For many foreign residents in the Emirates, wills for expats in UAE have long been associated with legal uncertainty and complex inheritance procedures. In recent years, however, the UAE legal framework has evolved significantly for non-Muslim residents. Today, the country offers a more modern and internationally oriented succession system, with multiple registration options and greater recognition of home-country laws. Understanding the available structures is therefore an essential first step for anyone planning ahead.
Why a Will Has Become Essential for Expats
Many foreign residents in the Emirates hold a broad range of assets, including real estate, bank accounts, company shares, investments, insurance policies, and digital assets. Without a valid will registered in the UAE, assets may be temporarily frozen and distributed according to local succession rules.
For years, this created concern among non-Muslim expats, particularly regarding the possible application of Sharia-based inheritance principles. Notably, the introduction of a civil law framework for non-Muslims has significantly changed this landscape.
The Civil Law Framework for Non-Muslims
A major development came with Federal Decree-Law No. 41 of 2022, which came into effect in 2023. Under this framework, non-Muslim residents can choose the application of their home-country law, register a locally enforceable will, freely determine asset distribution, appoint guardians for minor children, and simplify probate procedures for heirs.
Additionally, Federal Decree-Law No. 41 of 2024 on Personal Status, which took effect on 15 April 2025, applies to UAE nationals and consenting expatriates and governs inheritance and estate planning, improving legal clarity and ensuring will provisions align with updated family law standards. Individuals should therefore seek qualified legal advice to understand how either law applies to their specific situation. As a result, the UAE is progressively moving toward an international succession model more aligned with global standards.
Furthermore, under Federal Decree-Law No. 51 of 2024, effective from 1 January 2026, if an expatriate dies without a registered will and without identifiable heirs, their UAE-based assets are frozen and may ultimately be transferred to a state-managed charitable endowment (Waqf). This makes timely registration more important than ever.
Default Inheritance Rules Without a Will
For non-Muslim expats who pass away without a registered will, the current framework provides a general structure for asset distribution. As a general principle under the non-Muslim framework, a portion of the estate may go to the spouse and another portion to children, with remaining assets potentially passing to parents or siblings where applicable.
However, outcomes can vary depending on individual circumstances, asset types, and the emirate involved. Consequently, a properly registered will remains the most reliable way to ensure your wishes are respected.
Three Registration Options for UAE-Based Assets
Expats with assets in the UAE have more than one registration route available to them. The right option depends on the individual’s assets, emirate, nationality, family situation, and objectives. Indeed, there is no single solution that fits all cases.
DIFC Wills
The Dubai International Financial Centre wills system is one of the most established options for non-Muslim expats, particularly suited to international families, entrepreneurs, real estate investors, and those with complex or multi-jurisdiction asset structures. It operates under a common law framework and offers a structured probate process. In addition, the DIFC Wills Service offers different types of wills, including Full Wills, Property Wills, Financial Asset Wills, Guardianship Wills, Business Owners’ Wills, and Digital Asset Wills, giving expats the flexibility to choose a structure that suits their personal and financial needs. Nevertheless, it tends to involve higher costs and greater complexity than other options.
ADJD Wills
ADJD will registration is administered by the Abu Dhabi Judicial Department but is not limited to Abu Dhabi residents — any UAE resident can register, and ADJD-registered wills are valid across all seven UAE emirates under Federal Decree-Law No. 41 of 2022. This makes it a flexible and accessible option. Moreover, registration is available online or by video call, with a standard government fee. It is generally considered more cost-effective and straightforward than DIFC, though individuals should seek legal advice to verify how ADJD wills apply to their specific assets and circumstances.
Dubai Courts / Notary Public
Under Dubai Law No. 15 of 2017, non-Muslim expats with assets in Dubai may also register a will through the Dubai Courts or a Notary Public. The government fee for will registration through the Dubai Courts Notary Public is approximately AED 2,167 for a single will and AED 4,334 for mirror wills. This option can therefore be less costly than DIFC in many straightforward cases. However, the probate process is conducted entirely in Arabic, meaning non-Arabic-speaking beneficiaries and executors will likely require professional legal assistance during probate, which may offset the initial cost savings. It remains nonetheless an important alternative to consider alongside DIFC and ADJD when assessing the most appropriate structure.
Digital Assets and Corporate Holdings
A growing area of focus in UAE succession planning involves digital assets such as cryptocurrency, digital wallets, startup shares, and free zone company ownership. These assets can be addressed within a will, but they require careful and specific drafting to be effective. Moreover, access details and technical provisions must be clearly documented. Simply referencing digital assets in a will without adequate specifics may therefore not be sufficient for proper inheritance.
Guardianship for Minor Children
The UAE has lowered the age of majority from 21 to 18, which has implications for guardianship clauses, trust structures, inheritance conditions, and existing wills. As a result, expats with children are advised to review their current arrangements in light of this change.
How Kelmer Group Supports Expats in the UAE
For expats in the UAE, having a registered will is a core element of financial and family protection. The current framework offers several viable options — DIFC, ADJD, and Dubai Courts / Notary Public — each with distinct characteristics. Ultimately, choosing the most appropriate structure depends on the complexity of your assets, your emirate of residence, your family situation, and your long-term objectives.
At Kelmer Group, our team supports expats, business owners, and high-net-worth individuals in the UAE with assessment of the most suitable structure, coordination with local legal specialists, operational support for will registration, preliminary review of UAE assets and corporate holdings, and international succession planning advisory.
Contact our Dubai team to explore your options: kelmer.com/dubai