growth in construction and labor-intensive projects across the Kingdom.”[117]

They further added that a National Occupational Health and Safety Strategy is being adopted to support Vision 2030 projects, including several initiatives like launching a National Occupational Health and Safety Policy, training programs for occupational health and safety specialists, improving reporting of occupational incidents, launching free multilingual awareness programs and year-round campaigns, run year-round campaigns like the midday work ban, and establish a research center with Umm Al-Qura University to address occupational risks such as extreme heat exposure.

Despite the government’s stated commitment to occupational health and safety, migrant workers who would benefit from strong occupational health regulations face myriad dangers at their work sites. In particular, outdoor workers are at elevated risks of extreme heat exposure, a serious health hazard.[118] By its own admission as noted in its Nationally Determined Contribution (NDC), Saudi Arabia is “particularly vulnerable” to climate change as an “arid country with a harsh climate and sensitive ecosystem,” which combined with time-rushed infrastructure projects raises severe concerns about the health and safety of outdoor workers.[119]

A worker employed on a NEOM project said, “Everyday, one or two workers faint, including during mornings and evenings. Sometimes on the way to work. Sometimes while working. People are sweating profusely. The area where we work is a desert. There is no greenery. Hills made of stones. The environment is also like this. It is very hot. There is no AC. The wind doesn’t blow. Even when you find a shaded area, it is hot.”[120] This is despite temperatures in Tabuk being relatively better compared to other parts of Saudi Arabia, according to workers. A former worker supplied to the Red Sea project told Human Rights Watch, “It is not possible to describe the challenges of working in the heat. It is not possible to rest as we please…you drink water and fully cover your face [to finish assigned work].”[121]

Despite the blatant health risks, Saudi Arabia’s Ministry of Human Resources and Social Development (MOHRSD) in partnership with the NCOSH enforces grossly inadequate summer midday work bans that prohibit outdoor work only between June 15 and September 15 and only from 12-3 p.m. as their primary heat protection measure.[122]

Studies show such bans are inadequate to protect workers. One study found that the highest heat intensity for workers in Saudi Arabia was from 9 a.m. to noon, outside the ban hours.[123] Research has shown that authorities should instead adopt and enforce the wet-bulb globe temperature (WBGT) index as the standard for imposing work limitations during periods of extreme heat.[124]

NCOSH wrote in a response to Human Rights Watch that they are currently developing policies for high-risk jobs, incorporating requirements such as periodic medical exams and specialized training. However, regarding Human Rights Watch’s query on whether Saudi authorities have plans to replace the calendar-based midday bans, NCOSH did not mention any plans to do so. Instead, they wrote that NCOSH’s “procedural guide, adopted under Ministerial Resolution No. 196086, includes the Wet Bulb Globe Temperature (WBGT) index as a tool to classify work areas based on temperature and humidity.”

These government midday bans are not only inadequate, but they are not always strictly enforced. At least ten workers reported that employers do not apply mandated midday breaks consistently, including a worker at a NEOM site.

Only a few workers reported additional heat protections applied by their employers that went beyond the inadequate midday work ban. For example, one worker said, “During summer our work-rest schedule depends upon a flag raised [raised by the employer]. If the flag is red they send everyone to rest, stopping the work and keep everyone in A/C… During summer heat, if you work one hour, you may take a 20 minutes rest, if you work half an hour you take 10 minutes rest, there is system like that…”[125] Another worker said that there are “welfare zones” near his worksite that are equipped with water, washroom facilities, and comfortable resting areas.[126] In the hundreds of interviews conducted by Human Rights Watch in Saudi Arabia, workers rarely reported that employers had taken such positive steps to protect them from extreme heat.

Saudi law also mandates additional heat safety measures. Employers with over 50 full-time workers are required to develop health and safety policies in multiple languages, provide free training, conduct risk assessments, assess existing safety controls, and provide personal protective equipment (PPE), drinking water, and first aid equipment.[127] One worker said safety attire was provided “only for the purpose of taking a photograph” while another worker commented on the low quality of the protective clothes that caused excessive sweating and discomfort.[128]

Workers’ living arrangements determine their ability to rest, rehydrate, and recover, which in turn impacts their overall health and well-being. Human Rights Watch research has found that many migrant workers have housing conditions that are often grossly inadequate and do not meet minimal standards. A few workers, especially based at a NEOM project sites, did report having good living facilities. Workers living in inadequate housing compared their accommodations to a “container” or “caravan” where they were “packed like sheep.” Common problems included leaking ceilings and walls, bed bugs, overcrowding, and a lack of ventilation. Shared facilities like toilets and kitchens were usually overcrowded. One worker said, “There was 1 toilet for 35 to 40 people.”[129] A worker employed by SMASCO said, “They used to keep people live sheep in one room. It would be easier to live in a jail. They did not let us go out. Sometimes, there were so many people in a room that we would have to sleep on the floor.” This description was echoed by other SMASCO workers who said the living facilities were relatively better at companies where they were supplied to but inhumane at SMASCO premises.

These conditions are a serious issue in a context where workers are exposed to extreme heat for much of the year, especially in the summer.[130] One worker said, “The air conditioner (AC) [in his room] was in a dilapidated state, and when I requested maintenance, I was told it would only be fixed if I agreed to have the cost deducted from my salary.”[131] Another said, “The room in which I was staying had no windows and no ventilation. There were leaks in the room’s ceiling, and when it rained, water leaked through, requiring us to tap the leaking water.”[132]

Another worker said that the owner often cut off the electricity, likely because “his employer did not pay the electricity [bill]” of the rented space, often making it impossible to cool his living quarters.[133] Access to water was also difficult in certain instances. Some workers had to get water from public places like mosques. A few were compelled to buy 20-liter water jars from a local market.

