TL;DR
- The governing document is DM-HSD-GU85-LAC2, version 5.0, issued 30 September 2025 — replacing a version issued only nine months earlier. Dubai Municipality is actively reworking this sector.
- GU85 does not contain its own air or water limits. Sections 14 and 15 route to five other guidelines: GU133, GU44, GU17, GU119 — and the document also references GU81 for pools and GU46 for kitchens.
- Chapter 15 of Dubai Law No. 5 of 2025 applies specifically to workers' accommodation. Article 38(12) requires the owner to provide devices for determining indoor air quality.
- The authority is empowered to take samples from water systems and indoor air during inspection, and to issue or withhold occupancy approvals (Art. 37).
- Net effect: a single site carries five separate compliance regimes, each with its own documents, frequencies and laboratories — and one inspector.
In an office you deal with air quality. In a hotel you deal with pools and Legionella. In a restaurant you deal with food temperatures. Workers' accommodation is the one building type where all of it lands on the same facility manager, on the same site, in the same week — sleeping rooms, kitchens, water tanks, sometimes a pool, and refrigerators with temperature logs. GU85 is the only guideline in the Dubai catalogue that assembles that many regimes in a single document.
1. What GU85 actually is
DM-HSD-GU85-LAC2 — Technical Guidelines for Labour Accommodation Compliance
Version 5.0 · Issue date 30 September 2025 · Superseded issue date 3 January 2025 · Open Data
The version history is worth pausing on. Version 5.0 replaced version 4 after roughly nine months, and the change log lists a comprehensive update covering definitions, control and inspection systems, individual kitchens, water quality and indoor air quality. A guideline revised twice in a year is a guideline the regulator is paying attention to.
Its structure is unusual
Most DM technical guidelines carry their own numbers. GU85 largely does not. Section 14 (Water Quality) and Section 15 (Indoor Air Quality) consist mainly of instructions to comply with other documents:
| GU85 section | Routes to | What that document supplies |
|---|---|---|
| 14 — Water Quality | DM-HSD-GU133-EWS1 | Safety of emergency water systems |
| DM-HSD-GU44-LCWS2 | Legionella control — temperatures, quarterly sampling, bi-weekly reporting to DM | |
| DM-HSD-GU17-DW1 | Quality of unbottled drinking water | |
| 15 — Indoor Air Quality | DM-HSD-GU119-IAQ | Permissible limits for indoor air pollutants |
| Referenced in the body | DM-HSD-GU81-PSPS2 | Public swimming pool safety and water chemistry |
| Referenced in the body | DM-HSD-GU46-KFPA2 | Occupational health and safety in kitchens |
This is the practical problem. To answer "are we compliant?", a facility manager needs six documents open at once, each with its own version number, its own frequency and its own laboratory requirement — and GU85 itself references some of them by outdated version.
2. What Chapter 15 of the 2025 law adds
Dubai Law No. (5) of 2025 devotes an entire chapter to this asset class. Chapter 15, "Health of Workers' Accommodation", runs across Articles 37 to 39.
Powers of the authority — Article 37
- Set the environmental and health requirements for workers' accommodation, including building materials, indoor air quality, water systems, drainage, noise and lighting.
- Inspect, test, calibrate and evaluate the systems, equipment and materials used, and compel the owner to correct violations.
- Supervise and inspect the accommodation and its annexes, including food handling areas, and its staff.
- Take samples from water systems and indoor air to verify compliance with approved standards.
- Issue occupancy approvals only after inspection, and issue the specific permits required for accommodation-related activities.
Duties of the owner — Article 38
Introduced, as in Chapter 13, by the phrase "under penalty of liability":
| Clause | Duty |
|---|---|
| 38(1) | Comply with approved environmental and health requirements, including building materials, indoor air quality, water systems and tanks, drainage, noise and lighting |
| 38(2) | Carry out analysis of water samples as approved by the responsible authority |
| 38(6) | Do not exceed the unacceptable indoor air quality figures, and work to control them |
| 38(7) | Renew the indoor air in accordance with approved indoor air quality standards |
| 38(12) | Provide the tools and devices necessary to ensure the health of the accommodation, including devices for determining indoor air quality |
| 38(13) | Deliver the training and technical qualification programmes approved by the authority for accommodation staff |
Article 39 adds a separate set of duties for the companies occupying the accommodation — meaning the obligation does not sit solely with the property owner where operator and owner differ.
