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UAE inheritance law and making a will in Dubai for expats
Banks freeze accounts as soon as they learn the owner has died. Without a will a court divides the estate: half to the spouse and half to the children for non-Muslims, Sharia shares for Muslims. A DIFC will costs from $1,400 and is registered by video call in about 20 minutes.
A UAE bank freezes an account the moment it learns the holder has died, and a joint account with a spouse is no exception. The Dubai flat, the deposit and the shares in a company all stay out of the family's reach until a court names the heirs and their shares. Without a will registered in the Emirates, that decision belongs to the law rather than the owner, and the law is different for Muslims and non-Muslims.
Since 1 February 2023, non-Muslim foreigners have been covered by Federal Decree-Law No. 41 of 2022 on Civil Personal Status. With no will, half of everything in the UAE goes to the surviving spouse and the other half is split equally among the children, sons and daughters alike. Muslims, including foreign Muslims, remain under Sharia (Islamic law): a son takes twice a daughter's share, and a widow with children receives one eighth.
Fixing this in advance is cheap by the standards of Dubai property. A full will with the DIFC Courts Wills Service costs $2,800 in registration fees; an ADGM will costs about $420. There is no inheritance tax in the UAE, so the issue is not money for the treasury but who gets access to the assets, and when.
Below: what happens to UAE assets without a will, which will to choose and what it costs, when a foundation beats a will, how heirs transfer property and unlock bank accounts, and who these tools do not suit. How inheritance interacts with a second citizenship and a change of country is covered in our article on inheritance and a second passport.
UAE inheritance law for expats: what happens without a will
The answer depends on the deceased's religion. The UAE is a federation of seven emirates, and family matters here have long been split between two legal systems: Islamic law for Muslims and civil rules for everyone else.
For non-Muslims, Article 11 of Decree-Law No. 41/2022 applies. Half of the estate goes to the husband or wife, the other half is divided equally among the children with no distinction between sons and daughters. If there are no children, the parents inherit in equal shares. If only one parent is alive, that parent takes half and the brothers and sisters share the other half; with no parents, the siblings split everything equally. Abu Dhabi wrote the same proportions into law even earlier, in Abu Dhabi Law No. 14 of 2021 on civil marriage and its effects.
There is a caveat few people know about. Paragraph 3 of the same article lets any foreign heir ask the court to apply not these rules but the law designated by the UAE civil code, usually the law of the deceased's nationality. Only one thing blocks such a request: a registered will. Since 1 June 2026 the 1985 civil code has been replaced by the new Civil Transactions Law (Federal Decree-Law No. 25 of 2025), and case law on its conflict-of-laws rules is still taking shape.
For Muslims, the estate is divided by the fixed Sharia shares set out in the Quran (Surah 4, verses 11-12). A widow receives 1/8 if the deceased had children and 1/4 if not. A son receives twice as much as a daughter. Only up to one third of the estate can be left freely by will.
Worked example. A Dubai flat is worth $550,000; the heirs are a wife, a son and a daughter. Under the non-Muslim rules the wife receives $275,000, and the son and daughter $137,500 each. Under Sharia the wife receives about $69,000, the son about $321,000 and the daughter about $160,000. For the widow, the difference is fourfold.
Since 10 July 2023, non-Muslim inheritance disputes in Dubai have been heard by a dedicated division for non-Muslim inheritance and the execution of wills within the Dubai Courts, as announced by the Dubai government media office. Its legal basis is Dubai Law No. 15 of 2017 on non-Muslim wills and probate.
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Is a foreign will valid in the UAE
A foreign will is not prohibited, but UAE courts are not bound to enforce it directly. It has to be legalised or apostilled, translated into Arabic by a sworn translator licensed by the UAE Ministry of Justice, and then proven in a local court as valid and applicable to the assets in the Emirates. All the while the accounts stay frozen and the flat cannot be sold.
Many home jurisdictions send real estate back to the UAE anyway: under their conflict of laws rules, the inheritance of real estate is governed by the law of the country where it is located. A will made before a notary at home does not change the fact that a Dubai flat will be divided under UAE rules.
