For years, bribery within private companies in Oman was treated primarily as an employment matter, addressed through Article 146 of the Labour Law. That changed on 29 June 2026. With the entry into force of Royal Decree 66/2026, published in Official Gazette No. 1654 on 28 June 2026, bribery in the private sector is now a fully-fledged criminal offence under the Omani Penal Code.
This is one of the most consequential developments in Omani corporate law this year, and every business operating in the Sultanate should understand what it requires of them.
What the Decree Does
Royal Decree 66/2026 amends the Penal Code (promulgated by Royal Decree 7/2018) by introducing a new chapter dedicated to bribery in the private sector. In parallel, it repeals Article 146 of the Labour Law (Royal Decree 53/2023), which previously governed the matter. The effect is a deliberate migration: what was once a labour law violation, enforced within the framework of the employment relationship, is now a crime prosecuted by the state.
The new chapter applies to private sector companies and institutions, as well as public international organisations headquartered in the Sultanate of Oman. Its reach within those organisations is broad, covering employers, members of boards of directors, and employees alike.
The New Offences and Their Penalties
At the core of the new chapter is the offence of requesting or accepting any consideration – for oneself or for another – in exchange for performing, or refraining from performing, an act falling within one’s work duties. An employer, board member, or employee who does so faces imprisonment of one to three years, together with a fine of no less than the value of what was given or promised.
The penalty escalates where the act in question contravenes the duties of the position: in that case, imprisonment ranges from three to five years, in addition to the fine.
Notably, the law does not require a completed transaction. Merely offering a bribe to an employer, board member, or employee – even where the offer is refused – is itself punishable by imprisonment of three months to one year. The moment of criminal liability begins with the offer, not the acceptance.
Bribers, Intermediaries, and the Self-Reporting Exemption
The decree extends liability beyond the recipient. The person who pays the bribe and any intermediary who facilitates it face the same penalties as the person who receives it. In practical terms, everyone in the chain – the giver, the go-between, and the taker – stands equally exposed.
There is, however, a significant counterweight. A briber or intermediary who reports the crime to the competent authorities before it is discovered is exempt from punishment, and one who confesses after discovery may benefit from mitigation. This exemption is not a technicality; it is a deliberate policy lever designed to break the wall of silence that typically surrounds corrupt arrangements. It fundamentally alters the incentives of anyone involved in, or aware of, a bribery scheme – and it is precisely why companies should want misconduct reported internally before it is reported externally.
Why This Matters for Your Business
The shift from the Labour Law to the Penal Code is more than symbolic. It changes who enforces the prohibition, what is at stake, and how far liability extends.
First, exposure is now personal and criminal. Board members and senior managers cannot treat bribery as a matter to be handled through internal discipline or dismissal; the conduct now carries prison terms for individuals.
Second, the threshold for liability is low. Because an unaccepted offer is punishable, a company’s exposure can arise from a single conversation between an employee and a counterparty, long before any money changes hands.
Third, the self-reporting exemption means that the first party to approach the authorities controls the narrative. Businesses without functioning internal reporting channels are likely to learn of misconduct only when the authorities do.
What Companies Should Do Now
The decree is already in force, so compliance measures should not wait. In our view, three steps are immediately warranted. Companies should review and update their codes of conduct and anti-bribery policies so that they reflect the new criminal framework, define prohibited conduct clearly, and address gifts, hospitality, and dealings with intermediaries. They should train managers and staff – particularly those in procurement, sales, and any function that interacts with third parties – on what the law now prohibits and what the consequences are. And they should establish confidential internal reporting channels, so that concerns surface inside the organisation first and can be assessed and, where necessary, escalated properly.
For organisations with existing compliance programmes built around international standards such as the UK Bribery Act or the U.S. FCPA, the task is one of alignment: ensuring that policies drafted for foreign regimes also satisfy the specific contours of Omani law. For organisations without such programmes, Royal Decree 66/2026 is the reason to build one.
How MRB Law Firm Can Help
Our corporate team advises employers, boards, and compliance functions on the full range of measures the new law calls for – from policy drafting and workforce training to the design of internal reporting mechanisms and the handling of specific incidents. If you would like to assess where your business stands under the new framework, we would be glad to assist.
This article is provided for general information purposes only and does not constitute legal advice. Readers should seek specific legal advice on the application of Royal Decree 66/2026 to their particular circumstances.