Private Clients
DIFC wills for expats and foreign nationals
01_introduction
Residency and citizenship serve different purposes, and families comparing programmes on speed or price alone often end up with the wrong one for what they actually needed. A UAE Golden Visa, a Portuguese residency route, and a Caribbean citizenship programme address different objectives: where a family can live, what passport their children hold, how many jurisdictions their tax position touches, and how much of that changes if regulations shift in any one country.
GCG's own UAE Golden Visa work is delivered directly. Programmes outside the UAE, European residency routes and Caribbean or other citizenship-by-investment programmes, are coordinated through GCG's partner network, since these are administered by each country's own immigration authority, not by GCG itself. Both are covered here, matched to what the family is actually trying to achieve rather than sold as interchangeable products.
02
Why do expats in the UAE need a DIFC will specifically?
A DIFC will is registered through the DIFC Courts Wills Service, which operates under common law principles. For a non-Muslim foreign national, this is what allows full testamentary freedom, meaning the ability to leave assets to whomever the person chooses, rather than having assets distributed according to the statutory default.
Eligibility is specific: the testator must be non-Muslim and never have been Muslim, and must be 21 or over.
A will made in a home country may eventually be recognised in the UAE, but recognition is not automatic. It typically requires translation, notarisation, legalisation or apostille, and a recognition process before the courts, months at the point when the family is least able to absorb the delay, and while UAE bank accounts are frozen. A registered DIFC will is enforced directly by the DIFC Courts, removing that step.
Assets a DIFC will can actually cover
The DIFC Courts Wills Service registers six will types. Which one you need depends on what you own, not on what you want to protect.
you own
the will
Full Will
All movable and immovable UAE assets, plus interim and permanent guardianship of minor children
Property Will
Shares in up to five UAE real estate properties
Business Owners Will
Shares in up to five UAE companies, mainland or free zone
Guardianship Will
Guardianship of minor children only, no asset distribution
Financial Assets Will
Up to ten bank or brokerage accounts held at a UAE branch
Digital Assets Will
Digital assets
You cannot stack the single-asset wills. Mixed assets mean a Full Will. Guardianship provisions only cover children living in Dubai or Ras Al Khaimah. UAE assets only. Anything held outside the country needs a will where that asset sits. You do not need to live in the UAE. Owning an asset here is enough to register.
03
Is a DIFC will recognised across all seven emirates? `
Enforcement is where the detail sits. Under Dubai Law No. 2 of 2025, the DIFC Courts have exclusive jurisdiction over the enforcement of registered non-Muslim wills, and a DIFC probate order can be presented directly to UAE banks, the Dubai Land Department, and the RTA, with no separate ratification step through the Dubai Courts. For Dubai-situated assets, that is as clean a route as exists in the UAE.
For assets held in another emirate, the will remains valid and directs those assets, but the practical enforcement step depends on the registry or authority holding the asset, and may require a further procedure in that emirate. Where a family's centre of gravity is Abu Dhabi, an ADJD or ADGM will is sometimes the better instrument, or the right answer is both. GCG maps that before recommending a registry, not after.
04
Who a DIFC will is not for
A DIFC will is not open to everyone. You have to be non-Muslim and never have been Muslim, so in a mixed-faith couple only one spouse can register one and the other needs a separate plan. It only reaches assets inside the UAE. Property, accounts and shares held abroad pass under the law of the country they sit in. Guardianship provisions only cover children living in Dubai or Ras Al Khaimah. And if the estate is simple and sits outside Dubai, the Abu Dhabi non-Muslim wills register does much the same job for a far smaller fee.
A will also only does one thing. It directs assets after you die. It does not hold them, and it does nothing while you are alive. It will not keep a business trading while the estate goes through court, it does not help if you lose capacity rather than die, and it puts nothing out of reach of a future claim. If you need wealth held, governed and passed on across generations rather than handed out once, a foundation is the right instrument, and a will sits underneath it to catch whatever is still in your own name. GCG will tell you which you need.
05
How GCG approaches this
A will is one instrument inside a plan, not the plan itself. We establish what a family holds, where it sits, and who should receive it, then register the will that actually enforces those wishes in the UAE.
Most people arrive asking to “make a will.” The prior question is what assets need protecting, where they are held, and whether a single DIFC will covers them or whether home-country assets need their own instrument. A will registered without that mapping can leave gaps, assets it does not reach, or conflicts with a home-country will.
