Saudization for Holding Groups: How Nitaqat Applies Across Entities

Nitaqat multiple entities is a question every holding group asks: do we get one band for the group, or one per company? On the wording of MHRSD's guides, the unit is the entity, defined by owner and economic activity, and a group of separate companies is not pooled. This page sets out the definition, what follows from it, and where MHRSD is silent.

What counts as an entity under Developed Nitaqat?

An entity is all branches of the same economic activity owned by one establishment. MHRSD's English guide, version 2.0, defines it as the capacity in which the ministry deals with an employer for calculating Saudization, recruitment and transfer of services, and says it "represents all branches of the same economic activity owned by one firm".

Three terms do the work.

The guides we reviewed do not define "commercial registration" (CR). Our reading of the definition is that several CRs held by one company in the same activity sit inside a single entity. A CR held by a different company does not.

Two limits apply to what we can say. The definition groups branches by economic activity, and we found no passage on how a single establishment with two activities is combined. MHRSD's 2026 worked example uses one activity.

Is the entity concept new in 2026?

The word is not new. It already appears in the Developed Nitaqat guide version 2.0, issued under Ministerial Decision No. 182495, which the document gives as published on 11/10/1442 AH. Clyde & Co describes the 2026 guide as moving from establishment-level to entity-based assessment, and the 2026 guide defines the entity in the same terms.

We have not compared the two editions line by line, so we treat the 2026 guide as the operative text. For the cycle dates and bands, see the Nitaqat overview.

How does Nitaqat apply to a holding group with several companies?

Each company is assessed on its own Saudi and total workers. The required percentage follows Y = M ln(X) + C, where X is the entity's workforce, and the target changes continuously with workforce size. The X in that formula belongs to the entity, not to the group, so two subsidiaries face two different targets even in the same activity.

The how Nitaqat is calculated page explains the constants. For groups, three points follow:

• A holding company with few employees is assessed on those few employees. Its own band does not carry down to subsidiaries.
• Subsidiaries in different activities use different constants.
• Two subsidiaries do not combine merely because the same parent owns them. They combine only if they are the same legal person.

MHRSD has published no group-level calculation. That is a statement about the documents, and the ministry could clarify it.

Are profession rules also measured at entity level?

Yes. MHRSD's project management guide applies the rate at entity level and defines the entity in the same words: all branches in the same economic activity owned by a single establishment. Counting therefore happens inside each legal person, across its branches, not across the group. See the project management rule for the 70% test and the trigger of three covered workers.

Can a group pool its Saudis across companies?

On the published rules, no. These are the common beliefs, tested against the definition.

The last row mixes the guide's wording with our analysis. MHRSD has not ruled on restructuring to change a rate.

What happens when staff move between group companies?

Headcount leaves one entity and enters another, so both percentages and both targets change. Three routes exist.

Ajeer permits are not group-wide. Each names one beneficiary. For how third-party staff are counted, the answer in the guides is the same as on our outsourcing page: not stated.

What about mergers and restructuring?

Restructuring can change compliance at entity level, as Clyde & Co warns. If two companies in the same activity merge into one legal person, their workers combine and the target is recalculated on the larger workforce. If one company is split, each part is assessed from its own numbers. Neither case is described in the guides, so model both before filing anything.

A worked example

A group has two subsidiaries, each a separate legal person, in the same activity. Under the project management rule (70%, rounded to the nearest whole number):

Company B fails even though the group total would pass, because the rule is applied entity by entity. The pooled column is shown only to make that point. Moving Saudis from one company to the other changes both counts at once, which is why every transfer needs modeling on both sides.

How should a group plan for Saudization?

1. List every legal person and its registered economic activity as MHRSD has it on Qiwa. That list defines your entities.
2. Run a separate count for each entity: Saudi and total workers, band, and salary-weighted counting. Use the counting rules.
3. Keep one profession register per entity and test each against the rates database and its trigger.
4. Model every intra-group move on both sides before it is filed, including Ajeer placements.
5. Check dates in the Saudization calendar and track each entity's gap to its next target.
6. Plan hires where the gap sits. The levers are in how to meet Saudization targets.
7. Ask MHRSD or Qiwa support in writing about any point the guides leave open, such as multi-activity companies.

This page reports what the guides say and what they leave open. It is not legal advice for your group.