In short
In the UAE, foreign-owned property is subject to local succession rules unless a specific will is in place. Three recognised instruments exist: Dubai Courts, DIFC and ADJD, with different levels of protection, cost and territorial coverage. They can be registered remotely and ensure the chosen law applies to one's UAE assets.
The default almost nobody knows about
The 2022 UAE Personal Status Law for non-Muslims opened the option to apply the law of one's country of origin to assets held here. It is an important structural change, but the automatic default isn't guaranteed, and court timelines to clarify succession in the absence of a registered deed remain long. A registered UAE will is the simplest and fastest way to have complete certainty over what happens to one's assets in the country.
Three routes to register a UAE will
Three main venues exist for registering a valid will in the UAE: Dubai Courts, DIFC, and ADJD. They differ in jurisdiction, level of protection, cost, and territorial coverage. The right choice depends on the composition of your UAE estate and the horizon of the investment.
Dubai Courts is the most affordable option for those who own only Dubai property. The will is registered with Dubai's civil court. It requires Arabic translation and follows traditional procedures. It works well for simple estates and modest tickets, but the protection is more basic and execution timelines can lengthen in case of disputes.
DIFC Will (Dubai International Financial Centre) is the system established in 2015 under the common law jurisdiction of the DIFC Courts. Registration in English, automatic recognition by UAE courts, fast execution, coverage of Dubai and Ras Al Khaimah assets. Total costs higher than the other two options, but the highest level of protection and the most robust process for significant tickets.
ADJD Will (Abu Dhabi Judicial Department) is today a particularly attractive option. Under Federal Decree-Law 41 of 2022 on Personal Status for Non-Muslims, the ADJD will is recognised at federal level and is valid for assets in all seven emirates, not only Abu Dhabi. Digital procedure, overall costs above Dubai Courts but with the benefit of federal coverage and the new legal framework.
- All three venues are open to non-Muslims of any nationality
- All allow you to choose the applicable law (e.g. the law of your home country)
- Registration possible remotely, by video conference
- Court recognition by the relevant judicial authorities
- Can be updated or revoked at any time
Which one to choose depends on your case. If you own a single Dubai property with a modest ticket, Dubai Courts may be enough. If the investment is significant or you plan to acquire more assets in Dubai, DIFC offers the strongest coverage. If you have (or plan to have) assets in multiple emirates, ADJD is often the most efficient choice today, allowing you to handle everything with a single deed. The right call in your specific case is one to make together with the specialist lawyer during the Strategy phase.
When to do it
The practical rule: do it at the moment of purchase, not later. Postponing creates room for family disputes, court holds in case of a sudden event, and higher costs if heirs have to regularise the situation after the fact. For off-plan property, you can already do it at the moment the contract is signed, once the Oqood has been issued and the unit is registered in your name.
Three common mistakes
The first is thinking that a will made at home automatically covers UAE property. It doesn't. Succession rules apply in the country where the asset is located, not in the country of the owner. A will made at home is valid for the home estate, but for UAE assets you need a deed registered here.
The second is waiting to relocate before doing it. If you buy property in Dubai from abroad, you need to address the will at the moment of purchase, not when you eventually move someday. The probability of an event is low at any given moment, but it exists, and the assets are already part of your estate.
The third is ignoring off-plan property. An undelivered unit, already registered via Oqood, is part of your UAE estate to all effects. It needs to be covered by the will exactly like a ready property.
What to do now
If you already own UAE property, or you are about to sign, the will can be done at any time. The procedure is entirely remote: video identification, customised drafting by a specialist lawyer who knows both the home jurisdiction and UAE law, registration at the venue best suited to your case (Dubai Courts, DIFC or ADJD). When I work with my international clients, we open this topic in the Strategy phase and handle it in parallel with the purchase process, with the lawyer in my network who manages these deeds for non-residents.
Frequently asked
Do I still need a UAE will if I already have a will at home?
Yes. The will made at home applies to your estate at home. UAE property is governed by UAE law. Without a DIFC or ADJD will, the succession of your UAE assets may be subject to rules different from what you'd expect, with court timelines of months or years to regularise the situation.
Can a UAE will be done remotely?
Yes, regardless of the venue chosen (Dubai Courts, DIFC or ADJD). The procedure involves a video conference with the notary or competent authority for identification and confirmation of the will. The lawyer assisting you prepares the documentation and handles the process remotely. You don't need to come to Dubai.
How much does a UAE will cost?
Public registration fees vary by the venue chosen: Dubai Courts is generally the most economical option, DIFC the most articulated, ADJD sits in between but with the benefit of federal coverage. On top of that there are the fees of the specialist lawyer who drafts the deed. The total cost is low relative to the value of the asset it protects: it is a one-time expense that does not pay off to optimise at the expense of protection.
Want to understand which option fits your case?
DIFC, ADJD or Dubai Courts: the right call depends on your estate and your plans. Let's discuss it in thirty minutes, with the lawyer in my network involved if needed.
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