DIFC Wills for non-Muslims in UAE — why you need one and how to register

More than 90% of Dubai residents are non-Muslims. Without a registered UAE will, every one of them faces a critical succession gap: UAE law defaults to Sharia distribution rules for their UAE assets, regardless of their own religion, nationality, or intentions. The DIFC Wills Service Centre exists precisely to close that gap.

Why non-Muslims need a UAE will

UAE succession law is grounded in Islamic Sharia principles for the distribution of a deceased's estate. For Muslims, this is the intended system. For non-Muslims, the position is more nuanced — and for many years, more uncertain. The UAE Personal Status Law (Federal Law No. 28 of 2005 as amended) permits non-Muslims to apply their home-country succession law, but only where a valid, recognised instrument exists. In practice, this has meant that without a UAE-registered will, Sharia succession defaults have frequently been applied to the UAE estates of non-Muslim expatriates.

The practical consequences are significant. Dubai real estate owned by a non-Muslim expatriate who dies without a UAE will may be distributed entirely according to Sharia succession shares — not according to the deceased's own wishes, and not according to their home-country will. UAE bank accounts may be frozen for months or years pending court orders. A surviving spouse who is not a Sharia heir in the relevant proportions may receive less than expected. An unmarried partner receives nothing under default rules. Minor children may be subject to guardianship uncertainty.

A foreign will — English, American, French, Indian, or otherwise — is not automatically recognised by UAE courts for UAE-sited assets. Getting a UK grant of probate does not unlock a Dubai property. Even a carefully drafted home-country will cannot substitute for a UAE will that has been registered with the DIFC Wills Service Centre or the Abu Dhabi Judicial Department.

For the majority of Dubai's population — the more than 90% who are non-Muslims — registering a UAE will is one of the most important private client steps they can take. Yet the majority have not done so.

DIFC Wills Service Centre

The DIFC Wills Service Centre (DIFC WSC) was established in 2015 under the DIFC Wills Service Regulations (DIFC Law No. 4 of 2014, as amended). It operates as a specialist registry specifically designed for non-Muslim testators — both UAE residents and non-residents — who wish to register wills governing their UAE assets.

DIFC WSC wills are recognised under DIFC law and, by virtue of the cooperation between DIFC and the UAE federal and emirate courts, are given effect in Dubai and across the UAE for the asset categories they cover. The registry is not a legal practice — it does not draft wills or provide legal advice — but it provides standard will forms and a supervised registration process that gives the registered will legal validity in the UAE system.

Crucially, the DIFC WSC is available to all non-Muslims regardless of nationality, religion (or none), and whether or not they reside in the UAE. A British property investor who has never lived in Dubai but owns a Downtown apartment can register a DIFC will. A French resident of Abu Dhabi with Dubai bank accounts can register. An American tech executive with UAE company shares can register. There is no residency requirement on the testator's side.

Types of DIFC wills

DIFC WSC offers five principal will types. Testators may register more than one type, and many do — particularly those with both real estate and significant financial assets in the UAE.

(a) Full Estate Will

The most comprehensive option. A Full Estate Will covers all UAE assets — real estate (Dubai), movable assets, bank accounts, investment portfolios, business interests, personal effects — and can include a guardianship appointment for minor children ordinarily resident in Dubai. This is the recommended starting point for most non-Muslim expatriates with a mix of UAE assets. It is also the highest-fee option at USD 1,400 for registration.

(b) Real Property Will

Covers Dubai real estate (immovable property) only. Appropriate where the testator's only UAE asset is a Dubai property and they have no significant movable assets in the UAE. Registered at the lower fee of USD 840.

(c) Business Owners Will

Covers business interests in UAE — shares in UAE free zone and onshore companies, partnership interests, and similar business-related assets. Important for entrepreneurs and investors who hold equity in UAE entities. USD 840 registration fee.

(d) Financial Assets Will

Covers UAE bank accounts and investment portfolios. Relevant for those with significant UAE banking or brokerage relationships but limited or no real estate exposure. USD 840 registration fee.

(e) Guardianship Will

Appoints a guardian for minor children ordinarily resident in Dubai in the event of the testator's death (and that of the other parent, where applicable). This will type has an important geographic limitation: it applies only within Dubai emirate. For guardianship over children elsewhere in the UAE, additional or different documentation may be required. USD 840 registration fee.

Note that a Full Estate Will already incorporates the guardianship function alongside asset distribution — a separate Guardianship Will is mainly used where asset distribution is covered elsewhere but a standalone guardianship appointment is needed.

