Ssenkayi Marvin Ezra
Uganda’s employment law has received its most significant overhaul in nearly two decades. On 29 April 2026, the President assented to the Employment (Amendment) Act, 2025, a wide-ranging piece of legislation that updates the Employment Act, Cap. 226, which has been in force since 2006.
The amendments address gaps that have grown more apparent over time, such as inadequate protection for casual and domestic workers, unclear rules on dismissal, weak safeguards for Ugandans working abroad, and the absence of explicit protections against other forms of workplace harassment beyond sexual harassment. The changes also bring Uganda’s labour laws closer in line with international labour standards and the East African Community Labor framework, especially regarding sick leave.
So, what exactly has changed and what does it mean in practice?
1. A Broader Definition of the Workplace
The Act now formally defines a “workplace” to include not just permanent indoor locations such as offices, factories and shops, but also temporary worksites, open-air locations, fields, roads, oil refineries, and mobile workplaces such as trucks, aircraft freight decks and ships. This expanded definition matters because the protections in the Act now apply across all these settings.
The Act also formally defines “domestic work” and “domestic worker”, bringing this previously unregulated category of worker within the full scope of labour law protections for the first time.
2. Stronger Protections Against Harassment and Intimidation
All employers have always been required to have a sexual harassment policy. Under the amended Act, that policy must now be displayed in a conspicuous place at the workplace, not merely kept on file.
Going further, a new section 6A expressly prohibits employers and their agents from harassing or intimidating any employee. The Act defines harassment broadly to include written, verbal or physical abuse, as well as behaviour that creates an intimidating, hostile or offensive working environment. Intimidation covers conduct such as:
- Degrading public tirades by supervisors
- Insults relating to personal or professional competence
- Threatening or insulting communications, including by email
- Desecration of religious or national symbols
- Withholding food or basic necessities to which the employee is contractually entitled
- Conduct that insults the modesty of an employee
Breach of these provisions is a criminal offence.
3. Clearer Rules for Casual and Domestic Workers
A new provision sets a hard limit on casual employment: no person may be employed as a casual employee for a continuous period exceeding six months. Critically, if an employer dismisses a casual worker and then rehires the same person, the employment is treated as continuous. Employers cannot use brief gaps to reset the clock.
After six months of continuous casual employment, the employer must either move the worker onto a regular contract or lawfully terminate the employment.
The Act also introduces formal recognition of piecework contracts, which allow payment to be calculated by the amount of work completed rather than by time spent. Domestic workers and casual employees are now expressly included in the minimum protection provisions of the Act.
4. Regulation of Recruitment Agencies Sending Workers Abroad
A new Part IVA introduces a comprehensive licensing framework for agencies that place Ugandan workers in employment outside the country. The key requirements are as follows.
- Licensing
No person may operate a recruitment agency placing workers abroad without a licence from the Minister of Labour. Licences are valid for two years and are subject to renewal. Only companies incorporated under Uganda’s Companies Act, Cap 106 may apply. Companies that are insolvent, whose licences were cancelled in the last five years, or whose directors have been convicted of illegal recruitment or human trafficking are disqualified from obtaining a licence.
- Operational requirements
Licensed agencies must orient workers on terms and conditions before any contract is signed, ensure contracts are witnessed by the worker’s next of kin, verify that recruited persons have the skills the relevant job requires, maintain comprehensive records of all persons recruited, and ensure workers complete pre-departure training at an institution accredited by the Ministry of Gender, Labour and Social Development.
- Repatriation clause
Every employment contract for work abroad must include a repatriation clause guaranteeing the employee’s return at the employer’s expense when the contract ends or is terminated, or, in the event of the employee’s death, that their remains will be repatriated.
- Appeals
Individuals aggrieved by a ministerial decision under Part IVA may appeal to the High Court, whose decision will be final.
5. Extended Sick Leave Entitlements
The old three-month sick leave framework has been replaced by a structured six-month regime.
An employee who falls sick is entitled to full pay for the first two months of illness. If sickness continues, the employer is entitled to pay half the employee’s monthly wages for the subsequent four months. If the sickness extends beyond six months, the employer may terminate the contract of service, but only after first obtaining an opinion of a medical doctor and complying with all contractual obligations up to the date of termination.
This is a significant improvement on the previous entitlement and brings Uganda closer to international minimum standards.
6. Breastfeeding and Childcare Facilities
Every employer is now required to make available at the workplace time, space or a facility for breastfeeding and childcare for employees’ children between the ages of three months and thirty-six months. The Minister is empowered to prescribe operational standards for these facilities by regulation.
