Bahrain’s new health insurance law designed to leave migrants in precarity while ill

Bahrain began implementation of its National Health Insurance Programme for Residents this month. 

Article 2 of the Supreme Council of Health Decision No. 66 of 2026 on the mandatory health insurance packages for residents stipulates that migrants in the following categories — who were issued work or residence permits before 31 October 2026 — will be covered when their permits are renewed and the mandatory health insurance contribution is paid:  

• Migrant workers employed by an employer.  
• Non-Bahraini individuals who employ workers. 
• Workers authorised to work without an employer. 
• Spouses and children under 24 who are financially supported by migrants in the above categories. 

Sponsors/employers of migrant workers must pay the health insurance premium when processing work permits through the Labour Market Regulatory Authority (LMRA). The current fees are BD 90 (USD 240) for a one-year work permit and BD 180 (USD 480) for a two-year permit, with the premium expected to increase further next year. The LMRA then transfers the premiums to designated private insurance companies to provide coverage. 

When a migrant worker transfers to a new employer, the new sponsor becomes responsible for their health insurance. A new policy is issued alongside the new work or residence permit, while the previous policy is cancelled. The LMRA has also established a mechanism to refund - Opens in new tab the health insurance fees corresponding to the remaining validity period of the work permit when a worker transfers to another employer. 

The cost - Opens in new tab of health insurance coverage for family members of migrant workers in the private sector is borne either by the employer or the worker, depending on the terms of the employment contract. 

The new health insurance law raises major concerns over high co-payments, low coverage ceilings and extensive exclusions, including treatment for sexually transmitted infections, organ transplants, immunotherapy, and injuries or illnesses resulting from war, natural disasters, epidemics and pandemics. Work-related injuries are also excluded where costs are covered by employer liability or government social insurance, raising questions about protection for self-sponsored workers who are not tied to a single employer or covered by social insurance. 

A citizens-first approach to healthcare 

Bahrain’s Health Insurance Law No. 23 of 2018 established a broad legal framework for compulsory health insurance, but its implementation has been delayed until this year. In practice, employers continued to meet healthcare requirements for migrant workers through government healthcare fees, which enabled workers to access public health centres and hospitals, or insurance for private healthcare facilities. Under this previous arrangement, migrant workers could access public healthcare by paying relatively low consultation fees, with treatment costs also generally more affordable than those in the private healthcare sector.  

The new insurance scheme offers a defined package of healthcare benefits, with access to services provided through an approved network that includes private healthcare facilities. It also specifies the scope of coverage, applicable contributions, and conditions governing access to healthcare. 

Government-sector employees and their dependents are still covered by the government healthcare facility. The law is silent on the inclusion of domestic workers, though the 2018 Health Insurance Law states that the government is obliged to pay the mandatory health insurance premiums for domestic workers who work for Bahraini citizens.  

Solidarity Bahrain is currently the main health insurance provider. In August 2026, it signed an agreement - Opens in new tab with the Supreme Council of Health as part of the implementation of the programme. The Supreme Council also stated that mandatory coverage would ultimately be provided through standardised insurance packages and a consortium of accredited health insurance companies. 

According to the Chairman of the Supreme Council, Dr. Sheikh Mohammed bin Abdullah Al Khalifa, the shift towards an insurance-based model aims to contribute to reducing the pressure on government health facilities and reducing appointment waiting times. Bahrain’s public healthcare has faced severe operational issues for several years, with a lack of funding not only resulting in long wait times, but also months of unpaid wages for migrant nurses in public hospitals.

Since 2024, the Bahraini government has restricted migrant women’s access to public hospitals for childbirth in certain cases. This year, the government has also begun paying private hospitals to perform operations for Bahraini patients facing long wait times in Salmaniya Hospital, Bahrain’s main public hospital. 

Before the implementation of the new decision, Dr Noor Dhaif, director of the operations directorate at government hospitals, announced - Opens in new tab that migrants would no longer receive treatment at Salmaniya Medical Complex, under the new compulsory health insurance scheme. She added that “the move is expected to free up beds, ease overcrowding and leave Salmaniya treating mainly Bahrainis.” 

There is currently no blanket ban on migrants receiving treatment at Salmaniya Hospital, but the fee for migrant visits to Salmaniya has increased from BD 7 (USD 18) to BD 25 (USD 66). Though they have not formally been excluded from the hospital, the substantial increase in fees makes access to treatment unaffordable for many low-income migrant workers. Migrant workers continue to have access to public clinics, where they are charged a BD 5 (USD 13) consultation fee. 