That is why owners with assets in several countries use one will per jurisdiction: a UAE will for assets in the Emirates, a home-country will for everything else. The texts are aligned so that the newer one does not revoke the older one with a boilerplate line such as "I revoke all previous wills".
If there is a company in the UAE alongside the property, its shares also form part of the estate and pass only through the court. How to hold a business in the Emirates is covered on our page on company registration in the UAE.
Which will to choose in the UAE: DIFC, ADGM or the Dubai Courts
Non-Muslims have three main routes, and they differ in cost, language and where the estate is administered after death.
DIFC (Dubai International Financial Centre) is a free zone with its own courts based on English common law. The DIFC Courts Wills Service registers wills in English, and after death the same courts issue a Grant of Probate, the court confirmation of the will that lets the executor deal with the assets.
ADGM (Abu Dhabi Global Market) is the capital's counterpart to DIFC. Its notary public attests non-Muslim wills jointly with the Abu Dhabi Judicial Department (ADJD). The estate is then administered by ADJD.
The Dubai Courts and emirate notaries are the third route. A non-Muslim will is attested by a notary, and after death the case goes to the non-Muslim inheritance division of the Dubai Courts or to the court of another emirate.
| Feature | DIFC | ADGM (with ADJD) | No will |
|---|---|---|---|
| Who can register | a non-Muslim aged 18 or over who has never been a Muslim, with assets or minor children in the UAE | a non-Muslim with assets in the UAE | - |
| UAE residence visa required | no | no, but a valid UAE visa or entry stamp is needed | - |
| Registration fee | from $1,400; full will $2,800 | ~$420 | heirs' court costs |
| Language | English | bilingual, Arabic and English | Arabic in court |
| Format | video call or in person, about 20 minutes, e-signature | fully online, by video call | - |
| Guardians for children | can be appointed for children living in Dubai or Ras Al Khaimah | can be appointed in the will | decided by the court |
| Where the estate is administered | DIFC Courts | ADJD | court of the emirate where the assets are |
| Who inherits | whoever the owner named | whoever the owner named | spouse 50%, children 50% equally (non-Muslims) |
For owners of Dubai property, DIFC is usually more convenient: an English document, probate in the same court, and separate will types for property, business and bank accounts. ADGM costs a fraction of the price and makes sense when the assets and the family are in Abu Dhabi. An overview of the emirate is on our Abu Dhabi page.
How much does a DIFC will cost in 2026
The DIFC fee depends on the type of will and on whether one owner registers alone or a married couple registers together. Mirror wills are two near-identical documents in which husband and wife leave their assets to each other and, after the second death, to the children. For a couple they cost less than two separate wills.
| DIFC will type | What it covers | Single owner | Couple (mirror wills) |
|---|---|---|---|
| Full Will | all movable and immovable assets in the UAE, guardians for children | $2,800 | $4,100 |
| Property Will | shares in up to five properties in the UAE | $2,100 | $2,800 |
| Business Owners Will | shares in up to five companies in the UAE | $1,400 | $2,100 |
| Financial Assets Will | up to 10 bank accounts in the UAE | $1,400 | $2,100 |
| Digital Assets Will | digital assets | $1,400 | $2,100 |
| Guardianship Will | guardians for children under 18 only | $1,400 | $2,100 |
The figures come from the official DIFC Courts fee schedule. A booking fee is paid when the appointment is made: $280 for a single full will and $550 for mirror wills. It is deducted from the registration fee but not refunded if the appointment is cancelled or rescheduled more than three times. Amending a registered will costs $150, and the heirs' application for a Grant of Probate after death costs $1,500.
Choosing the will type is mainly a question of scope. A Property Will is $690 cheaper than a full will but covers only real estate. If the owner also has bank accounts, a car or company shares in the UAE, those stay outside the will and pass under the default rules. A full will covers everything at once and lets the owner appoint guardians for the children.
Registration fees are only part of the budget. Drafting a text that fits the specific assets, family and citizenship is separate work. Murblz's fee for it is shown in the table below this text.
