Employment relationships in the private sector in Bahrain are regulated principally by the provisions of Bahrain Law No. 36/2012 on the Issuance of the Labour Law in the Private Sector.

The scope of application of the provisions of Bahrain Law No. 36/2012 are not geographically restricted to Bahrainis and non-Bahrainis who are engaged in employment activities in Bahrain, but also applies to Bahrainis employed abroad where the contract of employment is made subject to the laws of Bahrain.

In fact, the provisions of Bahrain Law No. 36/2012 will, as a matter of public order, continue to apply to any employment relationship in Bahrain even where the parties have agreed to subject it to a foreign law. This was confirmed by the Bahraini Court of Cassation in a series of challenges such as BCC 773/2010 and BCC 776/2010, wherein it was held that: