Understand the differences between the federal non-Muslim personal-status framework, Abu Dhabi Civil Wills and DIFC Courts Wills before choosing a registration route.
Based on current official UAE legislation and court/department guidance checked for 2026. This guide does not constitute legal advice or a probate determination.
Do not choose a Will solely because it is advertised as a UAE Will. The correct route depends on the person, the assets, the emirate, the chosen authority and the legal framework that applies to the estate.
The three legal layers you should distinguish
Federal framework
Federal Decree-Law No. 41 of 2022 establishes a civil personal-status framework for persons within its scope, including rules on wills and estate distribution.
Abu Dhabi Civil Wills
Abu Dhabi has its own civil family-law framework and Civil Wills Office under Abu Dhabi Judicial Department. Its will and inheritance provisions should be read separately from DIFC Courts procedures.
DIFC Courts Wills
DIFC Courts runs a dedicated Wills Service with its own eligibility requirements, Will categories, registration rules, fees and probate process.
Federal non-Muslim personal-status framework
Federal Decree-Law No. 41 of 2022 is formally titled the law on civil personal status for non-Muslims. Its scope is not simply “all expatriates in the UAE”: it applies to the persons specified by the law, and the law also contains provisions allowing certain persons to adhere to their home-country law or agree to another applicable UAE personal or family-status regime.
Article 11 provides that a testator within the law's scope may make a Will covering property owned in the State. If there is no Will, the law provides a default allocation in which half goes to the husband or wife and the other half is divided equally among the children, without distinction between male and female children. This is a framework-specific default, not a rule that should automatically be applied to every estate in every emirate.
Practical point: A federal inheritance provision does not by itself tell you which registration service to use. The appropriate authority and legal regime still depend on the person's circumstances and the assets involved.
Choose the Will route you are researching
DIFC Courts Full Will
Authority: DIFC Courts Wills Service
AED 10,000 single will
AED 1,000 non-refundable booking fee*
Coverage: Covers movable and immovable assets in the jurisdiction specified in the Will and can include foreign assets, subject to the law and enforceability rules of the country where those assets are located.
Important limit: For minor children, DIFC Courts states that the Full Will can appoint interim and permanent guardians for minor children residing in Dubai or Ras Al Khaimah, where applicable.
Eligibility / route note: DIFC eligibility requirements include being at least 18, not being Muslim and never having been Muslim, and owning assets in the UAE and/or having minor children residing with you in Dubai or Ras Al Khaimah.
DIFC Courts basic eligibility
Age
At least 18 years old
DIFC Courts states that a testator must be at least 18 when registering a Will.
Religion
Not Muslim / never Muslim
This is part of the DIFC Courts Wills Service eligibility requirements.
UAE connection
UAE assets and/or qualifying children
DIFC Courts requires UAE assets and/or minor children residing with the testator in Dubai or Ras Al Khaimah.
Residency
UAE residency is not required
Eligible testators may register virtually from outside the UAE.
DIFC Courts also states that its Wills can be registered virtually from outside the UAE. Registration appointments require the testator(s) and two witnesses.
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DIFC Courts currently lists six Will categories in its fee and service information. Choosing the category determines the asset coverage. A specialised Will should not be treated as equivalent to a Full Will.
Will type
Coverage
Important limitation
Full Will
All movable and immovable assets within the jurisdiction specified in the Will; foreign assets can also be included, subject to local law.
Best suited where a broad estate plan is required.
Property Will
Up to five UAE real-estate properties or shares in those properties.
New properties need a new registered Will or modification to ensure coverage.
Business Owners Will
Up to five UAE company shareholdings.
Does not automatically become a worldwide business-succession document.
Financial Assets Will
Up to ten UAE bank or brokerage accounts.
Specific account coverage matters; new accounts may require modification.
Digital Assets Will
Digital assets under the dedicated DIFC category.
Custodian and foreign-law issues can still affect enforcement and access.
Current DIFC Courts fees
Will
Single Will
Mirror Wills
Booking fee
Full Will
AED 10,000
AED 15,000
AED 1,000 / AED 2,000
Property Will
AED 7,500
AED 10,000
AED 750 / AED 1,000
Business Owners Will
AED 5,000
AED 7,500
AED 500 / AED 750
Financial Assets Will
AED 5,000
AED 7,500
AED 500 / AED 750
Digital Assets Will
AED 5,000
AED 7,500
AED 500 / AED 750
*DIFC Courts states that the booking fee is deductible from the service fee but is non-refundable in the circumstances specified in its current fee schedule. Fees are subject to change; confirm the live schedule before payment.
Abu Dhabi Civil Will
Abu Dhabi has its own civil family-law framework under Abu Dhabi Law No. 14 of 2021, as amended, including provisions on inheritance and Wills. Article 11 allows a testator governed by that law to bequeath assets in the country to beneficiaries of the testator's choice. In the absence of a Will, Article 11 contains a default distribution rule, including half to the spouse and half divided equally among the children.
The Abu Dhabi Judicial Department operates a Civil Wills Office and currently lists AED 950 as the registration fee for a Will. The registration procedure, eligibility and supporting-document requirements should be checked directly with ADJD before filing.
Important distinction: an Abu Dhabi Civil Will is not a DIFC Courts Will. The two should not be described as interchangeable registration services.
