For most non-Muslim expats in the UAE, one registered will, not both, is usually enough for UAE assets. Both the DIFC Courts in Dubai and the ADGM Courts in Abu Dhabi offer wills services for non-Muslims that may cover assets across the UAE, so the choice often comes down to where you live, where your main assets are and how probate would work for your family. This reflects published guidance as at October 2026.

Why a UAE will matters at all

Without a registered will, a non-Muslim's UAE estate falls under default succession rules. Under Federal Decree-Law No. 41 of 2022 on civil personal status, a surviving spouse takes half the estate and the children share the rest equally. Heirs may also ask for the law of the deceased's home country to apply. UAE banks commonly restrict access to accounts on death until a court order is obtained.

A registered will lets you choose who inherits, name executors and appoint guardians for children. It also gives the UAE authorities a clear document to act on, which may make the process quicker for your family.

The DIFC wills service

The DIFC Courts' wills service is a joint initiative of the Government of Dubai and the DIFC Courts. Since 2019 a DIFC will can cover assets across the UAE and assets outside the UAE. Dubai Law No. 2 of 2025 gives the DIFC Courts' enforcement judge jurisdiction over enforcing registered non-Muslim wills, whether the assets are inside or outside the DIFC.

Key features:

  • Available to non-Muslims living or investing in the UAE
  • Several will types: Full Will, Property Will, Financial Assets Will, Business Owners Will, Digital Assets Will and Guardianship Will
  • Probate handled through the DIFC Courts, which operate on common law principles familiar to UK nationals

Because you can choose a narrower will type, the DIFC service may suit people who want, for example, a will covering only a Dubai property, or only guardianship for their children.

The ADGM wills service

The ADGM Courts in Abu Dhabi also offer wills for non-Muslims. ADGM's published wills office guidance has stated that:

  • the service is for non-Muslims aged 21 and over who own assets in the UAE
  • a will can cover assets elsewhere in the UAE and outside the UAE, although probate for overseas assets is granted where those assets are located
  • appointments are held virtually
  • guardians for children can be appointed
  • probate applications are made through the Abu Dhabi Judicial Department rather than ADGM itself

That guidance is several years old, and requirements on language and process have changed over time, so check the current position directly with ADGM before you start.

How to choose

Both can do the core job. These questions often decide it:

  • Where do you live? Dubai residents often choose DIFC and Abu Dhabi residents often choose ADGM, simply because the courts and lawyers are local.
  • Where are your main UAE assets? If your property is in Dubai, a DIFC will may be the more familiar route for that emirate's authorities and banks, and the same logic may apply to Abu Dhabi.
  • Do you only need part of your estate covered? DIFC's separate will types may be useful if you want, for example, a guardianship will on its own.
  • How would probate work? Ask which court your executors would deal with and how long it may take.

Your UAE will should sit alongside a separate UK will if you own UK assets, drafted so neither revokes the other. For how wills fit with life cover and trusts, see our guide on life insurance, trusts and succession for GCC expats.

A worked example

Illustrative example only, not a real client.

Tom and Priya, non-Muslim British nationals, live in Abu Dhabi with one child. They own a Dubai apartment worth AED 1,500,000, UAE bank accounts holding AED 300,000 and a flat in England worth GBP 250,000.

Their main UAE asset is in Dubai, so they choose DIFC Full Wills covering their UAE assets and naming guardians. For the flat in England they each make a separate English will limited to UK assets.

Had their only UAE asset been an Abu Dhabi property, an ADGM will might have been the more natural choice. Either way, the main step is having a registered will in place rather than relying on default rules.

Common mistakes

  • Making both a DIFC and an ADGM will without coordinating them, so one revokes the other
  • Assuming a UAE will automatically deals smoothly with UK assets
  • Not naming guardians for children
  • Never updating the will after a move between emirates, a new property or a change in family

A regulated financial adviser can help. Wills themselves should be prepared by a qualified lawyer. Get in touch for a free introduction.

Sources and further reading

Last reviewed: October 2026. Tax year: 2026/27; UAE wills rules as at October 2026. Jurisdictions covered: UAE (Dubai, Abu Dhabi), England and Wales. Rates, legislation and guidance change, so recheck before relying on this. Rules can differ between England and Wales, Scotland and Northern Ireland; tax residence is fact-specific; treaty outcomes depend on residence, domicile or nationality provisions; examples are simplified and omit reliefs, costs, exchange rates and anti-avoidance rules. This is general information, not financial, tax or legal advice. Take advice in the relevant country before acting.