Auditing Your HR Policies Against Somaliland’s Labour Law
By Idil Ibrahim Aden, Founder & Managing Director, Shaqo Kaab Solutions
Somaliland’s employment framework is anchored in the Labour (Amendments & Additions) Law, No. 31/2020, which repealed and updated the earlier Private Sector Employees Law (No. 31/2004) (International Labour Organization, n.d.). For employers — particularly banks, NGOs and growing enterprises operating across multiple jurisdictions — the practical challenge isn’t knowing that the law exists. It’s knowing whether internal HR policy actually reflects it, and where the gaps sit.
Why this matters beyond legal risk
Labour law compliance is often framed purely as risk avoidance — avoiding disputes, penalties or reputational damage. That framing understates the point. A labour law aligned HR framework is also an operational asset: it gives managers clear, defensible ground to act on, gives employees clarity on their entitlements, and gives the institution a coherent basis for consistent decision-making across departments and, for multi-branch employers, across locations.
Areas the law addresses that HR policy should mirror
Based on the current legislative framework, Somaliland’s labour law sets out requirements across several areas that employer policy should be checked against:
- Employment contracts — contract types, required terms, and registration procedures.
- Working hours and overtime — normal working hours, overtime arrangements and night work provisions.
- Leave entitlements — annual leave, public holidays, sick leave, maternity leave and family responsibility leave.
- Wage payment — timing and protection of wage payments to employees.
- Termination and resignation — notice requirements and procedures for both employer- and employee-initiated separations.
- Workplace health and safety — including specific provisions addressing HIV/AIDS in the workplace.
- Foreign worker recruitment — work permit and registration requirements where relevant.
- Dispute resolution — mechanisms for employee complaints, and the role of the Labour Directorate in inspection and enforcement.
- Freedom of association — provisions relating to labour unions and their federation structures.
An HR policy audit should go through each of these areas and ask a simple question: does our written policy say something specific and correct here, or does it say nothing at all? Silence in a policy manual is not neutral — it usually means the institution is relying on ad hoc practice, which is exactly what creates inconsistent treatment of employees and exposure during a dispute or inspection.
A practical starting point
We would recommend employers treat this as a structured audit rather than a general read-through: map each policy area above against the corresponding section of the law, note where policy is silent, outdated, or inconsistent with practice, and prioritise the gaps that carry the highest exposure — typically termination procedures and wage payment, since these are the areas most likely to surface in a dispute.
This is not a one-off exercise. Labour law compliance should sit inside the same governance cycle as financial and regulatory compliance — reviewed on a set schedule, not only when a problem has already occurred.
Note: this post summarises the areas covered by Somaliland’s labour law at a policy level. It is not legal advice, and specific clauses, thresholds and procedural requirements should be confirmed against the current legislative text or with qualified legal counsel before being applied to a specific employment decision.
Reference
International Labour Organization. (n.d.). Somaliland Labour (Amendments & Additions) Law, No. 31/2020 [NATLEX record]. https://natlex.ilo.org/dyn/natlex2/r/natlex/fe/details?p3_isn=112608