Workers employed in NEOM projects, however, did not complain about their rooms, citing that the new accommodations housed four people per room and are well maintained. A few also mentioned that they had added amenities such as free laundry and cleaning services, which alleviated the burden of personal chores. One worker employed in a NEOM project said, “It is the same labor supply company, but at the NEOM [project site], they have managed [to provide an] AC, fridge… separate toilet...”[134] He said that 12 people would be housed in a single accommodation at another site, whereas at the NEOM site, a comparable worker residence would include just six people. It will be important to maintain the quality of these accommodations and prevent them from becoming overcrowded as the number of workers increases.

All workers employed in NEOM projects, however, complained about the food they were provided in the mess. “When you cook for tens of thousands, the food won’t be good,” one worker reasoned.[135] One worker described the companies’ uncaring attitude towards inedible workers’ meals that are insufficient to aid in recovering from physically strenuous tasks, while other higher paid “expats” are “fed like kings.”

Another worker employed in a NEOM project said that nutritional deficiencies included “insufficient fluids and fruits” that made workers feel weak and less able to cope with the extreme heat. He added, “They don’t pressure you to work when you are sick. But you cannot stop working just because it is hot either. To the extent possible, you have to work. Working in this heat is not a matter to be taken lightly. Even those who are not working can barely stand in the heat. But we work in this temperature.”[136] Some workers also reported salary deductions if they took sick days off more generally. One worker said, “If I missed a day, they would deduct [salary] for two days.”[137]

Indeed, extreme heat exposure can cause heat rash, cramps, heat exhaustion, or heat stroke, which can be fatal or have lifelong consequences.[138] Migrant workers who faced extreme heat exposure reported harms to their health including nose bleeds, chest pain, fever, dizziness, dehydration, stomach pain, nausea, vomiting, heat rashes, and urinary tract infections.

Migrant workers will be further indispensable in advancing Saudi Arabia’s adaptation efforts to the country’s increasing extreme heat, made worse by climate change.[139] A former Saudi-based air conditioning technician from Pakistan likened his job to an “emergency” occupation as he provided life-saving services when air conditioning broke down especially in cases involving elderly, disabled or sick residents. He told Human Rights Watch, “We strived to reach the residents at the earliest in such situations to address the unique needs of individuals who could not easily relocate.” He paid PKR 300,000 ($1080) for the job but was paid SAR 1,050 instead of the promised SAR 1,400. He recalls the difficulties working in the heat, especially during the first six months in Saudi Arabia, when he faced nosebleeds and vomiting.

Heat can exacerbate pre-existing conditions, impair cognitive function, and increase the risk of workplace injuries.[140] There is also mounting evidence of its link to higher incidence of kidney injuries and chronic kidney disease in outdoor workers exposed to hot environments, including among migrant worker returnees from Saudi Arabia.[141] Extreme heat prevents the human body's attempt to cool off, thereby dangerously stressing kidney and other organs’ critical functioning. The American Society of Nephrology issued a statement on how climate change threatens to increase the incidence and prevalence of kidney diseases, disrupt access to care, and widen inequity to kidney health.[142] Other studies have also shown a higher incidence of kidney injuries in outdoor workers exposed to hot environments,[143] including among migrant returnees.[144]

The health impacts of inadequate and unsafe living and working conditions including exposure to extreme heat can be lasting for workers and their families. Human Rights Watch spoke to seven patients with end stage renal failures believed to be the result of their exposure to extreme heat while working in Saudi Arabia, and none of them had received any compensation to battle this long-term illness.

The wife of one dialysis patient who spoke to Human Rights Watch as her husband was too ill to speak said, “We must provide him with four to five types of medicines but due to lack of funds, we have been unable to purchase everything he needs. As a result, his health has been deteriorating recently.”[145]

She says that other than the daily labor she does off and on that pays her $5.24 per day, her family doesn’t have any source of income. “We have loans to repay, and our children are still in school. We haven’t paid school fees since the last six months.”[146] Her husband’s dialysis is covered by the government, and she told Human Rights Watch, “The [Saudi] company did not provide any assistance beyond booking his [return] ticket.”[147]

Another construction worker said he worked twelve hours a day, including in the heat. He said his company did not provide any safety measures except helmets and gloves although they work above nine stories high: “We had to take care of our own safety, such as tying our shirts around our faces… we were sent to work even in extreme temperatures… if there were any emergencies, there was no one to help us.”[148]

During his vacation, he got himself checked as he had started feeling nauseous in the mornings and had discomfort while standing for extended periods which he thought was related to gastritis, only to find out both his kidneys had failed. “I informed my company about my situation, but they ignored it and provided no benefits, despite being aware of my condition.”[149] He requires dialysis three times a week and has had to move near the hospital which has added to his housing expense. He said, “The working conditions, food, and living conditions in Saudi Arabia made it difficult for me to take care of myself…. My brother still works there [in Saudi] and faces the same situation now.”[150]

Another dialysis patient who spent over 15 years in Saudi Arabia said, “I spent all my end-of-service benefits which totaled around SAR 25,000 [$6,665] on medical treatment.”[151]

