For non-Muslim expats in the UAE, the simplest will and the most comprehensive one have different purposes. Here is how to tell which one fits your situation.
If you are a non-Muslim living in the UAE and you have not registered a will, the law decides who inherits your assets and who raises your children. That is true even if you have a will back home. Most expats we speak to assume their home-country will covers their Dubai flat, their company shares and their local bank account. It usually does not, at least not without months of delay.
This guide walks through what happens if you do nothing, the routes available to put a proper will in place, and the answer to the question we hear most often: the DIFC will costs more, so is it worth it over the Abu Dhabi route?
What happens if you die without a will
Since Federal Decree-Law No. 41 of 2022 on Civil Personal Status came into force in February 2023, a non-Muslim who dies in the UAE without a will is no longer subject to Sharia distribution by default. A secular, gender-neutral civil formula applies instead. That was a genuine improvement. But a formula is still not the same as your choice, and the practical problems remain:
- Your accounts are frozen. Personal and often joint bank accounts are frozen on death while heirs are verified. That freeze can run for months, cutting your family off from everyday funds at the worst possible time.
- Your assets are split by a fixed formula. The civil default commonly gives the surviving spouse a share and divides the rest among the children. Your specific wishes, a larger share to your spouse, a gift to a sibling, a business passing to one child, are not read in.
- A court decides guardianship. With no guardian named in a will, a court decides who cares for your minor children, rather than you choosing in advance.
For anyone with a mix of assets, a company, property, and accounts, the estate does not just move slowly. It stalls in several places at once. The Dubai Land Department will not transfer title without a recognised succession order. Company shares cannot move without a clear instrument, so ownership and signatory control freeze. A registered will is what unlocks all of it.
Your options as a non-Muslim expat
There are five main routes. They differ in coverage, language, enforceability and cost, and those differences matter more than the headline price.
- DIFC Wills Service – a common-law registry in Dubai. English language. Covers worldwide, all assets. The most comprehensive route.
- ADJD non-Muslim will (Abu Dhabi) – a civil notarised will. Bilingual. Covers UAE-wide assets. A straightforward, notarised route.
- ADGM Courts notary route – the same ADJD will, registered through ADGM’s digital notary.
- Dubai Courts notarised will – the local emirate route. Bilingual.
- Your home-country will – governs your home assets. Does not cleanly cover UAE assets on its own.
Everything below assumes a non-Muslim testator. Sharia-compliant estate planning for Muslims is a separate regime.
The DIFC Wills Service: the most comprehensive route
The DIFC Wills Service sits inside the Dubai International Financial Centre’s common-law framework. Your will is an English-language document, registered with a dedicated wills and probate registry.
What you get:
- A Full Will covers all of your worldwide moveable and immoveable assets in a single instrument, with no need to list each asset.
- Specialised wills are also available if you prefer: Property, Business Owners, Financial Assets, Guardianship and Digital.
- Strong guardianship provisions, including the ability to appoint an interim guardian for your children.
- Under Dubai Law No. 2 of 2025, DIFC probate orders are enforceable directly, including against banks and the Dubai Land Department, often within about a month for a straightforward estate.
- UAE residence is not required to register.
Cost (government registration, VAT-exempt, single / mirror):
- Full Will: AED 10,000 / 15,000
- Property Will: AED 7,500 / 10,000
- Guardianship, Business Owners, Financial Assets or Digital Will: AED 5,000 / 7,500
- Amendment: AED 550
Legal drafting is charged separately from the registry fee and it is charged depending on the complexity.
The Abu Dhabi route: the ADJD non-Muslim will
The Abu Dhabi Judicial Department (ADJD) registers a civil, notarised non-Muslim will that disapplies Sharia and lets you direct your estate and appoint guardians. It is the route many expats have heard about when they start comparing options.
What you get:
- A notarised will covering the distribution of your estate and the guardianship of your minor children.
- It can be registered by a Dubai resident and can cover assets across the UAE.
- Registration is fully remote, by video call, with a QR-verified certificate.
- The document must be bilingual, in Arabic and English, prepared by a Ministry of Justice-certified translator.
Cost: AED 950 for a single will, AED 1,900 for mirror wills, plus the mandatory legal translation and any drafting. Probate later runs through the ADJD Wills and Probate Office, and a grant of probate follows where the assets are located.