What happens after death?
A Will sets out testamentary instructions, but the death of the testator can still trigger formal estate-administration and probate processes. DIFC Courts states that it deals with applications for Probate Orders and, where necessary, Guardianship Orders for estates connected to a registered DIFC Will.
For bank accounts, investments, company interests and other assets, beneficiaries may still need to provide the relevant death, probate, succession or transfer documents required by the competent authority, bank, broker, company or court. A registered Will should therefore not be marketed as a guarantee that an asset will never be frozen or that money will be released immediately.
Typical Will-planning workflow
1
Identify the correct legal regime
Determine whether the estate should use the federal non-Muslim framework, an Abu Dhabi Civil Will, a DIFC Courts Will, or another applicable regime.
2
Select the appropriate Will type
For DIFC, the choice depends on whether you need broad estate coverage, property-only, business, financial-account or digital-asset coverage.
3
Prepare the Will
Use the authority procedure and template where required. DIFC Courts strongly recommends considering legal advice because non-compliance with the Rules can affect registrability and enforceability.
4
Complete registration
DIFC Courts currently permits virtual registration. ADJD provides a Civil Wills registration service with its own application and procedural requirements.
5
Keep the estate plan current
Changes in property, accounts, businesses, guardians, beneficiaries or family circumstances can require a new Will or formal modification.
Common mistakes to avoid
Treating the UAE as one probate regime
Federal personal-status law, Abu Dhabi Civil Wills and DIFC Courts Wills have different scopes, authorities and procedures.
Assuming a Will prevents every account freeze
A Will is testamentary evidence; the bank, probate court and estate administration process may still require additional steps after death.
Calling a DIFC Property Will a full estate plan
The Property Will is restricted to up to five UAE real-estate properties. Other assets generally require an appropriate additional or Full Will arrangement.
Assuming foreign assets are automatically enforceable
A DIFC Full Will can include foreign assets, but foreign courts and local law can determine how the Will is recognised and enforced outside the UAE.
Treating fee figures as permanent
Court and service fees can change. The official authority fee schedule should always be checked before registration.
Using “government verified” language
A page that cites official government sources should say it is based on current official guidance, not imply that the page itself has been verified or approved by a government authority.
DIFC vs Abu Dhabi Civil Will at a glance
Feature
DIFC Courts Wills Service
Abu Dhabi Civil Wills
Authority
DIFC Courts Wills Service
Abu Dhabi Judicial Department
Basic regime
DIFC Courts Wills Rules and related DIFC framework
Abu Dhabi Law No. 14 of 2021 and related regulations
Eligibility focus
Specific DIFC eligibility requirements, including age and religion requirements
Civil Wills Office operating under the Abu Dhabi framework
Remote registration
DIFC Courts currently permits virtual registration from anywhere
Check current ADJD application and appearance requirements
Current headline fee
From AED 5,000 for several specialised categories; AED 10,000 for a single Full Will
There is not one single UAE-wide civil-wills procedure for every non-Muslim expatriate. Federal Decree-Law No. 41 of 2022 contains a federal civil personal-status framework for persons within its scope, while emirate-specific regimes such as Abu Dhabi Civil Wills and DIFC Courts Wills have their own rules and eligibility requirements. The applicable regime should therefore be identified before relying on a distribution rule or registration procedure.
The DIFC Courts Wills Service is a dedicated registry for eligible testators. DIFC Courts states that an eligible testator must be at least 18, must not be Muslim and must never have been Muslim, and must own assets in the UAE and/or have minor children residing with them in Dubai or Ras Al Khaimah. DIFC Courts also permits virtual registration from anywhere in the world.
A DIFC Courts Full Will can include foreign assets. However, DIFC Courts expressly cautions that enforcement of the Will outside the UAE is subject to the law and rules of the jurisdiction where the foreign assets are located. A DIFC Will therefore should not be described as an automatic worldwide probate solution.
A death does not mean that the balance is automatically released to beneficiaries. Estate administration, probate or another court process may be required before assets can be distributed, depending on the applicable legal regime and the bank. A registered Will can provide testamentary instructions, but it does not itself guarantee immediate access to a bank account.
Yes, where the DIFC Courts Will is eligible and properly registered. DIFC Courts states that its Full Will can include interim and permanent guardianship provisions for minor children residing in Dubai or Ras Al Khaimah, subject to the applicable Rules. Abu Dhabi has its own civil family-law and guardianship framework, so the DIFC rule should not automatically be applied to every emirate.
Current DIFC Courts fees include AED 10,000 for a single Full Will and AED 7,500 for a single Property Will, plus the applicable non-refundable booking fee shown by DIFC Courts. Business Owners, Financial Assets and Digital Assets Wills are listed at AED 5,000 for a single will. ADJD currently lists AED 950 for registration of a Civil Will before its Civil Wills Office. Fees and service conditions can change, so the authority fee schedule should be checked before filing.
The following links are provided so readers can verify the current law, eligibility, registration process and fees directly with the relevant authority.
Legal-information notice: This guide is informational and does not determine which law or court will govern a particular estate. Cross-border assets, nationality, religion, residence, location of assets, family circumstances and the wording of an existing Will can materially affect the outcome. For a substantial or cross-border estate, obtain advice from a qualified succession lawyer before executing or changing a Will.