For non-Muslim expatriates living in the UAE, a registered will is not optional — it is essential. Without one, UAE inheritance law applies to your UAE assets by default. But not all UAE wills are created equal, and the choice between a DIFC Will and a notarised Dubai Will has material consequences.
Why UAE Expats Need a Local Will
In the UAE, the default inheritance regime is based on Federal Law No. 28 of 2005 (Personal Status Law), which derives from Islamic principles. For non-Muslims, this can produce inheritance outcomes that are entirely at odds with your wishes. While UAE courts increasingly respect foreign wills, a registered UAE will — particularly a DIFC Will — provides the clearest, fastest and most certain legal protection for your UAE assets.
The DIFC Will: What It Is
A DIFC Will is registered with the DIFC Wills Service Centre, which operates under common law principles (English law-based). It is available to non-Muslim individuals with assets in the UAE. Once registered, a DIFC Will takes effect on death and can be enforced through the DIFC Courts — a process that is well-understood, reliable and internationally recognised. DIFC Wills are available to both UAE residents and non-residents with UAE assets.
What a DIFC Will Can Cover
A Property Will: covering UAE real estate. A Financial Assets Will: covering bank accounts, investments, shares and other financial assets. A Business Owners Will: covering shares in UAE companies. A Guardianship Will: specifying the guardian of minor children in the UAE. A Mirror Will: for spouses who want mutual wills. Most DIFC Will clients register a comprehensive will covering all UAE assets in a single document.
The Dubai Notarised Will: The Alternative
A notarised will is prepared and registered through a Dubai notary public. It is available to both Muslims and non-Muslims, can cover UAE assets, and is enforceable through UAE courts. It is generally less expensive than a DIFC Will and can be prepared more quickly. However, enforcement through the UAE courts (rather than DIFC Courts) can be slower and involve a more complex probate process.
DIFC Will vs Dubai Will: The Key Differences
Governing law: DIFC Will operates under English common law; Dubai notarised will operates under UAE civil law. Enforcement speed: DIFC Wills are generally enforced more quickly. Scope: DIFC Wills can cover all UAE assets in a single comprehensive document. Cost: DIFC Wills carry higher registration fees but simpler enforcement. International recognition: DIFC Wills are more widely recognised internationally due to the common law framework.
Which to Choose?
For most non-Muslim UAE expats with significant UAE assets — property, bank accounts or business interests — the DIFC Will is the recommended choice. The higher registration cost is justified by the certainty, speed and international recognition of the outcome. For individuals with simpler asset profiles or limited UAE exposure, a notarised Dubai Will may be sufficient. PRF advises on the right choice based on your specific assets and family situation.
When to Register a UAE Will
Immediately on acquiring UAE assets of any significance. At a minimum, before: purchasing UAE property; incorporating a UAE company; opening a significant UAE bank account; having children while residing in the UAE. Wills should be reviewed and updated after: major life changes (marriage, divorce, birth of children); acquisition of new significant assets; changes to your business structure.