3. The requirements that carry numbers
Where GU85 and the older instruments do give figures, they are these:
| Requirement | Figure | Source |
|---|---|---|
| Minimum space per person in sleeping rooms | 3 m² | GU85 |
| Occupancy above permitted number | AED 3,000 per person over the limit | 2007 bylaw, Table 7 |
| Water tank cleaning | At least once every 6 months, records retained for inspection | 2007 bylaw, Art. 57 |
| Water sample analysis | At least one sample every 6 months, at Dubai Central Laboratory or an approved laboratory | 2007 bylaw, Art. 57 |
| Legionella sampling | Quarterly; aerobic count monthly for cooling water systems | GU44 v6, Table 2 |
| Legionella reporting to DM | Daily records submitted every two weeks to [email protected] | GU44 v6, Section 22 |
| Refrigerators and freezers | Appropriate temperature measurement devices plus a temperature log | GU85 |
| Water tank cleaning contractor | Company approved by Dubai Municipality, with periodic cleaning reports | GU85 |
| Breach of indoor air quality conditions | AED 500 | 2007 bylaw, Table 7 |
| Breach of water quality conditions (non-drinking) | AED 500 | 2007 bylaw, Table 7 |
The fines above are small. The serious consequence is elsewhere: under Article 57 of Local Order 11/2003, the authority issues occupancy permits for collective housing and may cut services and close the building, including cancelling the permit, where requirements are breached. Article 86 allows water and electricity to be disconnected for up to three months. For an operator housing several hundred workers, an occupancy permit problem is not a line item — it is a rehousing operation.
4. The five regimes, side by side
| Regime | What is monitored | Cadence | Needs a laboratory? |
|---|---|---|---|
| Indoor air quality | Pollutants per GU119 v4; devices required by Law 5/2025 Art. 38(12) | Continuous where EIAQI applies; audit at least every 2 years | Yes — EIAQI requires ISO 17025 calibration |
| Legionella | Hot water 50–60 °C, cold below 20 °C, tanks, calorifiers | Daily readings, bi-weekly submission, quarterly sampling | Yes — EIAC-accredited, ISO 11731 |
| Drinking water | Per GU17 | Per GU17 | Yes |
| Food temperature | Refrigerators and freezers | Logged, per GU85 and Food Code | No — but records must exist |
| Pools, where present | pH, disinfectant, per GU81 v3 | Daily before use; microbiology every 2 months | Yes |
Five regimes, four laboratories, at least four different reporting rhythms — daily, bi-weekly, quarterly, biannual — and a single inspector who expects one coherent file.
5. A defensible compliance file
- Get GU85 v5.0 — not version 4. The 2025 revision reworked exactly the sections that matter: water quality and indoor air quality.
- Read Chapter 15 of Dubai Law 5/2025 alongside it. GU85 tells you what to do; Chapter 15 tells you it is the owner's duty under penalty of liability, and that the authority may take samples.
- Check the version of every referenced guideline yourself. GU85 cites some by outdated version — the Legionella guideline is now at v6, issued 19 August 2025. Cross-references inside DM documents are not always current.
- Put the temperature logs on the same footing as everything else. Refrigerator logs are the cheapest item on this list to automate and the most common one to be filled in retrospectively.
- Confirm the tank cleaning contractor is DM-approved and that the cleaning reports are physically in the file, not with the contractor.
- Diarise the bi-weekly Legionella submission. It is the only obligation here measured in days, and the first to lapse when the site is short-staffed.
- Keep one register, not five. The inspector arrives once and looks at the building, not at your five separate folders.
Common questions.
Which guideline governs labour accommodation in Dubai?
DM-HSD-GU85-LAC2, Technical Guidelines for Labour Accommodation Compliance. Current version 5.0, issued 30 September 2025, superseding a version from 3 January 2025.
Does GU85 contain its own air and water limits?
No. Sections 14 and 15 route to other documents — GU133, GU44 and GU17 for water, GU119 for indoor air. The body also references GU81 for pools and GU46 for kitchens. The numbers live in those guidelines.
Is there a legal requirement for air quality measuring devices on site?
Chapter 15 of Dubai Law No. 5 of 2025 sets out the owner's duties for workers' accommodation. Article 38(12) requires providing the tools and devices necessary to ensure the health of the accommodation, including devices for determining indoor air quality. Article 37 empowers the authority to take samples from water systems and indoor air.
What is the minimum space per person?
GU85 requires a minimum of 3 m² per person inside the sleeping room. The 2007 implementing bylaw separately fines occupancy above the permitted number at AED 3,000 per person over the limit.
How often must water tanks be cleaned?
GU85 requires a cleaning contract with a Dubai Municipality approved company plus periodic cleaning reports. Article 57 of the 2007 implementing bylaw requires cleaning at least every six months and at least one water sample analysed every six months at Dubai Central Laboratory or an approved laboratory.
Do the obligations sit with the owner or the employer?
Both. Article 38 addresses the owner. Article 39 sets out a separate list of duties for the companies occupying the accommodation. Where owner and operator differ, neither is automatically off the hook.