Lack of Investigation into Worker Deaths and Lack of Compensation

Human Rights Watch spoke with the wife of a migrant worker who died following a worksite fall that was witnessed by fellow migrants in Saudi Arabia. He was 48 years old at the time and had worked in the same company for 13 years. She told Human Rights Watch, “We did not receive any compensation, and the company has said they will only pay for his end-of-service benefits.”[152]

She was informed by a friend of her late husband that he had collapsed at the work site and passed away in the hospital seven days later. Still in shock, she said, “He had no prior illnesses. He was a strong man.” Such deaths, attributed to “non-work-related causes,” are not compensated.[153]

A Human Rights Watch researcher accompanied the family as they transported the worker’s body back from the capital in a vehicle provided by the government. Throughout the 10-hour journey, the wife struggled to maintain her composure, managing to share a few words intermittently. The entire village awaited the family's arrival for the last rites in the middle of the night. Upon their arrival, she broke down in tears which she had tried to suppress throughout the journey, her loud wail merging with the cries that echoed throughout the village as they watched a few men remove the coffin from the vehicle.

Troubled by the conflicting accounts of her husband’s death and worried about her family’s future, she told Human Rights Watch during the journey home, “If we got compensation, I would have paid for my outstanding loans and to educate my son. There is no one to earn in the family, we are very poor… we have to educate my son and make him capable.”[154] But with the official cause of death attributed to “natural causes” and not work-related despite the worksite fall described by friends who witnessed it at the worksite, there is little hope of any compensation.

Such stories of migrant workers losing their lives in Saudi Arabia are common. Between 2008 and 2022, 13,685 Bangladeshis died in Saudi Arabia, according to Bangladeshi government reports.[155] Between 2020 and 2023, over 10,000 Indians died, according to Indian Government reports.

Click to expand Image

In migrant death certificates, the Saudi authorities classify a large majority of deaths as due to “natural causes,” “heart attack,” or “cardiac arrest” or others. According to non-public Bangladesh government data obtained by Human Rights Watch, 887 Bangladeshis died in Saudi Arabia between January and July 2024, of which 80 percent of the deaths were attributed to “natural causes.” Similarly, according to the Nepal government, 590 deaths out of 870 Nepali migrant worker deaths over a three-year period between mid-2019 and mid-2022 in Saudi Arabia were attributed to “natural” causes.[156]

Saudi Arabia’s Labor Law and Social Insurance Law do not effectively protect workers from health and safety risks, nor do they provide access to compensation for worker deaths because many of the most serious occupational risks such as extreme heat are not categorized as work-related when they occur.[157] Saudi Arabia, similar to other Gulf states that Human Rights Watch has conducted research on, does not sufficiently investigate the cause of migrant worker deaths.[158] Despite the minimal additional costs for employers, Saudia Arabia does not offer workers life insurance options that would provide families with compensation even if the deaths were classified as non-work related as Human Rights Watch has documented in other GCC contexts.[159]

All 14 families of the deceased workers from India, Nepal, and Pakistan that Human Rights Watch spoke to shared similar grievances about uninvestigated deaths. As one Nepali family member of a migrant worker whose death in Saudi Arabia was categorized as due to “natural causes” asked, “How can we say if the death was natural or not? He died in Saudi Arabia, and we didn’t see him.”

Another Indian woman lost her husband in Saudi Arabia when she was five months pregnant with their third child in 2021. She was told her husband died of a heart attack but said, “I have serious doubts about it. Was it due to heart attack or heat... whatever it is, there is a lack of clarity...”[160] She added that he had to take $2,400 as loans for his airfare and quarantine facilities, “Now, only loans are left. I don't know what to say to my children.”[161]

The wife of a deceased Saudi-based Indian plumber who had worked in Saudi Arabia for eighteen years prior to his sudden death said, “He did not have any health issues. We do not believe that he died of natural death as is mentioned in the death certificate. The death was not investigated properly. He was also not provided proper medical care.” There was also no further information provided by Saudi authorities or the employer. Their contact in Saudi Arabia who delivered this news said that the company was not willing to provide any compensation beyond the $3,575 the company sent to the deceased’s wife, who was unsure if this amount included the outstanding wages or the end of service benefits of eighteen years or compensation. She added, “He used to send approximately $536 every month to cover family expenses, education, and outstanding loans. After his death, we are in a state of destitution.”

The son of a deceased Saudi-based migrant worker food packer said, “We came to know about his death when we got a call from hospital from Saudi Arabia. I had spoken to my father on Friday, and he died on Saturday. His health condition was normal he was not taking any medications… I don’t know the actual reason of his death, but everyone tells he died because of a heart attack.”[162]

The son of a Nepali plumber who had worked in Saudi Arabia said that he received video clips of his father’s death as he suffocated on the floor, resembling that “of someone who had consumed poison.”[163] The hospital where his friends took him confirmed his death, and the family received around $2,171 which the son believes is the outstanding wages and benefits. He had just switched to the new company after his previous employer did not pay him his salary for many months. He adds, “My father used to send around [$300-337] each month, as there was not much income at home and his earnings covered groceries and other household expenses.”[164] He stated that his late father was owed money by the former employer where he worked for 12-13 years, but they never received the money or pursued the claim.

