Wills and Inheritance in the UAE

Why It Is Important for Expats to Have a Will

Expat families often have assets located in several countries. In the absence of a will, the distribution of property may be carried out according to Sharia law, which does not always coincide with the owner's intentions. A will allows you to determine in advance who your heirs will be and how your real estate, accounts, and corporate shares will be transferred. In this context, family law in the UAE gives expats the opportunity to choose the applicable rules, which is critical for protecting the interests of their loved ones.

Types of Wills Available in the UAE

In the UAE, several formats of wills are available depending on the testator’s nationality, religion, asset structure and intended distribution plan. Each format has its own registration requirements, language rules and scope of application.

DIFC Will
A DIFC will is registered under the DIFC Courts system and follows common law principles. It is primarily designed for non-Muslims and allows full freedom of asset distribution without automatic application of Sharia rules. The document is drafted in English and registered within the DIFC Wills Registry. It is commonly chosen by expats, property owners in Dubai and individuals seeking predictability in estate planning.

ADJD Will
An ADJD will is registered through the Abu Dhabi Judicial Department and can apply across the UAE. It is also suitable for non-Muslims and allows customised inheritance distribution. This format may be drafted in English or Arabic and is often selected by residents of different emirates or individuals with assets across multiple emirates.

Sharia Will
For Muslims, inheritance is generally governed by Sharia principles. A Sharia-compliant will may allow limited discretionary distribution within the boundaries permitted by Islamic law. In the absence of a will, assets are distributed strictly according to predetermined shares.

Combined and International Structures
Where assets are located in multiple jurisdictions, a coordinated approach may be required. This can include separate wills for UAE-based assets and overseas property, ensuring that documents do not conflict and comply with each jurisdiction’s legal standards. Such solutions are particularly relevant for business owners and internationally mobile families.