DIFC Wills & Succession (2026): Non-Muslim Estate Planning in the UAE

Quick Summary: DIFC Wills & succession

• What it is: a DIFC Will lets a non-Muslim decide exactly who inherits their UAE assets and who cares for their children – registered with the DIFC Courts under English common-law testamentary freedom, rather than leaving it to default rules.
• Who needs one: any non-Muslim with UAE assets – property, bank accounts, company shares – or with minor children resident in Dubai or Ras Al Khaimah.
• Will types: Full Will (all UAE assets + guardianship), plus targeted Property, Financial Assets, Business Owners and Guardianship Wills.
• Cost (2026, indicative): DIFC registration around USD 1,400 for a Full Will and USD 840 for a single-asset-category will – government registration fees only; legal drafting is extra.
• Why it matters: without a valid will, a non-Muslim’s UAE assets can face delay, frozen accounts and uncertainty over the children – a registered will removes that risk and is enforced quickly through the DIFC Courts.

Estate planning is the part of UAE life expats most often postpone – and the one that causes the most damage when it is missed. For a non-Muslim, dying in the UAE without a valid, recognised will can mean assets and bank accounts are frozen, distribution decided by default rules rather than your wishes, and real uncertainty over who looks after your children in the meantime. A DIFC Will is the clearest, most established solution. This guide explains what it is, the will types, the 2026 cost, how it compares to ADGM and Abu Dhabi options, and whether you still need one after the UAE’s 2022 reforms for non-Muslims.

What a DIFC Will actually is

The DIFC Courts operate a dedicated Wills Service that lets non-Muslims register a will over their UAE assets under the principles of English common law – most importantly, testamentary freedom, the right to leave your estate to whomever you choose. The will is registered and stored with the DIFC Courts, and on death your appointed executor applies to those same courts for a grant of probate that is then enforced across the UAE. Because the DIFC is a common-law jurisdiction with its own English-language courts, the process gives international families a familiar, predictable framework for something that would otherwise fall under UAE civil and Sharia principles.

Why a non-Muslim needs one

The risk a DIFC Will removes is concrete. Without a valid, recognised will in place, a non-Muslim’s UAE estate can face:

• Frozen assets. Bank accounts – including joint accounts – can be suspended on death until succession is resolved, leaving a surviving spouse without access.
• Distribution you did not choose. In the absence of a valid instrument, default principles can apply, which may not reflect how you want your estate divided.
• Uncertainty over the children. Without an appointed guardian, the care of minor children can be left to a court process at the worst possible time.
• Delay and cost. Resolving an estate without a clear will is slower, more expensive and more stressful for the family left behind.

A registered DIFC Will replaces all of that with certainty: your named beneficiaries, your named guardians, enforced quickly through the DIFC Courts.

The DIFC will types

You can register a single comprehensive will or a targeted one covering just a category of assets – useful and cheaper if, say, you only own property here:

Will type	What it covers
Full Will	All your UAE assets plus guardianship – and can extend to assets outside the UAE
Property Will	Up to five UAE real-estate properties
Financial Assets Will	Up to ten UAE bank and/or brokerage accounts
Business Owners Will	Up to five UAE company shareholdings – key for founders
Guardianship Will	Appointment of guardians for minor children only

For a business owner, the Business Owners Will is often the priority – it determines what happens to your company shares, and pairs naturally with the succession side of any family office or holding structure.

Cost & registration fees

There are two costs: the DIFC Courts’ registration fee, and the legal drafting fee your lawyer or adviser charges. Indicative 2026 DIFC registration fees:

Will type	DIFC registration fee (indicative)
Full Will (all UAE assets + guardianship)	~USD 1,400
Single-category will (Property / Financial Assets / Business Owners)	~USD 840

These are the government registration fees only. On top, budget for professional drafting – a will is a legal document and a poorly drafted one can fail when it matters most. Couples usually register “mirror” wills, which cost more than a single will. Treat the figures as indicative for 2026 and confirm the current schedule with the DIFC Courts.

Guardianship: the part parents cannot skip

For parents, guardianship is often the single most important reason to register a will. A DIFC Will – whether a Full Will or a dedicated Guardianship Will – lets you appoint both interim guardians (who can step in immediately, avoiding a gap while longer-term arrangements are formalised) and permanent guardians for your minor children. This matters because, without it, the care of your children could be decided by a court process rather than by you. One important condition: DIFC guardianship provisions apply to minor children who are habitually resident in Dubai or Ras Al Khaimah, so families elsewhere in the UAE should take advice on the right registry for their situation.

DIFC vs ADGM vs ADJD wills

Non-Muslims in the UAE now have more than one place to register a will. The three main routes:

Route	Key features
DIFC Wills Service	English common law; DIFC Courts register and handle probate; English-language; Full Will can extend worldwide; the most established route
ADGM Wills	Registration in Abu Dhabi’s ADGM; typically requires bilingual (Arabic/English) wills; probate is completed through the ADJD courts rather than ADGM itself
ADJD (Abu Dhabi Judicial Department)	Abu Dhabi civil framework for non-Muslims; government fees often lower; suited to Abu Dhabi-based estates

For most Dubai-based international families, the DIFC route is the natural choice – common law, one court for both registration and probate, and English throughout. The right answer still depends on where your assets and family are, so it is worth a short conversation before you register. Our DIFC vs ADGM guide covers the two jurisdictions more broadly.