It is difficult for families to come to terms with the cause of death, especially when their loved ones had no health problems. The son of a Nepali construction worker who died after 14 years in Saudi Arabia said, “He did not have any health issues nor was he taking any medicines. I spoke to him a day before his death, and he did not mention any health issue… it was a normal conversation.”[165]

Saudi Arabia’s International and National Legal Obligations

International Human Rights Standards

Saudi Arabia has international human rights obligations that are relevant to the concerns documented in this report. While Saudia Arabia has not ratified several core human rights treaties and covenants, including the International Covenant on Civil and Political Rights (ICCPR) and the International Covenant on Economic, Social and Cultural Rights (ICESCR), these instruments constitute authoritative sources and guidelines that reflect international best practice.[166] As a member of the United Nations, Saudia Arabia is also subject to the provisions of the Universal Declaration of Human Rights (UDHR).[167] The rights contained in the UDHR are widely recognized as customary international law, and the UDHR is therefore a common benchmark for measuring a country's human rights performance.

Saudi Arabia is a state party to the Arab Charter on Human Rights, which reaffirms key human rights principles contained in the United Nations Charter, the Universal Declaration of Human Rights (UDHR), and other instruments.[168]

Saudi has acceded to the International Convention on the Elimination of all forms of Racial Discrimination (CERD), the Convention Against Torture (CAT), and the Convention on the Elimination of all Forms of Discrimination Against Women (CEDAW).[169] Saudi Arabia ratified the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime (known as the Palermo Protocol) in 2007.[170] The Saudi government passed legislation criminalizing human trafficking, using the Palermo Protocol definition of trafficking, in 2009.[171]

Freedom of Association

The ICCPR guarantees the right to freedom of expression, peaceful assembly, and association.[172] These rights are also recognized by the UDHR.^[173] Article 23 of the UDHR, states that freedom of association includes the right of everyone “to form and to join trade unions” in order to protect workers’ rights.[174] This right is also codified in the ICCPR (article 22) and the ICESCR (article 8).[175] In the context of the ICCPR, this right has also been interpreted by the United Nations Human Rights Committee, the international expert body that oversees the interpretation of the ICCPR, to encompass collective bargaining by trade unions.[176] Similarly, the CESCR has observed that “collective bargaining is a tool of fundamental importance in the formulation of employment policies.”[177] Article 29 of the Arab Charter also recognizes the right to form and join trade unions and to strike.[178]

Freedom of Movement

Article 12 of the ICCPR states that everyone has “the right to liberty of movement” and is “free to leave any country, including his own.”^[179] Restrictions on these rights can only be imposed when lawful, for a legitimate purpose, and when the restrictions are proportionate, including in considering their impact. Freedom of movement is similarly guaranteed in the UDHR, as well as the Arab Charter.^[180] The Human Rights Committee has stated that the right to leave any country includes the right to obtain the necessary travel documents, such as a passport. Any restrictions must be clearly provided by law, necessary in a democratic society, and proportionate to protect national security, public order, public health, morals, or the rights and freedoms of others, and consistent with all other rights in the Covenant (e.g. equality and non-discrimination). For any limitations to be permissible they cannot negate the essence of the right.[181] While the provision of travel documents such as passports will typically be the responsibility of the country of citizenship, other governments may not create undue obstacles to the exercise of this right and may have obligations to ensure its enjoyment.

The existing kafala system continues to limit workers’ enjoyment of their right to freedom of movement, both in law and in practice. Violations of the right to freedom of movement also interfere with workers’ ability to obtain legal status in host countries and risks jeopardizing other rights such as access to employment, health care, and adequate work conditions.

The Saudi government has an obligation to ensure that migrant workers can leave the country without interference, including by prohibiting exit visas or exorbitant fees that impede migrant workers’ rights. Any restrictions can only be individual, for a legitimate reason, and proportionate – as, for instance, during a criminal investigation.

Nondiscrimination

The ICCPR and the ICESCR guarantee nondiscrimination in the exercise of the rights contained in the covenants. Article 2(1) of the ICCPR, for example, states that “Each State Party … undertakes to respect and ensure to all individuals within its territory … the rights recognized in the present Covenant without discrimination of any kind…”[182] The UDHR recognizes that everyone is “born free and equal in dignity and rights” (article 1) and “is entitled to all the rights and freedoms … without distinction of any kind…” (article 2).[183] Article 7 underscores that everyone is entitled to equal protection of the law “without any discrimination” and has the right to an effective remedy for violations of fundamental rights (article 8).[184] Similarly, under article 2 of the Arab Charter, each State Party undertakes to ensure to all individuals the enjoyment of “all the rights and freedoms contained herein, without any distinction on grounds of race, colour, sex, language, religion, political opinion, national or social origin property, birth or other status and without any discrimination between men and women.”[185]

Conditions of Work and Remuneration

International human rights law guarantees everyone the right to just and safe conditions of work, including reasonable limitations on work hours and fair pay as well as non-discrimination in the workplace. These basic human rights standards are articulated in numerous instruments, including the ICCPR, the ICESCR, and the UDHR, as well as in international labor law discussed below. Article 23 of the UDHR recognizes that everyone has a right to “work, to free choice of employment, to just and favourable conditions of work, and to protection against unemployment.”[186] Similarly, as a state party to the Arab Charter, Saudi Arabia is obligated to ensure that the “free choice of work is guaranteed and forced labour is prohibited.”[187]

