What happens without a UAE will
If you die in the UAE without a locally registered will, your family has to go through the courts to establish who inherits, which can take many months and involve translation, legalization and government fees. Your personal bank accounts, including joint ones, are frozen until the court issues an order, and if you have young children, the court will decide who looks after them. Inheritance follows the default rules set by law, which may not reflect what you wanted, and a will made in your home country may not be accepted for UAE assets unless it meets local requirements.
Muslims and non-Muslims
For Muslims, inheritance and guardianship follow Sharia principles, and although a will can be registered with the Personal Status Court, it must stay within those rules. Some Muslim families use structures such as a DIFC or ADGM foundation for longer-term wealth planning. Non-Muslims have far more freedom under the UAE’s non-Muslim personal status law, and can leave assets to anyone, including friends and charities, provided the will states clearly how the estate should be handled.
The DIFC will
The DIFC Courts register wills for non-Muslims, whether or not they live in the UAE, under common law principles and in English only. Registration includes an online video hearing attended by you and two witnesses, and the will can name assets worldwide, although other countries may not honour it for property within their borders, so take local advice there. The DIFC is also the only one of the three that lets you amend a registered will instead of replacing it, though its fees are typically higher than the other options.
The Dubai Courts will
A Dubai Courts will is prepared in Arabic and English, with the Arabic version taking legal priority, and it lets a non-Muslim resident choose either the law of their home country or the UAE law for non-Muslims. You usually need to prove family relationships with marriage and birth certificates that have been attested and translated into Arabic. After your death, your heirs still open an inheritance case to obtain a succession certificate, but a registered will makes that case noticeably quicker.
The Abu Dhabi will
The Abu Dhabi Judicial Department registers bilingual Arabic and English wills for residents and non-residents, and only you need to attend the video hearing, with no witnesses required. As with Dubai Courts, you can opt for the law of your own nationality or the UAE rules for non-Muslims. Visitors face some limits, for example on which assets they can cover, and may need to provide a title deed for any property they name. Its main attraction is that heirs can usually re-register assets without a full inheritance case.
The key differences at a glance
Each authority runs its own process, so compare them against your assets, residency and family situation. These points tend to decide the choice for most expats.
- Legal basis: common law at the DIFC; home-country law or UAE non-Muslim law at Dubai Courts and Abu Dhabi
- Language: English only at the DIFC; Arabic and English elsewhere
- Hearing: you plus two witnesses at the DIFC; you alone at Dubai Courts and in Abu Dhabi
- After death: an inheritance case at Dubai Courts; a simpler re-registration route for DIFC and Abu Dhabi wills
- Changes: amendments allowed at the DIFC; elsewhere you cancel the old will and register a replacement
- Costs and timings: these differ between authorities and change, so check the current figures
Decisions to make before you register
Whichever route you choose, a few decisions shape how well the will works for your family. Registration is handled online and includes identity verification by video, so have your documents ready in advance.
- Consider mirror wills if you are married, especially with children or jointly owned assets
- Name an executor and guardians who are at least 21, ideally living in the UAE
- Add two or three alternates in case your first choices cannot act
- Cover all movable and immovable UAE assets, including future and off-plan property
- Appoint a guardian for any minor beneficiaries, who inherit under supervision until they reach 21
How we can help
We can help you compare the three options, prepare a will that suits your circumstances and arrange its registration. If you live abroad, we can also explain what each authority will need from you.