Owning property in the UAE without a registered will is one of the most common — and most costly — mistakes expatriate investors make. By default, UAE courts can apply Sharia rules of inheritance to assets located in the country, regardless of your nationality or religion. For a married expat with children, that can mean a spouse receives only one eighth of the estate. A registered will allows you to override that default and direct exactly who inherits your UAE assets.
The legal backdrop
Two parallel frameworks apply. The federal Personal Status Law was overhauled in 2020 and again under Federal Decree-Law No. 41 of 2024, allowing non-Muslims to elect the law of their home country. Article 17 of the Civil Code also permits a foreign testator to apply the law of their nationality to movable and immovable assets in the UAE — but only if a properly drafted will is registered with a UAE-recognised authority.
DIFC Wills Service (Dubai and Ras Al Khaimah)
The DIFC Wills Service Centre, set up under DIFC Law No. 5 of 2017, is the most widely used route for non-Muslim expats. A DIFC Will can cover assets in any of the seven emirates and even certain offshore holdings. It is recognised by Dubai Courts, the Dubai Land Department and the RAK Courts via memoranda of understanding.
Key DIFC will types: Full Will, Property Will (up to five UAE properties), Business Owners Will, Financial Assets Will, Guardianship Will for minor children, and the Virtual Registration option for clients abroad. Government fees start around AED 5,000 for a single will and AED 7,500 for a mirror will, plus legal drafting fees.
Abu Dhabi Judicial Department (ADJD) Wills
For Abu Dhabi-based assets, the ADJD Non-Muslim Wills Register opened in 2017 and was strengthened by Abu Dhabi Law No. 14 of 2021 on Civil Marriage and its Effects. ADJD wills are bilingual (Arabic and English), can be registered remotely, and the government fee is AED 950 — materially cheaper than DIFC. ADJD wills are now widely accepted across the emirate.
Dubai Courts Wills Register
A third option for non-Muslims is the Dubai Courts Wills Register, opened in 2020. It is bilingual, accepted at the Dubai Land Department, and the registration fee is approximately AED 2,200. It is a useful middle ground when DIFC fees feel heavy but the testator wants Dubai-court recognition rather than the DIFC common-law overlay.
What a UAE will should cover
- All freehold property held individually or jointly (Palm Jumeirah, Saadiyat, Yas, Reem, Al Reef, Dubai Hills, etc.)
- Bank accounts held with UAE branches
- Shares in UAE-incorporated companies (free zone or mainland)
- Vehicles and high-value personal property
- Guardianship of minor children resident in the UAE
Practical recommendations
- Do not rely on a foreign will alone. UAE courts will require translation, notarisation and sometimes a probate order from the home jurisdiction — a process that routinely freezes bank accounts and property transfers for 6–18 months.
- Match the will to the asset's emirate. DIFC for Dubai and RAK, ADJD for Abu Dhabi, or a single DIFC Full Will if assets span both.
- Update on major life events — marriage, divorce, a new child, or buying a new property.
- Combine the will with a Power of Attorney so a trusted family member can act during incapacity.
For high-value or cross-border estates, a will alone may not be enough — onshore holding structures, ADGM or DIFC foundations, and life insurance written in trust can all play a role. Speak with our advisory team for a confidential review tailored to your portfolio.