The ICESCR states that everyone has the right to enjoy “just and favorable conditions of work,” which include “safe and healthy working conditions.”[188] This right is for “everyone, without distinction of any kind” and “applies to all workers in all settings,” including migrant workers.[189] The CESCR has stated that “preventing occupational accidents and disease is a fundamental aspect of the right to just and favourable conditions of work.” Furthermore, the Committee has underscored that “States parties should ensure that workers suffering from an accident or disease and, where relevant, the dependents of those workers, receive adequate compensation, including for costs of treatment, loss of earnings and other costs, as well as access to rehabilitation services.”[190]

Just and favorable conditions of work in the ICESCR also include “remuneration which provides all workers, as a minimum, with: fair wages and equal remuneration for work of equal value” and also provides workers with “a decent living for themselves and their families.”[191] The ESCR has stated that this provision requires “remuneration that is sufficient to enable the worker and his or her family to enjoy other rights in the Covenant, such as social security, health care, education and an adequate standard of living, including food, water and sanitation, housing, clothing and additional expenses such as commuting costs.”[192] The CESCR has interpreted this provision as imposing a duty on states to establish a minimum wage and has stated that “the failure of employers to respect the minimum wage should be subject to penal or other sanctions.”[193] The Arab Charter similarly states that “every worker has the right to the enjoyment of just and favorable conditions of work which ensure appropriate remuneration to meet his essential needs and those of his family.”^[194]

Although Saudia Arabia is not obliged to guarantee the right to work to non-nationals, once non-citizens assume an employment relationship, they acquire rights as a worker. As such, Saudia Arabia has an obligation to ensure that the provisions of article 23 of the UDHR are guaranteed to all migrant workers without discrimination, including on the basis of their migratory status.

Right to an Effective Remedy for Rights Abuse

International law requires that where rights are violated there be an appropriate remedy.[195] A state’s positive obligations to protect basic rights also requires that measures be taken to deter violations of those rights. Such deterrent measures may be in the form of appropriate and meaningful penalties for those who violate laws that protect basic rights. For example, the ILO Committee on Freedom of Association has specifically called for the enactment of adequate mechanisms and penalties to deter employers from interfering with workers’ rights to organize and bargain collectively, calling on states to enact legislation to “establish sufficiently dissuasive sanctions against acts of interference by employers against workers and workers' organizations.”

International Labor Law

Saudi Arabia became a member of the ILO in 1976 and has ratified seven of the ten ILO conventions setting forth core labor standards.[196] Conventions ratified cover the elimination of forced and compulsory labor, elimination of discrimination in employment and occupation, and abolition of child labor.[197] Saudi Arabia has not ratified critical ILO conventions on freedom of association, right to organize and collective bargaining, and occupational safety and health.[198] Saudi Arabia has also not ratified the International Convention on the Protection of All Migrant Workers and Their Families, states commit to respecting the rights of migrant workers and their families subject to their jurisdiction.[199]

The ILO Convention on Forced Labour defines forced or compulsory labor as “all work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.”[200] According to the ILO, “menace of penalty” can include: “…financial penalties, denunciation to authorities—including police and immigration—and deportation, dismissal from current employment, exclusion from future employment, and the removal of rights and privileges.”[201] Examples provided by the ILO of the involuntary nature of work include: physical confinement in the work location, psychological compulsion (order to work backed up by a credible threat of a penalty), induced indebtedness (by falsification of accounts, excessive interest charges, etc.), deception about types and terms of work, withholding and non-payment of wages, and retention of identity documents or other valuable personal possessions.[202]

One of the ILO’s key objectives is the “protection of workers against sickness, disease and injury arising out of employment.”[203] The ILO has expressed growing alarm at the serious impacts of climate change on the safety and health of workers. In 2024, the ILO stated that:

Heat stress is an invisible killer. It can immediately impact workers on the job, by leading to illnesses such as heat exhaustion, heatstroke, and even death, as has already been witnessed in many regions of the world. In the longer term, workers are developing serious and debilitating chronic diseases, impacting the cardiovascular and respiratory systems, as well as the kidneys. The mental health impacts must also be considered, as well as the numerous accidents and injuries occurring due to reduced cognitive performance, slippery and heated surfaces and unsuitable personal protective equipment (PPE).[204]

The organization has two fundamental conventions that deal with safe work conditions, the Occupational Safety and Health Convention, 1981 (No. 155) and the Promotional Framework for Occupational Safety and Health Convention, 2006 (No. 187) and their accompanying Recommendations No. 164 and No. 197. Saudia Arabia has not ratified Convention No. 155. However, in 2024 it ratified the Promotional Framework for Occupational Safety and Health Convention, which will enter into force for Saudi Arabia on June 4, 2025.^[205] The ILO has stressed that “[a]ll ILO Member States, regardless of ratification status [emphasis added], are expected to respect, promote, and realize the principles of these fundamental Conventions, as “a safe and healthy working environment” is recognized as a fundamental principle and right at work. The Occupational Safety and Health Recommendation, 1981 (No. 164), specifically mentions that measures should be taken regarding the “temperature, humidity and movement of air in the workplace” (Article 3(c)).”[206]

National Law

Saudi Labor Law enacted by Royal Decree No. M/51 of September 27, 2005, regulates the relationship between workers (citizens and migrants) and their employers, along with regulations and ministerial decisions passed to implement and clarify the law.[207] Despite recent reforms to the Saudi Labor Law, migrant workers remain governed by the abusive kafala (visa sponsorship) system. The Saudi kafala system, as in other GCC countries, gives employers excessive power over the migrant workers’ mobility and legal status in the country. This system underpins migrant workers’ vulnerability to a wide range of abuses, from passport confiscation to delayed wages and forced labor.