What assets can be covered

DIFC wills are UAE instruments and can only govern UAE-sited assets. The following asset categories are within scope:

UAE real estate: Dubai freehold and leasehold residential and commercial property registered with the Dubai Land Department. Abu Dhabi and Sharjah freehold real estate can be covered in some circumstances but the ADJD will route is generally more reliable for Abu Dhabi property — see the section on Abu Dhabi ADJD Wills below.

UAE bank accounts: Current accounts, savings accounts, fixed deposits, and similar deposit products held with UAE-licensed banks, regardless of which emirate the bank is licensed in or where the branch is located.

UAE investment and brokerage accounts: Portfolios held with UAE-regulated brokers, DIFC-based investment managers, and similar regulated entities operating in the UAE financial system.

Shares in UAE companies: Equity in onshore UAE limited liability companies (LLCs), free zone companies (DMCC, JAFZA, ADGM, etc.), and other UAE-incorporated entities. Business interests such as partnership shares and profit participation rights.

Personal effects: Physical assets located in the UAE — jewellery, vehicles, valuables, household contents.

Digital assets: Specified digital assets, including cryptocurrency wallet holdings and NFTs, can now be included if properly identified — see the section on digital assets below.

What is not covered: Assets outside the UAE cannot be governed by a DIFC will. Overseas real estate, foreign bank accounts, overseas investment portfolios, and foreign company shares require a separate will under the law of the jurisdiction where those assets are located. A DIFC will and a home-country will are complementary instruments, not substitutes for each other.

Registration process — step by step

The DIFC WSC registration process is straightforward once you understand the sequence. Allow approximately one to two weeks from initial drafting to the issued registration certificate.

Step 1: Instruct a qualified UAE lawyer

While DIFC WSC provides standard form wills, most testators with any complexity of assets — multiple properties, company shares, blended families, step-children, specific bequests — are better served by instructing a qualified UAE private client lawyer to draft a bespoke will tailored to their circumstances. A bespoke DIFC will provides far greater clarity and reduces the risk of ambiguity upon execution of the estate.

Step 2: Prepare identity documents

You will need: a valid passport (testator), copies of title deeds or other asset documentation, and identification for proposed witnesses (two witnesses required, both non-beneficiaries). If you are registering a Guardianship Will, you will also need birth certificates for the children named.

Step 3: Book and attend a DIFC registration appointment

Appointments are made through the DIFC WSC online portal. For testators physically present in the UAE, the appointment takes place at the DIFC WSC offices. Both the testator and the two witnesses must attend in person. DIFC staff review the will for technical compliance (not for legal advice), and the will is formally executed and witnessed in the presence of DIFC WSC staff.

Step 4: Remote registration (non-residents)

Non-UAE resident testators can complete registration by video call — see the dedicated section on remote registration below.

Step 5: Certificate issued

Upon successful registration, DIFC WSC issues a will registration certificate confirming the will's registration number, date, and the asset categories it covers. Keep this certificate with your estate planning documents and ensure your executor or next of kin knows where to find it.

Costs

Registration fees charged by DIFC WSC as of 2026 are as follows. These are government registration fees only and do not include legal drafting fees.

Full Estate Will: USD 1,400. This covers all UAE asset categories and the guardianship function in a single instrument.

Single-category will (Real Property Will / Business Owners Will / Financial Assets Will / Guardianship Will): USD 840 per will.

Annual will update service (optional): USD 200 per year. This is a service offered by DIFC WSC that provides an annual review reminder and facilitates minor administrative updates. It is not a substitute for instructing a lawyer when circumstances change significantly.

Legal drafting fees: These vary by firm and complexity. A standard DIFC will drafted by a qualified UAE private client solicitor or legal consultant typically costs between AED 3,000 and AED 10,000 depending on complexity, with bespoke multi-asset estate planning at the higher end. These fees are separate from and in addition to the DIFC WSC registration fee.

For context: the cost of registering a Full Estate Will — typically under AED 10,000 in total including professional fees — is a fraction of the cost of estate administration without a will, which commonly runs to tens of thousands of dirhams in court fees, translator fees, and legal costs, plus the significant time and distress costs borne by the family.

Abu Dhabi Judicial Department (ADJD) Wills

Abu Dhabi has its own will registration mechanism administered by the Abu Dhabi Judicial Department (ADJD). For non-Muslims who own real estate in Abu Dhabi emirate, the ADJD will route is the appropriate instrument for that property. DIFC WSC wills cover Dubai real estate reliably but the ADJD mechanism gives more direct recognition for Abu Dhabi-sited immovable property.

Key differences from DIFC WSC registration: ADJD wills are drafted in Arabic (or require a certified Arabic translation), are witnessed before a notary public, and are registered with ADJD rather than DIFC WSC. The process is administratively distinct but serves the same fundamental purpose of providing recognised succession instructions for Abu Dhabi assets.

