Background: A 1946 Law Meets 2025 Reality

Lebanon's Labor Law has been the country's principal employment legislation since its enactment on September 23, 1946. For nearly eight decades, its core definitions of employer, worker, and working arrangement remained largely unchanged, designed for an industrial economy where work happened in a fixed physical location, during fixed hours, under a clearly hierarchical relationship.

The Lebanese Parliament amended the Labor Law in May 2025 by Law No. 22, dated May 16, 2025. For the first time in decades, core provisions were substantially revised modernizing definitions of the employment relationship, recognizing non-traditional forms of work such as part-time and remote arrangements, and seeking to better align Lebanese labor legislation with international standards.

AMC was part of the process that shaped this reform. As a participant in WE-HUB Lebanon, the EU-funded women's empowerment project implemented by Expertise France and GIZ, AMC contributed to the focus groups that informed the policy brief on flexible work arrangements and labor law amendments. The experience of running Lebanon's first formalized Family Policy, developed under the SAWI project, gave AMC direct practitioner evidence to bring to those discussions: what flexible work looks like when it is implemented seriously, what the barriers are, and what the law needs to say to make it real.

What the Law Actually Changed: Articles 1, 2, and 12

Article 1 — Redefining the Employer

The previous Arabic terminology رب العمل ("master of work") has been replaced with صاحب العمل ("employer") a deliberate linguistic and conceptual shift toward neutrality and alignment with international legal standards. This goes beyond semantics: it reconfigures the employer-employee relationship by removing hierarchical connotations. The amendment also removed the limitation of employment to industrial, commercial, or agricultural projects opening the field of work and no longer tying it to particular project types.

Article 2 — Redefining the Worker

Article 2 redefines the worker as any man, woman, or minor working for a wage, whether full-time, part-time, or seasonal, in person or remotely, and even when using their own equipment. Prior to the amendments, the physical workplace was essential in qualifying an employment relationship. In the absence of a shared workplace, many arrangements risked being classified as contracting agreements, depriving employees of the protections of the Labor Law.

Article 12 — A Flexible Work Framework

Article 12 underwent the most substantial transformation, expanding from a single paragraph into a comprehensive framework of ten provisions. Compressed schedules, part-time employment, seasonal work, and remote work are each addressed separately.

Key provisions: compressed work is permitted where weekly hours do not exceed 48 and rest periods are maintained. Part-time work is formally defined as between one-third and two-thirds of full-time hours with proportional annual leave, settling a longstanding legal debate, and a 50% overtime premium for additional hours. Seasonal work is recognized as a fixed-term contract not exceeding six months. Part-time employees, seasonal employees, and remote workers benefit from the same protections as permanent employees, collective bargaining, occupational health and safety, and protection against discrimination, with rights calculated on a pro rata basis.

WE-HUB, the Labor Law Reform, and AMC's Role

The May 2025 amendments coincide with a broader moment of gender equity advocacy in Lebanon, of which WE-HUB Lebanon is a significant part. WE-HUB is an EU-funded project implemented by Expertise France and GIZ, running from January 2024 to June 2027 with a budget of €6 million, aimed at increasing women's participation in the workforce and advancing legislative reform for gender equity in Lebanon.

Rather than preceding the law, WE-HUB now operates as one of the key frameworks for monitoring its implementation, deepening its impact, and identifying where further reform is needed. Its focus groups in which AMC participated, have brought together employers, civil society organizations, and HR practitioners to examine what the amendments mean in practice: where they protect workers, where they fall short, and what the next legislative steps should be.

AMC's contribution to these focus groups was grounded in direct operational experience. Having already designed and implemented Lebanon's first formalized Family Policy, covering shared parental leave, hybrid work, lactation support, and caregiver leave, AMC brought documented practice to those discussions rather than policy positions in the abstract. What flexible work looks like when implemented seriously, where the legal gaps create friction, and what the law still needs to say to make these arrangements genuinely enforceable.

Lebanon's World Bank WBL 2.0 score stands at 53.8 out of 100, below both the global average of 65.7 and the MENA regional average of 66.0, with room for improvement across all ten indicators. The May 2025 amendments address some of these gaps. The ones that remain are precisely what AMC raised in those WE-HUB focus groups, and what the next legislative cycle must resolve.

The Gaps and Loopholes: What the Law Left Unresolved

No implementing decrees. Seven months after the promulgation of the amendments, the absence of implementing decrees continues to hinder clarity. These decrees are crucial for defining inspection mechanisms, clarifying occupational safety and health protections for remote workers, and operationalizing access to social security benefits for part-time, remote, and seasonal employees. Without them, the law exists on paper but cannot be consistently enforced.

