Work Prohibited for Juveniles, Their Employment Documents, and the Establishment’s Register

Article 161 of the Saudi Labor Law does not carry a table of named jobs banned for juveniles. Instead, it sets a description of the prohibited work, then delegates to the Minister the task of determining, by decision, the work, industries and professions it covers. What circulates as “the list of work prohibited for juveniles” is, in part, only what the Implementing Regulation offers as examples, not an exhaustive list.

A juvenile, under the definition in Article 2 of the Law, is a person who has completed 15 years of age and has not reached 18. This guide sets out Article 161’s ruling and what the Regulation executes under it, then the documents Article 165 requires an employer to obtain before employment, and the notification and register duties in Article 166. For working age itself, a juvenile’s hours, night work and the educational exception, see working age in Saudi Arabia and limits on employing juveniles.

1. What Article 161 prohibits

Article 161 provides that juveniles may not be employed in:

• hazardous work or harmful industries; or
• professions and jobs likely to expose their health, safety or morals to danger.

The governing condition in this second description is that it is conditional on the nature of the work or the circumstances in which it is performed. The description in the text does not rest on the job title alone, but on its nature or the circumstances of its performance.

The article then provides that the Minister determines those jobs, industries and professions by decision. Determination under the text is conditional on a decision, not on the establishment’s own judgment nor on an agreement with a guardian.

2. What the Implementing Regulation offers as examples

Article 32 of the Implementing Regulation executes this provision, banning the employment of a person who has completed 15 and has not reached 18 in professions and jobs likely to endanger health, safety and morals by their nature or the circumstances of their performance, then opens what follows with the phrase “among which are the following”:

• work in mines or quarries, or extracting mineral substances from underground;
• industries carrying health hazards;
• arduous work;
• work that may expose the juvenile to physical hazards through operating high-risk machinery, such as sharp cutting machines;
• any work that may expose the juvenile to moral, psychological or physical problems by virtue of where and how it is performed.

The phrase “among which” makes what follows examples, not an exhaustive list. In the Regulation, it opens a non-closed enumeration, and the absence of a specific job from these items does not, by itself, establish that it is permitted.

Note too that the Regulation’s enumeration is framed for the 15-to-18 band. The 13-to-15 band is not addressed by this enumeration at all.

These are rulings set out in the Regulation, not in the body of the Law, and attributing them to their correct instrument is part of citing them accurately.

3. This guide did not locate the exhaustive decision

Article 161 delegates the determination of the prohibited work, industries and professions to a ministerial decision. This independent decision was not located by this guide from an official source. Locating its content and its limits is a matter that is referred to the regulatory text and the competent authority.

This has a practical consequence for publishing and drafting: the Regulation’s enumeration should be conveyed as examples from the Regulation. Conveying it as “the work prohibited for juveniles in Saudi Arabia” attributes to it an exhaustive character its text does not carry.

4. Documents before employment: Article 165

Article 165 requires the employer to obtain from the juvenile, before employing them:

• a national identity card, or an official birth certificate;
• a certificate of health fitness for the work required, issued by a specialist doctor and attested by a health authority;
• the consent of the juvenile’s guardian.

The article also provides that these documents must be kept in the juvenile’s own file. Keeping them in the text is tied to the juvenile’s file itself, not to a general folder.

Note that the text makes these documents something the employer obtains from the juvenile, and that their timing is before employment, not after.

5. The health-fitness certificate: two steps in one item

The item on the health-fitness certificate carries two conditions together: that it be issued by a specialist doctor, and that it be attested by a health authority. One without the other does not satisfy what the article provides.

The item also carries a third condition in its own wording: that the fitness is set for the work required, i.e. tied to a specific job rather than to work in general.

As for the identity of the health authority meant by attestation, and the degree of specialization meant by “specialist doctor,” this is a matter that is referred to the regulatory text and the competent authority for the specific case.

6. Notification and the register: Article 166

Article 166 requires the employer to do two things:

• notify the competent labor office of every juvenile it employs, within the first week of their employment;
• keep at the workplace a special register of juvenile workers.

The data required in this register is listed in the article as follows: the juvenile’s name, their age, the full name of their guardian, their place of residence, and the date of their employment.

The one-week deadline here is set in the body of the article itself, not in a decision it delegates to. Its subject is defined in the text: notifying the competent labor office of employing a juvenile.

Note that notification in the text is a step toward an external body, while the register is tied to the workplace. They are two distinct obligations in the article, not two forms of one obligation.

7. What the text does not address

• The ministerial decision that exhaustively lists the work, industries and professions prohibited for juveniles. This guide did not find it, and locating it is a matter that is referred to the regulatory text and the competent authority.
• Whether the Regulation’s examples apply to a specific job at a specific establishment. The specific case is referred to the regulatory text and the competent authority.
• The health authority meant by attestation under Article 165, and what qualifies as a specialist doctor. This is a matter that is referred to the regulatory text and the competent authority for the specific case.
• The form of the guardian’s consent and what documents it. The article does not specify this, and the specific case is referred to the regulatory text and the competent authority.
• The effect of a breach of these articles. No fine amount can properly be stated here; this is referred to the regulatory text and the competent authority.