The order:
- Establish the asset picture, UAE and abroad, and where each asset is held
- Determine what a DIFC will covers and what needs a separate home-country instrument
- Register the DIFC will to enforce those wishes, coordinated with any foreign will
The most common version of this we see: a couple who own a Dubai apartment jointly and hold a home-country will drafted before they moved. They assume the property passes under it. It may eventually, after translation, legalisation, and a recognition process, during which the surviving spouse cannot deal with the property and the joint account is frozen. The DIFC Property Will that would have avoided that costs AED 7,500.
06
Related private client services
07_faq
How is a DIFC will different from a will made in a home country?
A home-country will is not void in the UAE, but it is not self-executing either. Before it can be enforced against UAE assets it typically needs translation into Arabic, notarisation and legalisation or apostille, and a recognition process before the courts. A registered DIFC will is enforced through the DIFC Courts directly, and since Dubai Law No. 2 of 2025 the resulting probate order is presented straight to the bank or the Land Department.
The two are not alternatives. Most clients need both, a DIFC will for UAE assets and a home-country will for everything else, drafted so that neither revokes the other. That last point is where unadvised wills most often go wrong: a later home-country will containing a standard "I revoke all former wills" clause can cancel the DIFC will the family is relying on.
Does registering a DIFC will cost more than a standard local will?
It can, and the difference buys direct DIFC Courts enforcement. DIFC Courts registration fees, current schedule, exempt from VAT, with legal drafting separate and additional:
Will type | Single | Mirror (couples) |
Full Will | AED 10,000 | AED 15,000 |
Property Will | AED 7,500 | AED 10,000 |
Guardianship Will | AED 5,000 | AED 7,500 |
Business Owners Will | AED 5,000 | AED 7,500 |
Financial Assets Will | AED 5,000 | AED 7,500 |
Digital Assets Will | AED 5,000 | AED 7,500 |
Modification | AED 550 per will | — |
There is no annual fee. A booking fee applies per will and is deducted from the registration fee. Two things worth knowing: mirror wills are cheaper than two singles, a married couple registering two Full Wills together pays AED 15,000 rather than AED 20,000. And for a simple single-emirate estate outside Dubai, an ADJD (Abu Dhabi) non-Muslim will registers at AED 950 and may be the better-value instrument. (Fees current as at 10-08-2026; re-check against difccourts.ae/about/fees on the day.)
Can a DIFC will name guardians for minor children?
Yes. A DIFC will can appoint both interim and permanent guardians. The interim appointment matters most, because it covers the hours and days immediately after a death, before any court has decided anything. Guardianship can sit inside a Full Will or be registered as a standalone Guardianship Will. The limit to know: DIFC guardianship provisions apply to minor children resident in Dubai or Ras Al Khaimah. Families based in other emirates need a different route for the guardianship element.
How long does DIFC will registration take?
The registration appointment itself is short, around 20 minutes, in person at the DIFC or by virtual video appointment, with two qualifying witnesses present. The real timeline is the work before the appointment: mapping the assets, drafting, and, where a home-country will already exists, checking the two against each other. For a straightforward estate that is days, not months. (Confirm the 20-minute figure against current DIFC Courts guidance on publish.)
What happens if someone dies in the UAE without a registered will?
Nothing is confiscated and nothing goes to the state in the ordinary case. What happens is that a formula decides instead of you, and the family waits. Under Federal Decree-Law No. 41 of 2022, the civil default for a non-Muslim estate is half to the surviving spouse and the other half divided equally among the children, regardless of gender. Where there are no children, the estate passes to parents, then to siblings. Heirs can ask the court to apply the law of the deceased's nationality instead, but only if they can prove that law to the court's satisfaction, a documentary exercise carried out by a grieving family under time pressure. Two practical consequences matter more than the formula: UAE bank accounts are frozen on notification of death, including in many cases joint accounts, until a court order issues; and a court decides guardianship of minor children if no guardian has been named.
There is also a narrow change effective 1 January 2026: under Federal Decree-Law No. 51 of 2024, where a non-Muslim dies with no registered will and no identifiable heirs can be established, UAE assets may ultimately pass into a state-managed charitable endowment (Waqf). An estate is not treated as heirless simply because immediate family is not resident in the UAE, so this is a narrow case, but it is real.