Remote work accident liability — unresolved. It remains unclear how existing workplace accident legislation will apply to remote employees. Applying Legislative Decree No. 136/1983 raises complex questions of liability and insurance coverage, particularly as Article 12 requires employers to maintain insurance covering compensation and medical treatment, yet it is uncertain whether insurers currently offer policies that adequately address accidents in remote, non-controlled workplaces.

NSSF integration for non-traditional workers. The law states that part-time and remote workers shall benefit from social security laws on a pro rata basis, but provides no mechanism for how this works in practice. Lebanon's NSSF systems were built for full-time, single-employer relationships. There is no operational framework for a worker holding multiple part-time positions, or for calculating end-of-service indemnity for a remote worker on a verbal contract. The right was created without the infrastructure to deliver it.

No anti-misclassification protection. The amendments create an incentive for employers to reclassify full-time employees as part-time or seasonal to reduce cost obligations. There is no anti-misclassification provision, no minimum conversion rights for workers whose status is changed, and no penalty for reclassification abuse. Labor inspection capacity in Lebanon is already severely limited; the amendments do nothing to address this.

Maternity and parental leave untouched. The amendments did not touch Articles 28 and 29. The prohibition on wage discrimination under Article 26 includes no enforcement mechanism and no clearly outlined penalty for noncompliance. The intersection of flexible work and parental leave what happens to a part-time employee's maternity entitlement, whether a remote worker retains hybrid return-to-work rights, whether seasonal workers are protected against dismissal during pregnancy, is entirely unaddressed.

Domestic workers remain excluded. Lebanon's domestic workers predominantly migrant women employed under the kafala system remain fully excluded from the Labor Law's scope. For legislation whose stated purpose includes inclusivity and alignment with international standards, this is a significant contradiction that must be addressed.

No right to disconnect. The law introduces remote work without establishing any right to disconnect no limits on employer contact outside working hours, no surveillance protections, no minimum rest period enforcement specific to home-based work. In Lebanon's economic environment, where workers are often in a position of vulnerability, this creates a real risk of boundary erosion for the most flexible workers.

Suggested Amendments: What Should Come Next

Immediate implementing decrees. The Ministry of Labor must prioritize decrees covering remote work inspection mechanisms, occupational health standards for home-based work, NSSF registration procedures for multi-employer part-time workers, and labor inspection protocols for seasonal arrangements.

Remote work accident liability framework. Legislative Decree No. 136/1983 should be amended to address workplace accidents in remote settings with clear definitions of "working time," mandatory insurance provisions for home-based work, and a shared liability framework for equipment and environment choices.

Anti-misclassification protections. Modelled on ILO Recommendation No. 198, a legal presumption of full-time employment should apply absent clear evidence of a genuinely flexible arrangement, with penalties for reclassification without legitimate operational justification.

Maternity and parental leave reform. Articles 28 and 29 should be revised to extend maternity leave to at least 14 weeks in line with ILO Convention No. 183, introduce statutory paternity leave of at least 10 working days, and building directly on AMC's Shared Parental Leave model create a legislative framework for transferable parental leave days between spouses. Lebanon would become one of the first countries in the MENA region to enshrine shared parental leave in national law.

Right to disconnect. A standalone provision should establish remote workers' right to disconnect outside contractually defined working hours, prohibiting employer contact during rest periods and enforcing a minimum 11-hour daily rest period across all work arrangements.

Extension to domestic workers. A dedicated chapter or supplementary law should bring domestic workers within the scope of the Labor Law, consistent with ILO Convention No. 189 on Decent Work for Domestic Workers, which Lebanon has not yet ratified.

Gender pay transparency mechanism. The prohibition on wage discrimination under Article 26 should be strengthened with mandatory gender pay ratio reporting for employers above a defined size threshold, and a clear penalty structure for non-compliance.

AMC's Position

AMC did not observe the May 2025 amendments from the outside. We helped build the case for them, through WE-HUB focus groups, our SAWI-recognized Family Policy, and through years of implementing practices that Lebanese law is only now beginning to formalize.

We support these amendments as an important first step and call on the Lebanese Parliament and Ministry of Labor to move quickly on implementing decrees, and to treat this law as the beginning of a reform sequence not its conclusion. The next step shared parental leaves as national law is one AMC is ready to continue advocating for.

Sources: Law No. 22 of May 16, 2025; Tohme Law — Lebanese Labor Law Amendments (May 2025); Mondaq / Eptalex — Reforming the 1946 Lebanese Labor Law (June 2025); Pearl Recruitment — 2025 Lebanese Labor Law Reforms (October 2025); Expertise France — WE-HUB Lebanon Project (August 2025); World Bank WBL 2.0 Lebanon (2024); Carnegie Endowment — Lebanon's Maternity Leave Gap (October 2025); ILO Conventions No. 183, 189; ILO Recommendation No. 198; Lebanese Labor Law Articles 26, 28, 29; Legislative Decree No. 136/1983.