Testators with assets in both Dubai and Abu Dhabi should consider both instruments: a DIFC Full Estate Will for UAE movable assets and Dubai real estate, and an ADJD will for Abu Dhabi real estate. This dual-instrument approach provides the most comprehensive UAE succession coverage for multi-emirate asset holders.

Remote registration for non-residents

Since the expansion of remote services during and following the COVID-19 period, DIFC WSC has offered a video call registration option for non-UAE resident testators. This significantly expands access to the DIFC will registration system for the large number of non-resident investors who own Dubai property but do not live in the UAE.

Under the remote registration process, the testator attends a supervised video call appointment with DIFC WSC. The testator must have a qualified professional present in their home country — typically a notary, solicitor, or comparable official — who can verify the testator's identity and witness the execution remotely in accordance with DIFC WSC's remote execution requirements. The specific requirements for the remote professional differ by country; DIFC WSC provides country-specific guidance.

Remote registration carries the same legal effect as in-person registration for DIFC will purposes. The registration certificate is issued in the same form and with the same legal validity. Non-resident testators should contact DIFC WSC directly or instruct a UAE lawyer familiar with the remote process to manage the coordination between the Dubai end and the home-country professional.

Updating and revoking a will

A registered DIFC will can be updated or revoked at any time during the testator's lifetime. There is no age limit on the right to update, and no minimum interval between updates.

The mechanism for revocation is registration of a new will of the same type: a newly registered Full Estate Will automatically revokes all previously registered Full Estate Wills. This means the testator does not need to execute a separate deed of revocation — the act of registering a new will serves as revocation of the prior instrument of the same category.

It is important to review and update a DIFC will following significant life events: marriage or divorce (which may affect beneficiary intentions), the birth of a child (particularly relevant for Guardianship Will provisions), acquisition or disposal of significant UAE assets (real estate purchase, business sale), changes in chosen executors or guardians, and changes in family circumstances affecting beneficiaries. An outdated will can be worse than no will, if it names deceased beneficiaries, former spouses, or no-longer-appropriate guardians.

The optional annual update service offered by DIFC WSC (USD 200/year) provides a structured reminder to review and confirm or update the will each year. Whether or not you subscribe to that service, reviewing your UAE will every two to three years — or after any significant life event — is sound practice.

Digital assets

DIFC Wills now formally accommodate specified digital assets, reflecting the growth of cryptocurrency and digital asset holdings among UAE residents and investors. A DIFC will can cover cryptocurrency wallet holdings (Bitcoin, Ethereum, and other specified cryptocurrencies), NFTs, and similar tokenised digital assets where they are properly identified in the will instrument.

The key requirement is specificity: the will must identify the relevant wallet addresses, platform accounts, or digital asset holdings with sufficient precision for the executor to locate and take control of the assets. A vague reference to "all my cryptocurrency" is inadequate — the will should identify the specific wallets, exchanges, or platforms and provide access instructions (or reference to where access instructions are securely held) to the executor.

Digital asset succession planning involves practical security considerations beyond the legal instrument: the executor must be able to access wallets without triggering loss of the assets. Testators with significant digital asset holdings should take legal and technical advice on the intersection of will drafting, wallet access, and secure executor instructions. Our private client team advises on digital asset succession planning as part of comprehensive UAE estate planning engagements.

What you need to register a DIFC will

• Valid passport (testator) — must be current and not expired
• UAE residence visa page (if UAE resident) — copy for DIFC WSC records
• Asset documentation — Dubai Land Department title deed(s), UAE bank account details, company share certificates or trade licence extract as applicable
• Two witnesses identified — both must be adults, non-beneficiaries, and not named in the will; prepare their passport copies
• Drafted will or completed DIFC standard form — either a bespoke will prepared by your UAE lawyer or the DIFC standard form completed in full
• Children's birth certificates — if registering a Guardianship Will or including guardianship provisions in a Full Estate Will
• Proposed guardian's identification — passport copy of any named guardian
• DIFC WSC appointment confirmed — book via the DIFC WSC online portal; confirm in-person or remote appointment and fee payment
• Registration fee paid — USD 1,400 (Full Estate Will) or USD 840 (single-category will), payable in advance

Frequently asked questions

Related guides

• UAE Golden Visa through property — eligibility, process, and costs 2026
• UAE inheritance law for non-Muslims — what the rules say in 2026
• Private client practice — succession, estate planning, and family matters

Published 7 June 2026. General information only — not legal advice. Contact us for matter-specific advice.