Fees from $1,400 - but a will does not protect assets left out of it
The law does not stop you making a UAE will on your own. But mistakes cost more than the fee: a will type that misses bank accounts or company shares, children left without named guardians, a text that contradicts the will at home and a missed appointment after which the booking fee is lost. Murblz specialists list your UAE assets, choose the will type or a foundation, align the text with your home-country will and handle registration with the court. We guarantee professional work and a transparent process, and in most cases a result on the first application.
The cost of support depends on your assets and family; package prices are in the table on the page, and a manager will calculate the total in the chat.
How to make a will in Dubai: step by step
The DIFC process is built for foreigners, including those who do not live in the UAE. The registration itself takes about 20 minutes; most of the time goes into preparation.
- Asset inventory. List everything held in the UAE: properties with their title deed numbers, bank accounts, company shares, cars, digital assets. This determines the will type.
- Heirs and shares. Decide who receives what, and who inherits if the main beneficiary dies first or at the same time as the owner.
- Executor and guardians. Appoint an executor, who will approach the court after death and deal with the assets. The executor does not have to live in the UAE and may also be a beneficiary. With minor children, appoint an interim and a permanent guardian so that the court does not have to decide on guardianship itself.
- Witnesses. Two witnesses are needed, neither of whom is named in the will as a beneficiary or guardian.
- Booking. Book an appointment with the DIFC Courts Wills Service and pay the booking fee.
- Registration. The appointment takes place by video call or at the court's office, and the will is signed electronically.
- Updates. After buying another property, a divorce or the birth of a child, the will is amended for $150 rather than a new registration fee.
The court requires anyone who drafts DIFC wills professionally to be registered with the Wills Service. So Murblz specialists work on each will together with such a registered partner: we gather the information and align the text with the documents in the home country, and the partner handles registration.
ADGM wills and wills in Abu Dhabi: how they work
ADGM is the cheapest way to register a non-Muslim will in the UAE: about $420 in fees to the Abu Dhabi Judicial Department and the ADGM Courts. That is more than six times less than a full DIFC will. The current fee schedule has applied since 8 February 2025.
Since 2021 the ADGM Courts notary public has attested non-Muslim wills in partnership with ADJD. The process is fully digital: the document is reviewed in advance, then an appointment is held by video call. The legal basis is Abu Dhabi Law No. 11 of 2017 on the notary public. UAE residence is not required, but a non-resident needs a valid UAE visa or entry stamp.
The low price has a catch. The will is drawn up in two languages, with the Arabic version prepared by a translator accredited by the UAE Ministry of Justice. And the ADGM Courts do not handle probate: after death the heirs go to the ADJD Wills and Probate Office. For a family whose flat is in Dubai, that means a court in another emirate and paperwork in Arabic.
Without a will, an Abu Dhabi estate is divided under the same rules that apply to non-Muslims across the country: half to the spouse, half to the children in equal shares.
What Muslims and mixed-faith families can do
A DIFC will does not help a Muslim. The DIFC Courts state plainly that registering one is not advisable for a Muslim, and list as a condition that the testator is not and has never been a Muslim. That also applies to anyone who has ever converted to Islam, for example on marriage.
For Muslims, a new Personal Status Law, Federal Decree-Law No. 41 of 2024, has applied since 15 April 2025. A will still works within one third of the estate. Leaving an heir more than the legal share is possible only with the consent of the other adult heirs, within their own shares, or where a court finds a compelling reason. On the other hand, the law now expressly recognises wills between people of different faiths, such as a Muslim husband leaving assets to a Christian wife.
Everything else is divided under Sharia. That is why Muslim and mixed-faith families usually plan succession through lifetime steps rather than a will:
- gifting property to a spouse or children through the Dubai Land Department (DLD, the emirate's property registry): the fee is 0.125% of the valuation, with a minimum of $550, instead of 4% on a sale;
- a company or foundation that owns the assets: what passes on is a shareholding or a role in the foundation, with the transfer rules set out in advance;
- co-ownership of property with shares that already belong to family members.
Each option has tax consequences in the family's country of residence, so it is checked against that country's tax law before any transfer. The Emirates' own taxes are summarised on our page on taxes in the UAE.