Medical cost coverage ceiling  

For migrant workers covered by the programme, the mandatory package provides an annual overall treatment limit of BD 15,000 (USD 39,650) per insured person per year. While the amount might seem adequate, the package contains a number of separate sub-limits:  

• Pre-existing and chronic conditions share a combined annual limit of BD 2,000 (USD 5,320). (The definition of a pre-existing condition is also broad, covering an illness, injury or related condition that existed before enrolment, whether or not the person was aware of it.) 
• Outpatient medicines are capped at BD 500 (USD 1,330), while outpatient kidney dialysis is capped at BD 500 annually. 
• Maternity coverage is limited to BD 500 (USD 1,330) for a normal delivery and BD 800 (USD 2,127) for a Caesarean section. Pregnancy coverage also operates within specified age and service conditions. 
• Cancer treatment is covered up to the applicable annual insurance ceiling, while newborn healthcare is covered for the first 30 days following birth under the specified benefit provisions. The package also provides up to BD 1,000 (USD 2,660) towards repatriating the remains of a deceased insured person. 
• While emergency treatment is covered at 100 percent, without a patient deductible or co-insurance, it is subject to the BD 15,000 (USD 39,650) annual limits. The 2026 law is not clear on how much the worker must cover if treatment exceeds this amount.

These sub-limits mean that while the migrant worker with a serious chronic illness could technically have BD 15,000 (USD 39,650) of annual overall coverage for healthcare issues related to pre-existing or chronic illness, only BD 2,000 (USD 5,230) is available for treatment in a given year.  

Tiered co-payments and out-of-pocket costs 

The new health insurance system groups healthcare providers into four tiers; the higher the provider tier, the larger the patient’s share of eligible costs of treatment.  

• Tier 1 – Bronze: 20% patient contribution 
• Tier 2 – Silver: 30% patient contribution 
• Tier 3 – Gold: 45% patient contribution 
• Tier 4 – Platinum: 60% patient contribution 

Insured workers can visit the Supreme Council of Health’s designated website - Opens in new tab to view the list of approved healthcare providers and their respective tiers. Currently, the network includes seven hospitals in the Bronze tier, two in Silver, three in Gold and thirteen in Platinum. 

A general-practitioner consultation carries a fixed BD 5 (USD 13) deductible. The charge is waived when the patient returns to the same doctor for the same condition within seven days, subject to the applicable conditions. Outpatient diagnostics and radiology also involve patient contributions ranging from 20 percent to 60 percent.  

For non-emergency inpatient admissions and daycare treatment at Bronze facilities, patients pay 20 percent, subject to a BD 50 (USD 133) maximum per visit and the applicable annual limit. As per Decision No. 66, the equivalent inpatient contribution caps do not apply in the Silver, Gold and Platinum tier facilities. 

While low-income migrant workers are likely to rely primarily on Tier 1 facilities, even a 20 percent co-payment and out-of-pocket costs of up to BD 50 may remain unaffordable for many. This is particularly significant given that 71 percent of migrant workers in Bahrain’s private sector insured under the Social Insurance Organisation earn less than BD 200 (USD 530) per month. 

Medicines are another area where patients continue to contribute. For approved generic medicines, the insurance covers 80 percent, leaving the patient responsible for 20 percent. For branded medicines, the insurance covers 60 percent, leaving the patient responsible for 40 percent. Both are subject to the package's formulary and the overall outpatient medicine limit of BD 500 (USD 1,330) per year. Again, for a low-paid migrant worker, a 40 percent contribution on medication can become a significant expense, particularly where a prescribed medicine is not available as an approved generic or where treatment continues over a long period. 

Extensive exclusions from the mandatory health insurance package 

The new insurance law contains extensive exclusions that run to eight pages of the law. Among them are routine medical check-ups, most non-emergency dental treatment, as well as genetic and hereditary conditions. Except for emergencies, most mental health treatment — including anxiety, depression and dementia — is excluded.  

Treatment for HIV/AIDS and other sexually transmitted infections is excluded, which is not surprising given that the Bahraini government regularly deports migrants who are HIV positive without providing care. Most forms of hepatitis, organ transplants and related medication, and immunotherapy are also excluded.

The new law also explicitly excludes treatment for injuries and illnesses resulting from war and natural disasters, as well as officially recognised epidemics and pandemics. This is particularly concerning given the ongoing risk of renewed conflict in the region and the potential consequences for migrant workers living in Bahrain, as well as the experience of the COVID-19 pandemic earlier this decade. Under the package, workers may be left without insurance coverage for medical conditions or injuries resulting from such events. 

This exclusion is particularly egregious, as during times of crisis employers renege on their obligations and workers are often not paid fully or partially, making it impossible for them to cover such costs. Countries of origin and individual families then have to handle the aftermath of events that occurred while working in Bahrain. 

Importantly, work-related injuries are excluded from the insurance package where the costs are already covered by an employer’s liability and/or government social insurance, in order to avoid double compensation. This raises questions about the protection available to workers under the self-sponsored Labour Registration Programme (previously known as Flexi-Permit). Although their permits include health insurance for doctor visits at public health clinics, it is unclear whether this provides coverage for work-related injuries, since these workers are not tied to a single employer or included in social insurance.  

More time is needed to assess the new health insurance law. A private hospital administrator told MRRORS that it will take several months for the decision to take effect for many migrants as they renew or issue new work permits. However, as it stands, the provisions of the law suggest that the exclusions have less to do with “raising the efficiency of the use of healthcare and resources”, as government officials claim, and more to do with limiting migrants’ access to public healthcare services to make room for more Bahraini patients, rather than adequately funding public hospitals. Given the exclusions, coverage ceilings and high contributions, the scheme is likely to place an additional burden on low-income migrants and further restrict their access to healthcare.