How Non-Muslim Expatriates Can Register Their Wills in the UAE Under the Latest Civil Personal Status Law

The United Arab Emirates has significantly modernised its legal framework governing inheritance and wills for non-Muslims, offering expatriates greater certainty, flexibility and control over how their estates are distributed. Under the current law, non-Muslim residents are no longer automatically subject to Sharia-based inheritance rules and may freely register wills governing their assets in the UAE and abroad.

The legal foundation for this shift lies in the Civil Personal Status Law, which applies to non-Muslim UAE citizens and non-Muslim foreign residents. The law allows non-Muslims to choose how their personal status matters -- including inheritance and wills -- are governed, unless they expressly opt for the application of their home country’s law. Crucially, the legislation permits a non-Muslim testator to bequeath all assets to beneficiaries of their choice, subject to procedural requirements laid down in implementing regulations.

Across the UAE, non-Muslim expatriates can register wills through the courts of the relevant emirate. These services are available via judicial authorities such as Dubai Courts, the Abu Dhabi Judicial Department and the Ministry of Justice, typically through a notary public. A registered will ensures that the testator’s wishes are formally recognised and enforceable upon death, reducing the risk of disputes or delays.

Dubai: Dual Registration Options

Dubai offers a particularly structured framework for non-Muslim wills. The law governing the administration of estates and implementation of wills for non-Muslims applies to all such wills in the emirate, including those relating to assets held in free zones. A dedicated register for non-Muslim wills operates under both Dubai Courts and the DIFC Courts, giving residents two distinct registration pathways.

A non-Muslim resident in Dubai may register a will either before Dubai Courts or through the DIFC Wills Service Centre. Both routes allow testators to clearly identify executors and beneficiaries and to specify how assets are to be distributed. These assets may include real estate, business interests, shares, bank accounts, investments, intellectual property, digital assets and other movable or immovable property, whether located inside or outside the UAE.

 

DIFC Wills: Global Asset Coverage

The DIFC Wills Service Centre is particularly popular among expatriates seeking a common-law-style approach. Wills registered with the DIFC must be written in English, signed by the testator and witnessed by at least two adults, either in person or virtually before an authorised officer. The will must appoint executors and, where relevant, guardians for minor children residing in Dubai or Ras Al Khaimah.

A key advantage of DIFC wills is their international scope. Testators may include both UAE-based and overseas assets within a single will, provided the will expressly states that succession is to be governed by DIFC laws and rules. This offers expatriates a streamlined solution for estate planning across jurisdictions.

 

Abu Dhabi and ADGM

Non-Muslim expats residing in Abu Dhabi also have access to wills registration services through local judicial authorities. In addition, the Abu Dhabi Global Market (ADGM) Courts provide a specialised framework similar to the DIFC system, allowing non-Muslims to register wills covering assets in the UAE and internationally under ADGM rules.

 

Embassy and Consular Wills

In certain cases, non-Muslim expatriates may also register wills at the embassy or consulate of their home country, provided such services are offered. While consular wills may be recognised, legal experts generally advise ensuring that the will is enforceable under UAE procedures, particularly when dealing with local assets such as property or bank accounts.

 

A Clear Path for Estate Planning

Taken together, the UAE’s current legal regime provides non-Muslim expatriates with multiple, legally secure options for estate planning. Whether registered through local courts, financial free zone registries or diplomatic missions, a properly drafted and registered will allows expats to safeguard their families’ interests, ensure smooth succession and avoid uncertainty in the administration of their estates.

 

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