Disclosing Training Data on Qiwa: What Should Your Establishment Prepare, and How Does a Training Agreement Document the Cost and the Service Commitment?

Who does the ministry's call cover, what is disclosed, where and when?

The call covers private sector establishments with 50 or more workers, and disclosure is made through the Qiwa platform before 31 January 2027, according to the ministry's statement published on 2 November 2026. The duty rests on Ministerial Decision No. 3568 dated 7/1/1445H, whose procedural guide the ministry has published in the knowledge centre on its website, stating that it applies from 18/2/1445H, corresponding to 3 September 2023. The Labor Law Executive Regulation also provides that the employer discloses training data annually and documents it on the electronic platform the ministry designates.

• For the year ending: trainee data, the training programmes, their hours and their costs, as listed in the ministry's statement of 2 November 2026.
• If the establishment ran no programme: a disclosure that it did not, while it remains bound by the mandatory training requirements set by regulation, according to the same statement.
• For the year ahead: the training plans and the budget the establishment commits to training, according to an earlier statement the ministry published on 28 January 2025.
• Minimum length: in its statement of 28 January 2025 the ministry said each trainee receives at least 8 training units a year, and that trainees fall into four groups: workers, students, graduates and job seekers.

The statement of 2 November 2026 noted that this data supports the decision on training graduates and job seekers, which requires covered establishments to train 2% of their total workers. What we did not find on an official page we read, such as how the worker count is calculated, the window after the year end, and the fine amount by establishment size, we have deliberately left out; read it in the procedural guide published on the ministry's website before you rely on it.

Which records should you already hold before you disclose?

The short answer: the Saudi training register, each training documented on the ministry's platform, and a named worker responsible for training activities. These are requirements of the Labor Law Executive Regulation issued by the ministry, a regulation presumed to be in force alongside the Labor Law, whose current version we have not verified with the issuing body. If your records are complete through the year, disclosure becomes a matter of copying ready figures instead of hunting for them in January.

• The Saudi training register: the Regulation lists it among the records the employer keeps at the workplace, on paper or electronically, containing the name, type and length of each training programme, the training year, and the number, names and share of the workers trained on it.
• Training data documented for each worker: the programme's name, type and length, the provider, and the mechanism and method of delivery, within no more than 30 days of the training date on the electronic platform the ministry designates; under the Regulation's wording this applies to an establishment that is bound to train.
• A worker responsible for training activities: the Regulation requires one to be assigned, so name them in a written decision and set out their authority.
• Trainee evaluation: the Regulation requires the trainee to be evaluated at the end of training or during it, and the evaluation to be placed in their file at the establishment.
• A cost file: keep the provider's invoices and the travel and accommodation receipts for each programme, because the ministry's statement asks for costs to be disclosed.

The finance officer has a direct role here: the Regulation provides that the establishment bears all the costs of qualifying or training its Saudi workers, provides travel tickets and living arrangements, or an allowance instead, where the training is outside its location, and keeps paying the worker's wage throughout the training. So open a separate training line in the accounts that lets you extract the cost of each programme and each trainee.

What training policy does the Labor Law ask of every employer?

Article 42 of the Labor Law, as amended by Royal Decree M/44 in force from 20/8/1446H, requires every employer to set a policy for training and qualifying its Saudi workers to raise their skills and improve their level in technical, administrative, professional and other work, and refers the related provisions to the Regulation. The text does not tie this duty to a number of workers, so it is wider than the disclosure call, which concerns establishments with fifty or more workers.

Article 43, in its text after the same amendment, requires every employer to qualify or train in its work those of its Saudi workers who are completing their studies where the employer bears the cost of study, without prejudice to concession and other agreements. The current text of the article states no percentage, and the Executive Regulation leaves percentages and mechanisms to a decision of the minister. Article 44 then sets what a training programme must include:

• The skill the worker is trained in, and the rules and conditions followed in the training.
• The programme's length and number of hours, and the theoretical and practical training programmes.
• The testing method, and the certificates awarded.
• And from the Executive Regulation: a job description of each role's duties and requirements under the Saudi Unified Classification of Occupations, and varied lists of training programmes for each occupation the establishment needs.

In practice, write the policy as a short document that links each role to its programmes, names the training officer, and refers to a written training agreement for every programme that carries a cost or a service commitment. Many establishments keep this policy alongside the internal work regulation (template E-07) so that the rules are announced to workers in one place.

How does a training agreement document the cost and the service commitment?

