Key points
- A UK will does not automatically deal with assets in the UAE, and a will not registered in the UAE may be hard to rely on there.
- Non Muslim expats can register wills with the DIFC Courts Wills Service, the Abu Dhabi Civil Family Court or Dubai Courts, and each has its own scope, language and cost.
- Since 1 February 2023, a federal personal status law lets non Muslim residents follow their home country rules, and sets default shares if there is no will.
- Only a registered will can appoint guardians for your children, and guardian appointments have territorial limits that you should check.
- Keep a UAE will and a UK will in step: written carelessly, the later one can cancel the earlier one.
Yes, in most cases an expat who owns anything in the UAE, or has children living there, should have a will that is registered in the UAE. A UK will may be valid in the UK, but it does not reach UAE assets on its own terms, and without a registered local will you leave the outcome to default rules and to a court process you cannot steer. This guide covers non Muslim expats. If you are Muslim, different considerations apply and you should take advice before registering anything.
Why a will matters here
When someone dies in the UAE, the practical problems arrive before the legal ones. Bank accounts held in the deceased's sole name are generally frozen until the court process produces an authority to release them. Joint accounts can be frozen too, even where the survivor expected to access them. Property, vehicles and business shares must be transferred through the local authorities, which will look for a court order or a registered will. Children's guardianship has to be settled formally. A registered will gives the courts something clear to work from, and it can shorten the period during which a surviving family is without money.
What happens without one
This is the part of UAE law that has changed most in recent years. Federal Decree Law No. 41 of 2022 on Civil Personal Status took effect on 1 February 2023. The government portal describes it as giving non Muslim residents the option to follow the laws of their home country, or alternative personal status laws in force in the UAE, on matters including marriage, divorce, inheritance and custody. Abu Dhabi has its own personal status law for non Muslims, with its own court.
For people who die without a valid will, published legal summaries of the federal law say the default shares are: half the estate to a surviving spouse, with the rest divided equally between children, sons and daughters alike. If there are no children, the parents take, and failing that, siblings. This is a change from the older reliance on Sharia rules, which gave different shares to men and women. Two cautions apply. First, these shares come from published legal commentary, so confirm them against the text of the law. Second, how a court decides between applying UAE default rules and the law of your home country is not something a general guide can settle, because it depends on the emirate, the court, who applies and what is in the file. Muslim residents remain under Sharia rules unless they take specific steps. The DIFC Courts also say plainly that it is not advisable to register a DIFC will if you are, or have ever been, Muslim.
Where non Muslims can register a will, and what it costs
There are several routes, and the right one depends on where you live, what you own and how complicated your family is.
DIFC Courts Wills Service
- Who. Non Muslims who have never been Muslim, with UAE assets or minor children living in the UAE. A UAE residence visa is not required, and the process can be completed virtually from anywhere. The DIFC FAQ gives the minimum age as 18.
- Form. English language wills, signed in front of two witnesses aged 18 or over with photo ID, who cannot be beneficiaries, guardians or their spouses. The signing is done electronically in person or by video call, and the electronic version is the original.
- Types. A Full Will covers movable and immovable property in the UAE and can appoint guardians. Smaller template wills cover up to five properties, up to five shareholdings or up to ten bank or brokerage accounts. A Guardianship Will appoints guardians only. Guardianship cannot be included in the template wills.
- Overseas assets. A Full Will may mention assets outside the UAE, but enforcement abroad is not guaranteed.
- Cost. The DIFC FAQ says registration fees depend on the will type under the published schedule. It states that a modification costs AED 550, that a cancelled appointment costs AED 1,000 non refundable, and that a probate grant costs USD 1,500. Registration fees are not subject to VAT. One 2026 summary of the schedule suggested that a full will for an individual costs several thousand dirhams, with a lower price for each partner in a mirror pair, but please read the DIFC Courts fee schedule rather than relying on that.
- Marriage. Marriage revokes the whole DIFC will unless it states an intention to marry a named person. Divorce cancels gifts to the former spouse, not the whole will.
Abu Dhabi Civil Family Court
- Who. The Abu Dhabi Judicial Department says that anyone who is not a UAE citizen, whatever their religion, can register a will with its Civil Wills Office. It says a civil will must be registered to be treated as valid, and registration is for your UAE estate.
- How. The request is submitted through the Judicial Department website, personally or through a representative with a power of attorney. A video appointment follows, and the certified will is notarised. Forms and templates are in English and Arabic, and legal representation is not mandatory.
- Cost. The page gives AED 950 for a regular will and AED 2,500 for a special will. Press reports say fees can be paid in interest free instalments. Execution of a will is charged on the judicial fee schedule.
- Volumes. Press reports in January 2026 said about 11,000 civil wills were registered in Abu Dhabi in 2025, more than double the previous year, which reflects how quickly this has become normal.
Dubai Courts
Dubai Law No. 15 of 2017 set up a registry for non Muslim wills in both the Dubai Courts and the DIFC Courts, and Dubai Courts accepts registration of non Muslim wills, including through its notary services. Current fees and process should be confirmed directly with Dubai Courts, because they are not set out here. Other routes exist, including ADGM Courts for people connected to Abu Dhabi Global Market and, in some cases, your home country's embassy or consulate.
