Wills & Estate Planning for Expats in Dubai
If you live in Dubai without a UAE will, Sharia inheritance law applies to your assets by default — even if you are non-Muslim. This guide explains everything you need to know about protecting your estate, your property, and your children.
This Is Urgent — Even for Healthy, Young Expats
Why You Need a UAE Will — Even If You're Not Muslim
Under UAE Federal Personal Status Law, if a person dies without a valid will registered in the UAE, the default inheritance rules are determined by Sharia law — for everyone in the UAE, regardless of religion or nationality. This surprises many expats who assume their home country will covers their UAE assets.
Since 2023, non-Muslim foreigners can choose to have their home country's law apply to their estate in the UAE (through a formal legal declaration), but this requires proactive action — silence means Sharia applies by default.
What Happens Under Sharia Law Without a Will?
Married couple (spouse + children)
Spouse receives 1/8 of estate. Sons receive twice the share of daughters. Non-Muslim relatives excluded.
Married couple (no children)
Spouse receives 1/4 of estate. Rest goes to other prescribed heirs. If no heirs, can be directed to the state.
Minor children (both parents deceased)
A UAE court appoints a guardian under Sharia principles. This could be someone you would not have chosen.
Unmarried partner
Unmarried partners (including long-term partners) receive nothing under Sharia law — regardless of years together.
No family heirs in UAE
Assets can be frozen for months or years pending government review. Bank accounts locked from day of death.
Bank Account Freezing
Upon death, all UAE bank accounts are frozen by law, regardless of whether a will exists. The difference is the duration: with a DIFC will, probate typically takes 2–4 weeks. Without any will, the process can take 6–18 months and may require heirs to travel to Dubai, hire lawyers, and navigate lengthy court proceedings — all while the family has no access to funds.
DIFC Wills Service Centre
The DIFC (Dubai International Financial Centre) Wills & Probate Registry is the gold-standard solution for non-Muslim expats. Established in 2015, it allows non-Muslims to register a will that operates under common law (English law principles), ensuring your assets are distributed exactly as you wish.
As of 2021, DIFC wills can cover all UAE assets (not just Dubai), including Abu Dhabi properties and federal bank accounts. This makes the DIFC the preferred option for most non-Muslim expats in the UAE.
Registration Process
Initial Consultation
Consult with a DIFC Wills & Probate Registry approved practitioner (a will drafter). Discuss your assets, beneficiaries, and wishes. Many law firms offer this consultation free or at a fixed fee.
Draft the Will
Your appointed drafter prepares a will under common law principles (similar to English law). You review and approve. The will can cover Dubai assets specifically or all UAE assets.
Book Registration Appointment
Schedule an appointment at the DIFC Wills & Probate Registry. Both spouses attend separately (for mirror wills). Appointment available online at difcwills.ae.
Execute and Register
Attend the DIFC in person. Bring original passport. The will is signed in front of a DIFC official and registered in a secure, searchable database. Takes 1–2 hours.
Store Securely
DIFC retains a certified copy. You receive a sealed copy. Tell a trusted person where the original is stored. Consider telling your bank and employer's HR department that a registered DIFC will exists.
DIFC Wills — Key Facts
- • Available to non-Muslims only. Muslims follow Sharia distribution by default.
- • Can cover all UAE assets as of 2021 (previously Dubai only).
- • Registered will is legally enforceable in UAE courts without requiring home country court orders.
- • Website: difcwills.ae — book appointments and find approved will drafters.
What Your UAE Will Should Cover
Dubai property (freehold or leasehold)
CriticalA home country will does NOT cover UAE real estate — UAE will is mandatory for property
UAE bank accounts and investments
CriticalAccounts are frozen on death; will speeds up probate from 12 months to 2–4 weeks
Vehicles registered in UAE
Include all vehicles to avoid complications with insurance and transfer
Personal belongings and jewelry
Specify valuable items to prevent disputes between heirs
Business interests in UAE
CriticalShareholding in UAE companies must be addressed — LLC shares pass differently to personal assets
Guardianship of minor children
CriticalThe #1 reason parents with children MUST have a UAE will — see guardianship section
Life insurance beneficiary designations
Life insurance usually bypasses the estate but good to confirm in will
Digital assets and online accounts
Increasingly important — include passwords or a reference to a secure vault
Guardianship of Minor Children — The Most Critical Reason to Act
For expat parents with children in Dubai, the guardianship provision is the single most important function of a UAE will. Without one, if both parents die, a UAE court will appoint a legal guardian under Sharia principles — which may not align with your wishes.