8. What your system should record

• The national identity card or birth certificate in the juvenile’s file, because Article 165 ties its keeping to that file.
• The health-fitness certificate with its date, who issued it, and the health authority that attested it, because the item carries both conditions together.
• The required work the fitness certificate was issued for, because the text ties it to a specific job.
• The guardian’s consent, and their full name, because the register in Article 166 asks for the full name.
• The date of employment, because the one-week deadline in Article 166 is counted from it.
• The date the labor office was notified, a fact worth adding to the record because it cannot be recovered later.
• The juvenile’s age and place of residence, which are among the register’s data items under Article 166.
• The description of the work assigned to them, because the prohibition in Article 161 is conditional on the nature of the work and the circumstances of its performance.

9. Checklist

• Were the Article 165 documents completed before, not after, the juvenile started work?
• Is the fitness certificate issued by a specialist doctor and attested by a health authority together?
• Does the certificate refer to the specific required work?
• Is the guardian’s consent kept in the juvenile’s file?
• Was the competent labor office notified within the first week of employment, and is the notification date recorded?
• Is there a register of juvenile workers at the workplace, and does it carry the data items Article 166 lists?
• Was the description of the work assigned to the juvenile checked against the prohibition in Article 161, not just against the job title?

10. Why this turns into a problem

The error in this area does not lie in knowing the rule. Part of it lies in reading the Regulation’s examples as a closed list, so that a job’s absence from them is taken to mean it is permitted. The phrase “among which” does not support that inference, and the standard operating in Article 161 is the nature of the work and the circumstances of its performance.

Part of it lies in the fact that all of these articles are conditional on facts with dates: the date each document was obtained, the date of employment from which the one-week deadline is counted, and the date of notification. These are facts that are not recoverable after the event; they are either on record when they happen, or they are not.

Add to that the fact that the documents themselves are tied in the text to the juvenile’s file, not to a general folder for the establishment. Each employee’s file is the container Article 165 sets for these papers.

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For working age, a juvenile’s hours, night work and the educational exception, see working age in Saudi Arabia and limits on employing juveniles. For the wider framework on workplace inspection and an establishment’s duties, see labor inspection, and for a work injury and an employer’s liability, see work injury under the Saudi Labor Law. For more guides and templates, browse the HR resource center.

Frequently Asked Questions

What work is prohibited for juveniles under the Saudi Labor Law?

Article 161 bans employing juveniles in hazardous work or harmful industries, and in professions and jobs likely to expose their health, safety or morals to danger by their nature or the circumstances in which they are performed. Determining those jobs, industries and professions is conditional in the text on a decision from the Minister.

Is there an official, exhaustive list of this work?

Article 32 of the Implementing Regulation offers an enumeration that opens with the phrase “among which are the following,” and this phrasing makes what follows examples, not an exhaustive list. The ministerial decision that Article 161 delegates the exhaustive determination to was not found by this guide, and locating it is a matter that is referred to the regulatory text and the competent authority.

What examples does the Implementing Regulation give?

Article 32 of the Regulation lists work in mines or quarries and extracting mineral substances from underground, industries carrying health hazards, arduous work, work that may expose the juvenile to physical hazards through operating high-risk machinery such as sharp cutting machines, and any work that may expose them to moral, psychological or physical problems by virtue of where and how it is performed. These are examples from the Regulation, not from the body of the Law.

What documents are required before employing a juvenile?

Article 165 requires the employer to obtain from the juvenile, before employing them, a national identity card or an official birth certificate, a health-fitness certificate for the required work issued by a specialist doctor and attested by a health authority, and their guardian’s consent. These documents must be kept in the juvenile’s own file.

Must the labor office be notified when a juvenile is employed?

Article 166 requires the employer to notify the competent labor office of every juvenile it employs within the first week of their employment. This deadline is set in the body of the article itself.

What data does the register of juvenile workers include?

Article 166 requires keeping a special register of juvenile workers at the workplace, and its data is listed in the article as the juvenile’s name, their age, the full name of their guardian, their place of residence, and the date of their employment.

Regulatory references

This guide is based on the Saudi Labor Law issued by Royal Decree M/51 dated 23/8/1426H, in its updated text: Article 2 (definition of a juvenile), Article 161 (hazardous work, harmful industries, and the delegation to the Minister), Article 165 (documents before employment), and Article 166 (notification and the register); and to the Labor Law’s Implementing Regulation, Article 32 (examples of prohibited work).

On the effect of the amendments made by Royal Decree M/44 of 1446H, in force since 19 February 2025: none of Articles 161 to 167 carries an amendment footnote in the updated text, and none of them appears in the official amendments table. This chapter stands as originally enacted under Royal Decree M/51.

This guide is regulatory explanation, not legal advice. In an active dispute or a specific case, the regulatory text and the competent authority remain the reference.