On July 23, 2009, Saudi Arabia passed its Anti-Trafficking in Persons Law under Royal Decree No. M/40 prohibiting forced labor and exploitative slavery-like practices. The 2009 law sets a maximum prison term of up to 15 years and/or a financial penalty of up to SAR 1 million ($266,000) for trafficking in persons.[208] It uses the internationally accepted definition of human trafficking, as articulated in the UN Trafficking Protocol (Palermo Protocol), and thus criminalizes the extraction of forced labor or servitude, slavery or slavery-like conditions, through the use of force, threats, or deception.[209] However, the anti-trafficking law does little to protect and improve the situation of migrant workers in practice due to poor enforcement.

In a response to Human Rights Watch’s questions on human rights policies in place to protect migrant workers, NCOSH wrote that it “has launched a Comprehensive National Program for Reporting and Investigating Work-Related Accidents, Injuries, and Diseases…” that “outlines roles and responsibilities for handling work-related accidents and diseases which are considered under the responsibility of the employer. It also includes a specialized training program to equip OSH professionals with the tools and techniques to identify root causes, develop corrective action plans, and share lessons learned on an electronic platform.” NCOSH says the platform will be released in the “second half of 2025.”

 

Labor Law

The Saudi Labor Law sets out minimum entitlements for employees working in the private sector, excluding domestic workers and farmers, who are among the least protected and most vulnerable. The law provides for a maximum of 8 hours of work a day and 48 hours per week (after which workers should receive overtime pay), requires 21-30 days of annual paid leave depending on the number of years of service, and sets forth end-of-service payments. Workers who are paid monthly should be paid once a month through accredited banks in Saudi and the Wage Protection System.[210] According to the General Organization for Social Insurance (GOSI), the Wages Protection Program aims to monitor the obligation to pay wages on time.[211] The WPS, in theory, ensures that establishments comply with labor laws and pay employees on time, in accordance with the salaries agreed in their employment contracts and registered with GOSI.

Saudi law also mandates additional heat safety measures. Employers with 50+ full-time workers are required to develop health and safety policies in multiple languages, provide free training, conduct risk assessments, assess existing safety controls, and provide personal protective equipment (PPE), drinking water, and first aid equipment.[212]

The Labor Law sets out conditions workers and employers must meet to obtain valid work permits. Migrant workers must hold work permits issued by the Ministry of Labor covering the duration of the fixed-term employment contract. Following recent reforms to the Labor Law, migrant workers who fall under the jurisdiction of the law can request an exit and re-entry visa or a final exit visa from the Ministry of Human Resources and Social Development without permission from their employer, according to the LRI Services Guidebook.[213]

The LRI also allows some migrant workers to change jobs without employer consent under certain narrow circumstances.[214] Migrant workers falling under the jurisdiction of Saudi Arabia’s Labor Law can change their jobs without obtaining permission from their current employer after completing one year of their contract, when their contract or work permit expires, if the worker has not been paid for three consecutive months, if the employer is absent due to travel, imprisonment, death, or any other reason, if the worker reports a commercial cover-up by the employer, and if labor dispute arises between the worker and the employer and the employer fails to attend two litigation or settlement hearings.

The Labor Law and Implementing Regulations for Recruitment Rules lay out conditions for recruiting workers. It stipulates that employers must recruit workers through a recruitment agent licensed by the Ministry of Human Resources and Social Development. Article 40 places an obligation on employers to bear recruitment fees and other costs like issuing the work permit and exit and re-entry visas and return tickets to the worker’s country of origin after the expiration of the employment contract.

Saudi Arabia has implemented reforms to its complaint and redress mechanisms, including the establishment of fully digitized labor courts. However, migrant workers in Saudi Arabia face barriers to access information such as inquiring about their legal status, filing a labor dispute, lodging complaints about passport and work permit confiscation, reporting abuse, or appealing an absconding case. Saudi’s labor courts hear disputes that fall under the labor law, but do not issue rulings on sponsorship-related cases.[215]

Part eight of the Labor Law on protection against occupational hazards and the relevant Ministerial Decision requires employers involved in construction, oil and gas, and manufacturing employing 50 or more full-time workers to develop and promote a written health and safety policy in the languages most used by the workers as well as Arabic, conduct training for workers free of charge, conduct a review to determine the safety and health risks arising from the work environment, and evaluate whether existing controls are enough.[216] The law also requires the employer to inform workers of occupational hazards, provide drinking water, protective gear, first aid equipment, and training on how to use gear and equipment. The law also requires employers to assume all direct and indirect expenses incurred as a result of a worker sustaining a work injury or an occupational disease. According to the Social Insurance Law issued under the Royal Decree No. M/22 dated 15/11/1969, work injuries are injuries that the worker sustains during work, due to his work, or on the way to and from work.[217]

Article 229 of the Labor Law and Ministerial Resolution No. 92768 dated 5/5/1443 prohibit the confiscation of passports and residence permits of migrant workers and their families and attach a penalty of SAR 5000 ($1,333) on employers.[218] Though illegal, passport and identity document confiscation remain common practice by sponsors.

Despite reforms to the Labor Law, key protections remain absent. The Law does not set a minimum wage for migrant workers. As noted above, international law requires that workers receive remuneration sufficient to ensure an adequate standard of living for themselves and their families and non-discrimination in the application of remuneration. This right has been interpreted to include a minimum wage. A minimum wage would provide workers with clear information about the minimum required payment they can expect to receive from employers before migrating. Minimum wage legislation that is strictly enforced would help prevent exploitation of workers leading to cases of human trafficking.