7. Overhauled Termination and Dismissal Framework
This is arguably the most consequential part of the amendment for both employers and employees.
- Expanded grounds for termination
The grounds on which an employer may lawfully terminate a contract now expressly include redundancy (covering closure of business, reorganisation of work, introduction of labour-saving devices, changes in work patterns, or a reduced need for employees), sickness lasting more than six months that renders the employee unable to perform their duties and situations where continued employment would lead to a breach of a statutory obligation.
- New grounds for dismissal
New grounds for summary dismissal now include abscondment from duty (absence of more than thirty consecutive days without permission or knowledge of the employer, presentation of forged documents or unqualified representations at the time of recruitment, and conduct inside or outside employment that may adversely affect the employer’s business.
These grounds are not exhaustive however and employers retain the discretion to dismiss for any other grounds stated in the contract of employment.
- Mandatory pre-dismissal hearing
Before any dismissal, employers must now follow a formal procedure. The employer must: explain the reasons for dismissal to the employee in a language they understand; allow the employee to have a person of their choice present; and give the employee five working days to prepare a defence.
Failure to follow this procedure results in an automatic liability of four weeks’ net pay, regardless of whether the dismissal was substantively justified. This penalty is separate from any other remedy.
Statutory definitions of unfair and wrongful dismissal
The Act now provides clear statutory definitions of both concepts:
- Unfair dismissal: dismissal for any reason other than those listed under the Act’s grounds for dismissal
- Wrongful dismissal: dismissal where the employer has not fulfilled contractual obligations and has not complied with the Disciplinary Code in Schedule 2 of the Employment Act
8. Probationary Employment
Two important changes apply to probationary contracts. First, if an employer does not formally extend a probationary contract but continues to pay the employee after the probationary period lapses, the employee is deemed to have been confirmed in employment. Second, the payment in lieu of notice required to terminate employment during a probationary period has been extended from seven days to one month.
9. Standardised Severance Pay
Severance pay entitlements have been expanded, and the calculation standardized. The rate is now one month’s salary for each year worked. Previously, the amount was heavily dependent on contractual terms and judicial discretion, leading to unpredictable outcomes.
The expanded grounds entitling an employee to severance pay now include termination by the employer due to physical incapacity or redundancy, and termination of a contract by a labour officer where the employer has refused to pay wages.
10. Redundancy Notice
Employers intending to make redundancies must notify the Labour Commissioner at least thirty days before the scheduled termination date. This is a new statutory requirement.
11. Increased Compensation for Unfair Dismissal
The basic compensatory order that a Labour Officer may award upon a finding of unfair dismissal has been doubled, from four weeks’ wages to eight weeks’ wages. Labour Officers’ orders may now also be executed directly in the Industrial Court.
12. Regulation of Migrant Workers in Uganda
A new Part IXA regulates the employment of non-citizen workers in Uganda. The Minister may, by Gazette notice, declare categories of jobs that migrant workers may not be offered. The National Citizenship and Immigration Board is prohibited from issuing entry permits for declared job categories unless the worker holds an exemption certificate from the Commissioner.
Exemptions are available where a bilateral or multilateral agreement applies, or where the job requires a particular skill not held by any Ugandan citizen. Employing a migrant worker in a declared job category without an exemption certificate is a criminal offence.
13. Changes to Labour Dispute Resolution
The amendment removes arbitration as a mechanism for resolving individual employment disputes. Dispute resolution is now consolidated around the labour officer adjudication pathway and the Industrial Court.
Under the revised framework, only the complainant may request a referral to the Industrial Court if a dispute is not resolved by a Labour Officer within three months of the dispute being reported.
What Employers Should Do Now
The amendments introduce a number of new compliance obligations that employers should begin preparing for. In particular, employers should:
- Review and update their sexual harassment policies, and ensure the policy is displayed visibly at the workplace
- Audit their use of casual labour to ensure no worker has been, or will be, employed on a casual basis for more than six months continuously
- Update dismissal procedures to incorporate the mandatory pre-dismissal hearing requirements
- Review employment contracts to ensure probationary periods, notice provisions and severance calculations reflect the new statutory requirements
- If operating a recruitment agency placing workers abroad, obtain the required licence and comply with the new operational obligations
- Prepare for redundancy procedures, including giving the required thirty-day advance notice to the Labour Commissioner
Note on Commencement
As at the date of publication, the commencement date of the Employment (Amendment) Act, 2025, is yet to be gazetted. Employers and employees are advised to monitor the Uganda Gazette for the appointed date from which these changes will take legal effect.