A DIFC Will is a formal legal document registered with the DIFC Courts Wills Service that allows non-Muslim expats in the UAE to specify who inherits their UAE-based assets — property, bank accounts, business shares, investments — according to their own wishes, not UAE default inheritance law (which applies Sharia-based distribution for non-Muslims in the absence of a will). Cost: from AED 10,000 for a simple will. Non-UAE assets are not covered — you need separate home-country wills for those.
Why Non-Muslim UAE Expats Need to Plan Inheritance
The UAE operates a dual inheritance system. UAE nationals and Muslim expats are subject to Sharia inheritance law, which specifies fixed shares for designated heirs. For non-Muslim expats, the position has evolved significantly — but without a registered will, your UAE assets may be subject to lengthy estate administration that can freeze accounts for months or years.
Before the DIFC Wills Service (launched 2015) and Abu Dhabi Judicial Department (ADJD) Wills (launched 2021), non-Muslim expats had no formal mechanism to direct UAE-based inheritance. Assets could be distributed under principles applied by UAE courts that were not necessarily aligned with the deceased's intentions.
DIFC Will vs Abu Dhabi ADJD Will: Which Do You Need?
| Feature | DIFC Will | Abu Dhabi ADJD Will |
|---|---|---|
| Jurisdiction | Dubai and other emirates (for most asset types) | Abu Dhabi primarily; valid for UAE-wide assets |
| Who can use it | Non-Muslim expats resident in UAE | Non-Muslim expats (and potentially nationals for certain assets) |
| Assets covered | UAE property, bank accounts, company shares, investments, business assets | Abu Dhabi property; general assets |
| Language | English (and Arabic version provided) | Arabic (primary); English translation provided |
| Cost (simple will) | From AED 10,000 (online) to AED 14,000+ (in-person) | Lower — typically AED 950–2,000 |
| Court system | Common law DIFC Courts (familiar to UK, Australian, US expats) | UAE civil law courts (Abu Dhabi) |
| Online registration | Yes — difcwills.com | Yes — ADJD portal |
For most non-Muslim expats in Dubai, a DIFC Will is the standard recommendation. Expats primarily in Abu Dhabi may prefer the ADJD Will given lower cost and local court familiarity. Some expats register both for comprehensive coverage.
What a DIFC Will Covers
A DIFC Will can cover:
- UAE real property (freehold and leasehold property registered in your name)
- UAE bank accounts (savings, current, investment accounts at UAE banks)
- UAE-based investment portfolios (shares at UAE brokers, UAE DIFC company shares)
- UAE business interests (LLC shares, free zone company ownership)
- Guardianship of minor children resident in the UAE (critical for parents)
What a DIFC Will Does NOT Cover
- Assets outside the UAE — your IBKR portfolio, UK property, Indian bank accounts, etc. require separate wills in the relevant jurisdiction
- Moveable personal assets of modest value (typically handled separately)
- Life insurance policies with named beneficiaries (these are typically paid per beneficiary designation regardless of will)
Your UCITS ETF portfolio held at Interactive Brokers Ireland is not covered by your DIFC Will. IBKR Ireland is an Irish-regulated entity — the assets are held in Ireland (legally), not the UAE. To ensure your IBKR holdings pass to the right heirs, you need a will in the jurisdiction where the assets are held — typically Irish law or the law of your home country. Discuss this with a private client lawyer.
The Guardianship Clause: Protecting Your Children
For expat parents with children in the UAE, the guardianship provision of a DIFC Will may be the most important element. Without a registered will specifying guardianship, UAE authorities may need to seek guidance from the UAE courts in determining care arrangements for minor children — a process that can cause significant uncertainty and delay.
A DIFC Will allows you to name a legal guardian for your children in the event of your death. This guardian can be anyone you designate — a spouse (usually automatic), a family member in your home country, or a trusted friend. Registering this formally through the DIFC system provides clarity and legal standing.
How to Register a DIFC Will
- Choose your will type: Property Will, Financial Assets Will, Business Owners Will, Guardianship Will, or a Full Will covering all categories. The Full Will is most comprehensive and typically recommended.
- Prepare your will document: You can draft it yourself using DIFC templates at difcwills.com, or use a UAE lawyer (recommended for complex estates).
- Register online or in person: The DIFC Courts Wills Service has an online portal for straightforward cases. In-person registration is available at the DIFC Courts.
- Pay the fee: From AED 10,000 online; AED 14,000–17,000 for in-person or complex registrations.
- Store copies securely: Keep digital copies and inform your executor and key family members of the will's existence and location.
What Happens Without a UAE Will
Without a registered UAE will, your estate is subject to UAE succession procedures that can be complex, lengthy, and expensive. Bank accounts may be frozen immediately on the bank being notified of death, sometimes for 6–24 months. Property cannot be transferred until courts confirm heirs. Business assets may be paralysed. The process can consume 10–30% of estate value in fees and delays in extreme cases.
The AED 10,000–14,000 cost of a DIFC Will is trivial relative to the administrative complexity it prevents — and the certainty it gives your family at the worst possible time.
A DIFC Will is not optional if you have UAE assets or children in the UAE
After 12+ years in the UAE, the number of expat families I have heard of where frozen accounts or estate uncertainty caused serious hardship is sobering. The DIFC Will is straightforward to register, relatively affordable, and provides enormous peace of mind. If you have UAE property, a UAE bank balance above AED 50,000, UAE business interests, or children in the UAE, register a DIFC Will. Do it this year, not eventually. And ensure your home-country wills are also current for your IBKR portfolio and any assets held outside the UAE. Read our leaving Dubai financial checklist for the full exit planning framework.
Frequently Asked Questions
The DIFC Wills Service is available to non-Muslim expats. Muslim expats are subject to Islamic inheritance law (Sharia succession) for UAE assets, and the DIFC Wills mechanism does not apply to them. Muslim expats can make Sharia-compliant wills and should seek specialist Islamic estate planning advice.
Yes. A DIFC Full Will is generally recognised for real property across all UAE emirates, not only Dubai/DIFC. However, property in Abu Dhabi may be more efficiently handled with an ADJD Will given the Abu Dhabi court system. For comprehensive UAE-wide coverage, some expats register both a DIFC Will and an ADJD Will. Confirm the current position with the DIFC Courts Wills Service and an Abu Dhabi legal advisor.
No — you can register a DIFC Will yourself using the online portal at difcwills.com. The DIFC Courts provide templates and guidance. However, for complex estates (multiple properties, business interests, international assets), engaging a UAE private client lawyer is strongly recommended. The cost of professional legal advice (typically AED 5,000–15,000 for a comprehensive estate plan) is generally worthwhile for estates above AED 500,000.