Saudi Labor Law does not guarantee workers the right to strike. In addition, migrant workers are banned from joining workers’ committees and not allowed to engage in collective bargaining. The Ministry of Human Resources and Social Development also exercises broad powers over Saudi citizens’ right to freedom of association, requiring Saudis who want to establish a workers' committee to obtain the permission of the Minister.[219] The law violates the right of all workers to freedom of association and assembly and discriminates against migrant workers, by further restricting the already-limited rights to Saudi workers, in violation of international law.

Sponsorship Law

Workers’ migration to Saudi and their legal residence in the country are subject to the conditions set forth in the Residency Regulations issued by the Supreme Royal Order No. 17/2/25/1337 dated 11/9/1371. The Residency Regulations require migrant workers to have a Kafeel (sponsor) to enter and stay in Saudi Arabia, otherwise migrant workers can be detained and deported within a week of their detention.[220] Article 26 of the Regulations places an obligation on the sponsor to report “absconding” migrant workers to the Labor Office if the worker misses two days of work without a reason. On October 23, 2022, the Ministry of Human Resources and Social Development announced in a press release an update to the regulations on absconding, stating that migrant workers who have been labelled as absconding will no longer be linked to their employer after the employer submits a request to terminate the contractual relationship and the worker’s status will be updated to “discontinued from work” in the Ministry’s systems.[221] The worker can then change to a new employer or request a final exit visa within 60 days of their employer submitting the termination request.[222] After the 60 days have passed, the worker’s status becomes “absconded” in the Ministry’s systems and workers will be subject to fines, detention, and deportation.
 

Business and Human Rights Responsibilities

While governments have the primary responsibility to respect, protect and fulfill human rights under international law, businesses also have internationally recognized responsibilities regarding human rights and labor rights, including a responsibility not to cause, contribute to, or become complicit in actual or potential adverse human rights impacts, and ensure that any abuses that occur despite these efforts are adequately remedied.

The UN Guiding Principles on Business and Human Rights, which the UN Human Rights Council endorsed in 2011, and the Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises on Responsible Business Conduct are widely accepted as a legitimate articulation of businesses’ human rights responsibilities.[223] Under the UN Guiding Principles, companies should periodically conduct human rights due diligence to identify human rights risks associated with their operations, take effective steps to prevent or mitigate those risks, and ensure that the victims of any abuses have access to remedies.^[224] Under the Guiding Principles, companies have a responsibility to “avoid causing or contributing to adverse human rights impacts through their own activities,” as well as to “seek to prevent or mitigate adverse human rights impacts that are directly linked to their operations, products or services by their business relationships, even if they have not contributed to those impacts.”[225]

NEOM also has its own Code of Conduct that emphasizes the importance of diversity, equality, and inclusion in the workplace.[226] The code applies to all NEOM board members, committee members, executive management, employees, subsidiaries, as well as anyone who does business with NEOM. It mandates a non-discriminatory approach where all employees are expected to treat each other fairly, regardless of race, color, religion, gender, or political beliefs.[227] It adopts a zero-tolerance policy towards any form of bullying, harassment, and sexual harassment, and emphasizes dedication to worker safety, health, and well-being.[228] Employees are required to adhere to safety policies and contribute to a secure working environment.[229] NEOM also states that it prioritizes respect for human rights, ensuring a safe and respectful work environment, and encourages employees to report any violations.[230] The protection of confidential information and adherence to various policies, including anti-bribery and anti-corruption, are also crucial aspects of the Code.[231] Lastly, NEOM stresses that it fosters a culture of transparency and integrity, encouraging employees to speak up against any actions that contradict the Code of Conduct.[232]

NEOM’s code of conduct mentions its commitment to promote and provide a healthy, safe, and secure working environment particularly for vulnerable groups like migrant workers.[233] It also states the company’s commitment to ensure that everyone working on NEOM sites has a contract that adheres to basic international standards and receives all the contractual benefits.[234] In terms of suppliers, NEOM states its commitment to assess the suppliers as needed for compliance with the company’s labor protection requirements and working with the suppliers to improve identified issues, in addition to preventing human trafficking, child labor, and modern slavery from across its business operations and supply chains.[235]

Finally, companies also have their own human rights policies and codes of conduct that they need to abide by. Human Rights Watch, for example, wrote to 10 engineering and consulting companies with planned or ongoing projects in NEOM, Saudi Arabia, 5 of which replied.[236] One of the companies stated that they “do not engage migrant workers in the Middle East” while four noted policies on fair recruitment, discrimination, occupational health and safety, forced labor, and reporting mechanisms. One company noted policies on adequate accommodation and passport retention in addition to the aforementioned policies. Human Rights Watch also wrote to the Saudi Manpower Services Company (SMASCO) and the Saudi BinLadin Group that have no apparent codes of conduct or human rights policies available on their respective websites.
 

FIFA’s Human Rights Commitments

In July 2024, Saudi Arabia submitted its bid to host the 2034 FIFA World Cup as sole bidder.[237] The bid documents included the bid book, Human Rights Strategy, and an Independents Context Assessment to fulfill FIFA bidding requirements.[238] Despite the indispensable role of migrant workers to realize Saudi Arabia’s vision for the 2034 FIFA World Cup, the submitted documents fail to acknowledge serious concerns for workers’ health and safety or meaningfully prioritize strengthening key labor protections.