Do you still need a DIFC Will after the 2022 reforms?

In 2022 the UAE introduced a federal Personal Status Law for non-Muslims (Federal Decree-Law No. 41 of 2022), which removed the automatic application of Sharia principles to non-Muslims and gave them civil-law options for succession. That is a genuinely positive change – but it does not remove the case for a registered will. A clear, valid instrument is still the safest way to guarantee your specific wishes, appoint guardians, and give your family a fast, enforceable route rather than relying on default provisions or leaving room for dispute. In short: the reforms improved the default position, but a registered DIFC Will remains the certainty most families want.

How to register a DIFC Will

1. Take stock of your UAE assets and wishes – property, accounts, company shares, and who should inherit and act as guardian.
2. Choose the will type – a Full Will, or a targeted Property, Financial Assets, Business Owners or Guardianship Will.
3. Have it drafted by a qualified wills lawyer or a registered DIFC Wills draftsperson – this is where the value is; a template will can fail on the detail.
4. Register with the DIFC Courts Wills Service – in person at the DIFC or through the virtual registration appointment.
5. Keep it current. Review the will after major life events – marriage, children, a new property or business – and update it as needed.

What happens on death

When the testator dies, the executor named in the will applies to the DIFC Courts for a grant of probate. Because the will is already registered and the DIFC Courts operate in English under common law, this is typically far faster and more predictable than resolving an estate with no valid will. The grant is then recognised by the relevant UAE authorities to transfer assets – property, accounts and shares – to the beneficiaries you chose.

Common mistakes

1. Not having a will at all. The single biggest error – it exposes your family to frozen assets and default distribution.
2. Using a template. A will is a legal document; small drafting errors can invalidate it or create disputes. Use a qualified draftsperson.
3. Forgetting guardianship. Parents who cover their assets but not their children leave the most important question unanswered.
4. Choosing the wrong registry. DIFC, ADGM and ADJD suit different situations – match the route to where your assets and family are.
5. Never updating it. A will made before children, a marriage or a new business may no longer reflect your wishes.

DIFC Wills: frequently asked questions

What is a DIFC Will?

It is a will that a non-Muslim registers with the DIFC Courts to govern their UAE assets under English common law, giving them freedom to choose their beneficiaries and appoint guardians for their children. The DIFC Courts both register the will and, on death, grant the probate to enforce it.

Who can make a DIFC Will?

Non-Muslims of any nationality with assets in the UAE, or with minor children resident in Dubai or Ras Al Khaimah. Muslims’ estates are governed by Sharia principles and fall outside the DIFC Wills framework.

How much does a DIFC Will cost in 2026?

Indicatively, DIFC Courts registration is around USD 1,400 for a Full Will and around USD 840 for a single-asset-category will (Property, Financial Assets or Business Owners). These are government fees only; professional drafting is charged separately, and couples’ mirror wills cost more. Confirm current fees with the DIFC Courts.

What types of DIFC Will are there?

A Full Will (all UAE assets plus guardianship, extendable worldwide), and targeted wills: a Property Will (up to five UAE properties), a Financial Assets Will (up to ten UAE accounts), a Business Owners Will (up to five UAE shareholdings), and a Guardianship Will (guardians for minor children only).

Do I still need a DIFC Will after the 2022 non-Muslim law?

Yes, in most cases. Federal Decree-Law No. 41 of 2022 removed the automatic application of Sharia to non-Muslims and improved the default position, but a registered will is still the surest way to guarantee your specific wishes, appoint guardians and give your family a fast, enforceable process rather than relying on defaults.

DIFC or ADGM will – which is better?

For most Dubai-based international families, DIFC is the natural choice: English common law, one court for both registration and probate, English-language, and a Full Will that can extend worldwide. ADGM requires bilingual wills and uses the ADJD for probate. The best route depends on where your assets and family are based.

Can a DIFC Will cover assets outside the UAE?

A DIFC Full Will can be drafted to cover assets outside the UAE as well as UAE assets, though how foreign assets are ultimately dealt with can also depend on the law of the country where they are located. This is exactly the kind of detail to get right with a qualified draftsperson.

How do I appoint a guardian for my children?

Through a Full Will or a dedicated Guardianship Will, you can appoint both interim guardians (who can act immediately) and permanent guardians for minor children habitually resident in Dubai or Ras Al Khaimah – ensuring their care is decided by you rather than by a court process.

Sources and official references

Related guides

• Family office setup (DIFC & ADGM)
• DIFC vs ADGM comparison
• DIFC company setup
• UAE business setup overview

This guide is general information, not legal advice. A will is a legal document, and UAE succession rules – including the DIFC Wills framework and the federal personal-status law for non-Muslims – are technical and change over time; fees are indicative for 2026 and must be confirmed with the DIFC Courts. HenryClub is an independent advisory, is not a law firm and does not draft or register wills; always instruct a qualified, licensed wills lawyer for your own estate planning.