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Royal Decree 78/2025 allows a court to suspend or dissolve a legal person found liable, in an economy that runs on 1.8 million expatriate workers and a $50 billion project pipeline.
Oman’s Law on Combating Human Trafficking, issued by Royal Decree 78/2025 and published in the Official Gazette in September 2025, replaced a framework that had stood since 2008. Most of the coverage went to the sentences: three to ten years and fines of OMR 5,000 to OMR 100,000, rising to seven to fifteen years and OMR 10,000 to OMR 100,000 where the victim is a child, where an organised group is involved, where a public official abuses their position, or where the offence crosses a border.
The provision that changes the commercial calculation sits further down. Where a legal person is found liable, the fine runs from OMR 10,000 to OMR 100,000 and the court may order the suspension of the entity’s operations or its dissolution.
Consent stops being an answer
The clearest published reading of the statute has come from a lawyer who watched it move. Dr Mohammed bin Ibrahim Al Zadjali holds a doctorate in criminal law, sits on the roll of advocates admitted before Oman’s Supreme Court, has led the Omani Lawyers Association since 2014, and chaired the legislative and legal committee of Majlis Al Shura. He is founding partner of Mohammed Ibrahim Law Firm, which runs labour, corporate and construction practices from offices in Muscat and Sohar, and in March 2026 he was endorsed as secretary general of the GCC Lawyers Union.
Writing in Times of Oman, he set out the definition the law now uses, covering exploitation, slavery, forced labour, domestic servitude, organ removal and sexual exploitation, and noted that the law provides expressly that “a victim’s consent is irrelevant in cases where trafficking involves coercion”, deception, abuse of vulnerability, or the exploitation of children or persons lacking full capacity. Muscat Daily
That is the sentence employers should read twice. The instinctive corporate defence in a labour dispute is documentary: the worker signed the contract, accepted the terms, agreed to the deduction. In the circumstances the law names, the signature no longer settles the question.
Where the exposure actually sits
Exposure here is a function of scale. National Centre for Statistics and Information data put the expatriate workforce at 1.81 million in May 2025, with construction the largest employer at 436,301, wholesale and retail trade at 272,774 and manufacturing at 179,418. Expatriates make up 43.4 percent of Oman’s population.
Very few of those workers are recruited directly by the company that ultimately employs them. Agents, subcontractors and labour suppliers sit in between, and it is in that layer, in recruitment fees, contract substitution and document retention, that trafficking indicators are usually found. The law reaches legal persons; the conduct that triggers it typically happens two contracts away from the boardroom.
Then there is what Oman is building. Nine large-scale hydrogen projects are onboarded in Al Wusta and Dhofar, representing roughly $50 billion of investment. In June 2026 the Duqm special economic zone signed ten agreements worth about $7.5 billion, including OMR 1.6 billion for ACME’s next green hydrogen phases and OMR 30 million for a residential city built to house one steel producer’s workforce. Projects of that size arrive with lenders, offtakers and insurers who ask about labour.
The enforcement direction
The record shows where scrutiny is heading. The US State Department’s 2025 Trafficking in Persons report kept Oman at Tier 2 and credited a specialised trafficking court and the first investigations of labour trafficking involving migrant workers since 2023, while identifying labour cases as the weaker half of the file. The national committee’s allocation for its action plan rose to OMR 144,180 from OMR 100,000.
A second front opened in June 2026. Marking the world day in Al Roya, Al Zadjali pointed to Articles 43 and 45 of Royal Decree 61/2026, the new Information Technology Crimes Law, which aggravate penalties where websites and information systems are used to commit or facilitate trafficking. He read it against this year’s United Nations theme, which centres on victims recruited through fake job advertisements and forced into online fraud, and against UNODC findings that 74 percent of traffickers operate inside organised networks. The Royal Oman Police have described dismantling a network that lured victims with false overseas employment before compelling them to smuggle narcotics.
The case against urgency
The counterweight is real. The law is less than a year old, no suspension or dissolution of a company has been reported under it, and the police say incidence in Oman remains limited. Buyer-side pressure is not arriving on schedule either: the European Union’s due diligence regime was narrowed by Directive (EU) 2026/470 to companies above 5,000 employees and 1.5 billion euros in turnover, with application pushed to July 2029. No counterparty is forcing this conversation in 2026.
What has changed is the shape of the downside. A wage claim costs money. A finding against the entity costs the entity. Recruitment-chain diligence, contract review and a functioning grievance channel are cheap by comparison, and they are the only part of this an employer controls.