Choosing between them
- Dubai or Ras Al Khaimah residents with children often look first at the DIFC, because the DIFC guardianship provisions are tied to minors living in those two emirates.
- Abu Dhabi residents generally look first at the Abu Dhabi court, which is set up for that emirate.
- If you own assets in more than one emirate, ask each registry whether the will will be accepted for all of them, because the position between emirates should be confirmed.
- Avoid registering more than one local will unless advised to, so that one does not cancel the other.
Children and guardianship
If you have young children, the guardianship clause may be the most valuable part of your will. In the DIFC, interim and permanent guardians can be appointed in a Full Will or a Guardianship Will, with signed statements from the guardians, who cannot attend the signing. The provisions apply to a child who is habitually living with you in Dubai or Ras Al Khaimah when the will is probated. A guardian named in a UK will is not necessarily recognised in the UAE, and a UAE guardianship order will not necessarily bind the UK. If your family could end up in two countries, take advice in both.
Property, bank accounts and business interests
- Property. UAE property is normally dealt with through a registered will or a court order. Check any mortgage and its life cover.
- Bank accounts. A joint account is not a substitute for a will, because banks may freeze it on death. Think about holding an emergency fund in an account that your spouse can reach, and ask the bank how it handles death.
- Business interests. Shares in a UAE company or free zone company may be subject to the constitutional documents and local rules. The DIFC template for business owners covers up to five shareholdings.
- Digital and other assets. Passwords, cryptocurrency and online accounts are easily forgotten. Record them securely, and ask the registry what it accepts.
- Executors. Choose people who can act in the UAE. An executor who lives abroad and cannot travel is a practical problem.
UK wills, and how the two fit together
A UK will governs UK assets, and a UAE will governs UAE assets. The most common drafting mistake is a UK will that says it revokes all earlier wills, written after, or before, a UAE will that says the same thing. The result can be that one cancels the other. Ask both lawyers to limit each will to the assets in its country, and to include clear language that neither revokes the other. Marriage revokes a will in England and Wales, and the DIFC applies a similar rule, so a wedding is a trigger to review both documents. Scotland and some other jurisdictions differ.
There is also a tax link. UK inheritance tax can reach worldwide assets of someone who has been UK resident for at least 10 of the previous 20 tax years, even after they leave. A will does not change that, but it should be drafted knowing it. Pensions are due to be included in estates for UK inheritance tax from April 2027, so the beneficiary arrangements for UK pensions also deserve a look. Our guide on UK inheritance tax after you leave the UK explains the rules.
Common mistakes
- Relying on a UK will for UAE assets.
- Signing a document and assuming it is registered. An unregistered will is only a draft until the registry confirms.
- Using a template without reading the limits. The DIFC templates cap the number of properties, shareholdings and accounts, and cannot appoint guardians.
- Naming the wrong guardian or executor. Check they are willing, and agree to the role.
- Forgetting marriage, divorce, new children or a new property. These are the events that make a will wrong.
- Naming a beneficiary as a witness. This breaches the registry rules.
- Holding everything in one name. Any survivor is left with a frozen household.
- Assuming Sharia rules always apply. For non Muslims, they no longer do, but the position without a will is still uncertain.
Questions to ask
- Which registry is right for my emirate and for my assets?
- Will this will be accepted for assets in other emirates?
- What does the lawyer or the registry charge in total, including modifications?
- Who can be my guardian and executor, and are they in the UAE?
- How does the will deal with my UK assets, and will it conflict with my UK will?
- What happens to the will if I get married, divorced or move country?
- What do my bank and my property developer need to see when I die?
What to do next
- List everything you own in the UAE, with the name or names it is held in.
- Decide who should inherit, who should be executor and who should look after your children.
- Choose the registry and check the current fees on its website.
- Have your UK will reviewed at the same time, so that the two work together.
- Store the registration confirmation where your family can find it, and diarise a review each year.
Check your UK inheritance tax residence status
Find out whether you count as a long term resident and how long exposure may last.
Open itSources and checks
- DIFC Courts, Wills Service Centre frequently asked questions
- Abu Dhabi Judicial Department, Civil Family Court: civil wills
- Abu Dhabi Judicial Department, frequently asked questions on civil wills
- UAE Government Portal, personal status affairs for non Muslims
- Federal Decree Law No. 41 of 2022 on Civil Personal Status (effective 1 February 2023), as summarised in published legal commentary
- Dubai Law No. 15 of 2017 on the administration of the estates of non Muslims, as summarised in published legal commentary
- Gulf News, report on Abu Dhabi Civil Family Court will registrations, January 2026
- To double check before relying on this article: DIFC minimum age (the DIFC FAQ says 18, some commentary says 21); the current DIFC fee schedule; Dubai Courts fees and process; whether wills registered in one emirate are accepted for assets in another; the default shares without a will under Article 11 of Decree Law 41 of 2022, which were taken from legal commentary; how a court chooses between UAE rules and home country rules without a will.