It is documented by a written agreement signed before the programme starts, stating the programme, the provider, the dates and the cost item by item, and then the service commitment and the repayment clause within the limits the Executive Regulation allows. Article 46 of the Labor Law requires a qualification or training contract to be written and to state the type of occupation, the rights and duties of both parties and where the training takes place; under Article 45 that is a contract in which the employer undertakes to prepare a person for a given occupation. When an existing worker is trained, the written agreement is the evidence of what the two parties agreed. These are its sections:

1. The programme: its name, type, target skill, length and hours, the testing method and the certificate, matching the elements of Article 44.
2. The provider: its name and the training location, in house with trainers accredited by the competent body or at an accredited training centre or institute, inside or outside the Kingdom as the Regulation allows.
3. The dates: the start date and the end date, and how the worker combines training and work if assigned work during the training period.
4. The itemised cost: the provider's fees, travel, accommodation and living costs, and any other item, each with its amount in riyals, stating that the establishment bears these costs and that the wage continues during training.
5. The service commitment: no longer than a period equal to the programme's length where the employment contract is indefinite, or the remainder of the contract where it is fixed-term, as the Regulation provides.
6. The repayment clause: limited to the cases the Regulation lists below, stating that the amount repaid is what was actually spent on the worker.
7. Signature: both parties sign before the programme's first day, and a copy is kept in the worker's file with the evaluation and the certificate.

The rule in the Regulation is that the trainee bears no training related expenses. As an exception, the Regulation allows the employer to charge the worker the training or qualification expenses spent on them in three cases only:

• If the trainee worker decides to end the training or qualification before its set date without a legitimate excuse.
• If the contract is terminated during the training or qualification period under one of the cases in Article 80 of the Labor Law, except its paragraph 6 on a worker appointed on probation.
• If the worker resigns or leaves work during the training or qualification period other than in the cases in Article 81 of the Labor Law.

Note that all three cases fall during the training or qualification period. A worker who leaves after the programme ends but before the commitment period runs out is not expressly named in the Regulation's list, and whether the cost can be claimed from them is a question that needs legal verification, which this guide does not answer. So write the clause in language that describes what the parties agreed without promising an outcome in court.

Which steps should your establishment complete before 31 January 2027?

Start now by gathering the data for the year ending and preparing the plan for the year ahead, then enter it in Qiwa before the deadline the ministry announced. This is an ordered work list you can split between the owner, HR and finance:

1. Confirm your establishment is covered, meaning 50 or more workers according to the ministry's statement, and check how the count is calculated in the procedural guide published on its website.
2. Name the training officer in a written decision and give them access to the establishment's Qiwa account.
3. Pull from the Saudi training register every programme run in the year: name, type, length, provider and trainees' names.
4. Sort trainees by group (workers, students, graduates, job seekers) and by nationality, and total each trainee's training hours.
5. Ask finance for each programme's itemised cost reconciled to invoices, and the total spent on training during the year.
6. Prepare the training plan for the year ahead and the budget the establishment commits to training, and have the owner approve it.
7. Check that every programme with a cost or a service commitment has a signed training agreement, and that every training is documented on the ministry's platform.
8. If you ran no training programmes, disclose that you did not, since the ministry's statement makes disclosure mandatory in both cases.
9. Enter the data in Qiwa before 31 January 2027, and keep proof of submission and its date in the training file.

Which mistakes weaken the establishment's position in disclosure and in any later dispute?

The most common are five mistakes, and they usually surface when the establishment tries to prove a cost or claim it from a worker:

• No written agreement: a costly programme with no document signed before it starts leaves the cost and the commitment open to dispute.
• A lump cost: a single figure that does not show fees, travel and accommodation is hard to reconcile with the invoices and with what is disclosed.
• A commitment longer than the programme: the Regulation caps it at a period equal to the programme's length under an indefinite contract, or the remainder of a fixed-term contract, so do not exceed it.
• Training with no platform record: the Regulation asks for each training to be documented within 30 days, and delay leaves a gap between the internal register and what is disclosed.
• A fine figure taken from the press: the ministry's statement of 2 November 2026 gives no fine amount, and its statement of 28 January 2025 says only that the penalties in the decision apply to a non-compliant establishment. Do not base your decision on a fine table published by a news site or a blog; go back to the ministry's page.

Because the commitment cap depends on the type of employment contract, review the contract itself before drafting the agreement; if the worker is a Saudi on an indefinite contract, the matching template is E-02.

Frequently asked questions