The bidding documents show the immense scale of construction required for the tournament, including 11 new and refurbished stadiums. Additional infrastructure that will be built includes over 185,000 new hotel rooms and significant airport, road, rail and bus network expansions, as well as the giga-projects envisioned under Saudi Vision 2030.[239] In presenting its bid to FIFA, the Saudi government blatantly ignored well-documented risks that migrant workers face, including those documented in this report, such as serious health and safety concerns, restrictions on the right to movement, and rampant wage theft. The government also failed to acknowledge the absence of key human right protections for migrant workers, such as the right to join a union, to engage in collective bargaining, or participate in protests, rights that are crucial to enable workers to defend their own interests. Although the government submitted a human rights strategy, the strategy not only failed to identify these widespread human rights and labor law violations, but it failed to set out its strategy for remedying these abuses. All three documents are devoid of any nuanced analysis of implementation gaps, and do not indicate any consultation process or include the perspectives of rightsholders.[240]

Human Rights Watch wrote to FIFA and AS&H Clifford Chance that conducted the mandatory human rights impacts assessments as part of the hosting process, detailing concerns regarding the 2034 bid book. FIFA did not respond to letters requesting details on the exclusion of international human rights and labor rights treaties and instruments as part of the assessment process. The law firm said it would be “inappropriate” to offer any comment.[241]

In 2016, FIFA adopted the United Nations Guiding Principles on Business and Human Rights and enshrined its responsibility to respect human rights in article 3 of the FIFA Statutes.[242] In 2017, FIFA adopted a Human Rights Policy stating that human rights commitments are binding on all FIFA bodies and officials,[243] and announced that human rights requirements would be part of the consultation and bid process phases of the selection of the 2026 World Cup host. Bidding countries are now required to submit a human rights strategy in preparing for and hosting the tournament.

FIFA also has human rights responsibilities to remedy abuses it contributes to, under the UN Guiding Principles on Business and Human Rights, and as recognized by FIFA’s own policies:

• Article 3: “In line with the UNGPs [UN Guiding Principles on Business and Human Rights], FIFA will exercise its leverage, and seek to increase said leverage where necessary, in connection with adverse human rights impacts arising through its business relationships. To this end, FIFA will explore and make use of all options available to it within the said relationships.”[244]
• Article 4: “FIFA will strive to go beyond its responsibility to respect human rights, as enshrined in the UNGPs, by taking measures to promote the protection of human rights and positively contribute to their enjoyment, especially where it is able to apply effective leverage to help increase said enjoyment or where this relates to strengthening human rights in or through football.”[245]
• Article 11: “FIFA helps protect those who advocate respect for human rights associated with its activities and is committed to contributing to providing remedy where individuals have been adversely affected by activities associated with FIFA.”[246]
• Article 11: “FIFA will respect and not interfere with the work of both human rights defenders who voice concerns about adverse human rights impacts relating to FIFA and media representatives covering FIFA’s events and activities…. Where the freedoms of human rights defenders and media representatives are at risk, FIFA will take adequate measures for their protection, including by using its leverage with the relevant authorities.”[247]
• Article 5: “Discrimination is an issue in the world of football both on and off the pitch. FIFA strives to create a discrimination-free environment within its organisation and throughout all of its activities.… Article 4 of the FIFA Statutes prohibits discrimination of any kind against a country, private person or group of people on account of race, skin colour, ethnic, national or social origin, gender, disability, language, religion, political opinion or any other opinion, wealth, birth or any other status, sexual orientation or any other reason.”[248]
   

Acknowledgements

This report was researched and written by a Human Rights Watch researcher.

This report was reviewed and edited by Michael Page, Middle East and North Africa deputy director. The report was also reviewed by Joey Shea, Middle East and North Africa Division researcher and Leila Saad, Gulf research assistant in the Middle East and North Africa division. It was also reviewed by Minky Worden, director of Global Initiatives Division, Aruna Kashyap, associate director in the Economic Justice and Rights Division, Nadia Hardman, researcher in the Refugee and Migrants Rights Division, Matt McConnell, researcher in the Global Health Initiative of the Economic Justice and Rights Division, Erica Bower, climate displacement researcher in the Environment and Human Rights Division, Jayshree Bajoria, associate director in the Asia Division and Kayum Ahmed, Program Lead, Global Health Initiative.

Holly Cartner, legal advisor, conducted legal review, and Tom Porteous and Babatunde Olugboji, deputy program directors, provided program review. 

Rothna Begum, former associate director in the Women and Rights Division and Kristine Beckerle, former senior researcher in the Middle East and North Africa division provided specialists review in earlier versions of the report.

An Officer in the Middle East and North Africa Division provided research, editing, and production assistance. The report was prepared for publication by Travis Carr, publications officer.

Ahmed Benchemsi, MENA Communications Director, provided consultation and expertise on report text. Taurai Maduna, video editor and producer in the Multimedia team, produced the multimedia video accompanying the report. Neena Fuchs, deputy general counsel, in the office of the general counsel, Lauren Camilli, general counsel and Anna Sattler, coordinator  in the office of the General Counsel provided legal guidance on the report.

Multiple consultants from Bangladesh, India, Nepal, and Pakistan provided invaluable support to collect testimonies from migrant workers and their families. We are grateful to all the current and former migrant workers and families of deceased migrant workers who were willing to share their experiences.