AI and Restructuring in the GCC: Can Employers Rely on AI to Make Workforce Decisions?

Artificial intelligence is rapidly becoming part of the modern HR toolkit. Organisations are increasingly using AI-enabled systems to analyse workforce data, identify restructuring opportunities, forecast future workforce needs and support decisions relating to recruitment, performance management and organisational design.

For multinational employers operating in the GCC, however, an important question arises: how far can AI be relied upon when making employment decisions?

While the UAE, Saudi Arabia and Qatar continue to promote AI adoption as part of wider national digital transformation strategies, employment laws across the region continue to place responsibility for employment decisions squarely on employers. There is currently no comprehensive framework regulating the use of AI in employment decision-making across the GCC. Instead, employers remain accountable under existing labour laws for ensuring that employment decisions are lawful, objectively justified and implemented through appropriate procedures.

AI can support decision-making, but it cannot replace it

Many employers are already using AI to support workforce planning by identifying duplicate roles, analysing organisational structures, modelling different restructuring scenarios or reviewing employee performance data.

These tools can help employers process large volumes of information more consistently and efficiently than traditional manual approaches. However, AI outputs should be treated as one source of information rather than the decision itself.

Ultimately, decisions regarding restructuring, redundancy, termination or redeployment remain management decisions for which the employer is legally responsible.

Employers should therefore ensure that AI-generated recommendations are reviewed critically, tested against business realities and supported by independent human judgement before decisions are implemented.

Existing legal obligations still apply

Although the GCC has not yet introduced employment-specific AI legislation comparable to developments in some other jurisdictions, existing employment obligations continue to apply regardless of whether AI is involved.

Across the region, employers remain responsible for ensuring that employment decisions:

• are supported by legitimate business reasons;
• comply with applicable contractual and statutory obligations;
• follow any required procedural steps;
• are appropriately documented; and
• can be justified if challenged before the relevant authorities or courts.

The use of AI does not reduce these obligations.

Managing the risk of bias

One of the greatest risks associated with AI-assisted decision-making is that systems may unintentionally reinforce existing patterns or produce outcomes that disproportionately affect particular groups of employees.

This can be particularly relevant in the GCC, where workforces are often highly international, comprising employees of different nationalities, languages, ages and backgrounds.

Employers should therefore avoid relying exclusively on automated scoring or ranking systems when identifying employees for restructuring or other employment decisions. Instead, organisations should regularly review AI outputs, validate the criteria being applied and ensure that any recommendations are tested against objective business considerations before decisions are finalised.

Governance matters as much as technology

Increasingly, the question is not whether employers use AI, but whether they use it responsibly.

Organisations should establish clear governance over the use of AI in HR decision-making by defining:

• where AI may appropriately be used;
• who remains accountable for employment decisions;
• when human review is required;
• how AI outputs should be documented; and
• how AI systems are periodically reviewed for consistency and accuracy.

These governance measures are likely to become increasingly important as regulators continue to develop AI strategies across the region.

Practical steps for employers

As AI becomes more integrated into HR functions, employers should consider:

• reviewing existing HR technologies to understand where AI is already influencing employment decisions;
• ensuring meaningful human oversight over AI-assisted decisions;
• validating AI outputs before implementing restructuring or redundancy decisions;
• documenting the rationale for decisions and the role AI played in the decision-making process;
• training HR teams and managers on the appropriate use of AI; and
• monitoring future legal and regulatory developments across the GCC.

Looking ahead

The GCC continues to position itself as a global leader in AI adoption, and employers are likely to make increasing use of AI across the employment lifecycle. At the same time, employment regulators and courts will continue to expect organisations to demonstrate fairness, accountability and sound decision-making.

For employers, AI should therefore be viewed as an important decision-support tool rather than a substitute for management judgement. Organisations that combine technological innovation with strong governance, transparent processes and effective human oversight will be best placed to realise the benefits of AI while managing legal and operational risk.