A common point of confusion: the “ADGM will.” Many people believe ADGM runs a separate common-law wills registry like DIFC. It does not. ADGM Courts operates a digital Notary Public and Wills Office in partnership with ADJD, and it notarises the same non-Muslim will. The fee through this channel is AED 950 to ADJD plus USD 155 to ADGM Courts per will. So “DIFC versus ADGM” is really “the DIFC common-law registry versus the ADJD notarised will.” That distinction matters when you choose.
The Dubai Courts notarised will
There is also a local emirate route: a bilingual non-Muslim will notarised through the Dubai Courts, at a government registration cost of roughly AED 2,020 plus translation. It is workable, but it does not carry DIFC’s common-law framework or its streamlined enforcement route, and it is less commonly chosen by expats with cross-border or corporate estates.
Your home-country will, and why it is not enough on its own
A home-country will remains essential for your assets back home. But relying on it for your UAE assets creates real delay. UAE authorities may require translation, legalisation and a local recognition process before they act on a foreign will, and that can hold up the whole estate.
Take a French national in Dubai, a very common profile. France reserves a protected share of the estate for children, the réserve héréditaire. Under the EU Succession Regulation, a French national can elect their national law in a will, but a 2021 amendment to Article 913 of the French Civil Code lets EU-national or EU-resident children claim a compensatory levy over assets located in France where the governing law ignores forced heirship. The key point for expats: this reaches assets situated in France. It does not claw back UAE-situated assets governed by a valid UAE will. So the clean approach is a UAE will for your UAE assets, plus a coordinated home-country will for your home assets, drafted together so beneficiaries, executors and guardians line up and neither will accidentally revokes the other. Forced heirship is a live area of law and needs specialist advice in your home jurisdiction.
So does the Abu Dhabi route do the same job?
For a simple estate, it covers the essentials: it disapplies Sharia, directs your assets and appoints guardians. Where it differs from DIFC is the probate and enforcement pathway, the language of the document, and how naturally it fits with company ownership and cross-border structures.
| Option | Government fee* | Language | Asset coverage | Probate route | Best suited to |
| DIFC Full Will | AED 10,000+ | English | All UAE and worldwide, one instrument | Direct DIFC route, banks and Land Department (Law 2/2025) | Multi-asset, cross-border and business-owner estates |
| ADJD / ADGM will | AED 950+ | Bilingual | UAE-wide, clearer with assets listed | ADJD Wills and Probate Office, grant follows asset location | Simpler, single-emirate estates |
| Dubai Courts will | Approx. AED 2,020 | Bilingual | UAE assets, notarised | Dubai Courts system | Local, straightforward estates |
| Home-country will | Varies | Home language | Home-country assets only | Home-jurisdiction probate | Assets held back home |
The bottom line: the ADJD route disapplies Sharia and directs your assets too. What DIFC adds is a cleaner, faster and more enforceable probate path, which is exactly where an estate made up of company shares, property and accounts would otherwise get stuck. For a founder or business owner, that difference is not a luxury, it is what keeps the company moving while the estate is administered.
How to choose
- Choose the DIFC Full Will if your estate is multi-asset, if you own company shares or property, if any part of your affairs is cross-border, or if you want a single English-language instrument with strong guardianship and a fast, enforceable Dubai probate route.
- Choose the ADJD or ADGM route if your estate is simple and sits in one emirate, and if your priority is guardianship together with a modest cash estate.
- In most cases, pair your UAE will with your home-country will, coordinated so the two work together rather than against each other.
How Altus Citadel helps?
Wills sit at the intersection of the work we already do every day: company formation, shareholding, bank accounts and cross-border structuring. We map your UAE and home-country assets, match the right instrument to your estate, and coordinate your wills so nothing conflicts, and handle registration through the DIFC Virtual Registry or remote ADJD or ADGM notarisation, with secure storage arranged.
One conversation now can save your family months of frozen accounts and court process later.
Talk to us: info@altuscitadelservices.com, +971 50 961 6354 or +971 50 161 9605. Offices in Dubai, Ajman, Nicosia and Luxembourg.
This article is general information, not legal advice. Fees are government registration figures verified against the DIFC Courts and ADGM published schedules and are subject to change. Your own position, particularly any home-country forced-heirship rules, should be confirmed for your specific circumstances.
