What a PMC is actually accountable for on a UAE construction site

Supervision is not substitution

The most common misunderstanding on a UAE project is that once a Project Management Consultant is appointed, safety becomes the consultant's problem. It does not. Federal Decree-Law No. 33 of 2021 places the duty to provide a safe workplace, safe equipment and instruction on the employer of the workers — in practice the contractor and each subcontractor for their own people.

What the PMC holds is a supervision and assurance role, defined by the executed contract: review deliverables, verify that agreed controls are in place, record what is found and escalate what is not resolved.

Where the emirate rules put the consultant

Dubai Decree No. (19) of 2025 concerning safety in construction work and Dubai Law No. (3) of 2026 concerning the quality and safety of buildings both describe duties across the delivery chain rather than resting everything on one party. That is why a PMC scope written in generic terms causes trouble later: the consultant's specific duties should be read from the executed contract alongside the applicable legislation, not assumed.

In Abu Dhabi, work sits within the ADOSH-SF (formerly OSHAD) framework, which expects entities to run a documented occupational safety and health management system with defined responsibilities. A consultant's assurance plan is easiest to defend when it maps onto that structure.

The four things a PMC should be able to produce on request

Authority visits and client audits tend to test the assurance trail rather than the consultant's opinion.

• The approved contractor HSE plan and the record of the review that accepted it.
• Pre-start gate records: what had to be in place before a high-risk activity was allowed to begin.
• Inspection and audit findings with severity, owner, due date and evidence of close-out.
• The escalation record — what was stopped, who was told, and when it was resolved.

Getting the boundary in writing

The practical control is a responsibility matrix agreed at mobilisation that names, per activity, who performs, who verifies and who is informed — and states plainly that verification does not relieve the performing party of its duties. Our PMC section sets out that matrix, the 30-day setup sequence and the assurance system behind it.

Put it to use