What Can Happen Without a Guardian Nomination?
- A UAE court appoints a guardian — which could be a relative you would not have chosen
- In the absence of suitable relatives in UAE, the process can involve prolonged court proceedings
- Children may be prevented from leaving the UAE while custody is determined
- The guardian appointed may live in a different country, causing further disruption
A DIFC will allows you to name a specific guardian for your minor children in a legally enforceable document. The appointed guardian does not need to be in the UAE at the time of making the will. This provision alone is worth the entire cost of registering a DIFC will.
Property Inheritance
If you own freehold or leasehold property in Dubai, it is classified as a UAE asset and subject to UAE law — not your home country's law. A will made in the UK, Australia, or elsewhere has no jurisdiction over a property located in Dubai.
Without a UAE will covering your Dubai property, title transfer after death requires a UAE court order, which can take 6–18+ months. During this time, the property cannot be sold or transferred, and any rental income may be frozen pending resolution of the estate.
Cost Comparison — Will Registration Options
| Option | Cost | Timeline | Best For |
|---|---|---|---|
| DIFC Wills — Single Will | AED 7,500 | 2–4 weeks | Single expat or married couple each wanting their own will |
| DIFC Wills — Mirror Wills (couple) | AED 10,000 | 2–4 weeks | Married couples wanting identical mirroring wills at a discounted rate |
| DIFC Wills — Full Estate Plan | AED 15,000+ | 4–8 weeks | Complex estates with property, business interests, and multiple beneficiaries |
| Lawyer-Drafted Notarized Will (UAE Court) | AED 3,000–5,000 | 4–8 weeks | Cheaper option; processed through UAE courts; less common for expats |
| Abu Dhabi Judicial Department | AED 2,000–5,000 | 3–6 weeks | Non-Muslims owning assets specifically in Abu Dhabi emirate |
| Home Country Will (no UAE will) | Varies | N/A | NOT recommended — does not cover UAE assets and Sharia applies by default |
Other Will Options
Abu Dhabi Judicial Department
Non-Muslims can register a will with ADJD. Best for assets specifically in Abu Dhabi. Cheaper than DIFC. Less flexible than DIFC in terms of will provisions.
Notarized UAE Court Will
Drafted by a UAE lawyer and notarized at a UAE court. Less common for expats. Works but lacks the searchable registry and streamlined probate of the DIFC system.
Home Country Will
Only covers assets in your home country. Has NO jurisdiction over UAE bank accounts, property, or vehicles. Do not rely on this for UAE assets.
Recommended Law Firms for Estate Planning
Al Tamimi & Company
Largest UAE law firm; full estate planning services; offices across UAE
Baker McKenzie
International firm; strong private client practice; DIFC-licensed
Hadef & Partners
Long-established UAE firm; good track record on wills and probate
BSA Ahmad Bin Hezeem
Specialist UAE knowledge; good for complex business-linked estate planning
Charles Russell Speechlys
UK firm with Dubai office; popular with British expats
Ince (formerly Gordon Dadds)
Specialist private client team in Dubai DIFC
Always request a fixed-fee quote before engaging any firm. Most Dubai law firms offer an initial estate planning consultation at a fixed fee of AED 500–1,500 before any drafting begins.
If You Own Property or Have Children in Dubai — Act Now
Useful Links
- • difcwills.ae — DIFC Wills & Probate Registry (book appointments, find approved will drafters)
- • adjd.gov.ae — Abu Dhabi Judicial Department (for Abu Dhabi asset wills)
- • ica.gov.ae — Federal Authority for Identity & Citizenship (residency and estate queries)