A DIFC or ADGM foundation instead of a will: when it pays off
A foundation is a separate legal entity without shareholders that holds assets under its charter. The founder transfers flats, company shares or accounts into it, and the foundation council manages them under rules written in advance. When the founder dies, the foundation's assets are not part of the founder's estate and are not frozen along with the founder's personal accounts: the foundation keeps operating under its charter.
DIFC foundations are governed by DIFC Foundations Law No. 3 of 2018, ADGM foundations by the ADGM Foundations Regulations 2017. Both require a council of at least two members. The DIFC law specifically shields a foundation from foreign forced heirship rules: under Articles 14 and 15, a transfer of assets into a foundation cannot be challenged on the basis of such rights. This matters for families from countries with forced heirship, where minor children or a dependent spouse receive a compulsory share even against the will.
DIFC government fees for a foundation are modest. Under the 2026 DIFC fee schedule, registration is free, the licence costs $350 on registration and $350 a year after that, and the annual confirmation statement another $300. The main costs are a registered address in DIFC, council members, bookkeeping and filings.
Moving Dubai property into a foundation is a DLD transaction. The standard transfer fee is 4% of the value; the reduced 0.125% applies to gifts to first-degree relatives and to companies. DLD publishes no separate rate for transfers into a foundation and decides case by case.
Worked example. A flat is worth $550,000. A 4% fee is $22,000; a 0.125% fee is $690. That $22,000 gap decides whether a foundation is worth it for a single flat.
A foundation makes sense when there are many assets across several emirates or countries, when the family includes Muslims or heirs in forced heirship countries, and when the owner wants to manage succession over years rather than through one document. For one flat and one account, a DIFC will is simpler and cheaper. How to choose between a trust and a foundation is covered in trust or foundation: which to choose, and all structures are gathered in our trusts and private foundations section.
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How heirs take over a Dubai flat and unlock bank accounts
With a DIFC will the path is shortest. The executor writes to the DIFC Courts with the death certificate, files an application for a Grant of Probate and pays $1,500. According to the court, a grant is normally issued within a few weeks when the paperwork is complete and the case is straightforward. If an asset was left out and found later, a further court order costs another $300.
Without a will, the heirs first obtain an inheritance certificate from the court of the emirate, listing every heir and their share. For non-Muslims in Dubai, that case is handled by the Dubai Courts' non-Muslim inheritance division. Filings are in Arabic, and foreign birth and marriage certificates must be apostilled and translated in advance. If the heirs disagree, the process lasts as long as the dispute.
Next comes the property transfer at DLD. The service is called Inheritance Title Transfer and costs about $380 per property, including the new title deed and the service centre fee. The property map fee is charged separately. It requires:
- the inheritance certificate;
- an official letter from the court to DLD asking for the property to be transferred to the heirs;
- Emirates ID (the UAE residents' identity card) of all resident heirs and passports of non-resident heirs;
- a NOC (no objection certificate) from the bank if the flat is mortgaged, or from the developer if it was bought off-plan.
Bank accounts work the same way: the bank unfreezes them on a court order, not at the family's request. A joint account does not pass automatically to the surviving holder. Without a will recognised in the UAE, families can be left without access to their money for long periods. A second account in the spouse's name at a different bank is a simple safeguard for the first months. How to open a personal account in the Emirates is covered on our page on personal bank accounts in the UAE.
Is there inheritance tax in the UAE
No. The UAE levies no inheritance tax, no gift tax and no personal income tax. Heirs pay only fees: to the courts, to DLD, to notaries and to translators.
Tax may arise in the country where the heirs live. Some countries do not tax inheritances but tax the gain when an inherited flat is sold, depending on how long it was held. In several European countries, including Germany and Spain, residents pay inheritance tax on assets worldwide, including a flat in Dubai. If the family is planning to move, this is worth factoring in before choosing the country. Life and taxes in the Emirates are covered in detail in the UAE in 2026: residency, taxes and cost of living.
Pitfalls and who this does not suit
- Wills go out of date. A Property Will covers only the properties named in it, five at most. A sixth flat bought later passes under the default rules unless the will is amended.
- Beneficiary witnesses. Beneficiaries and guardians named in a DIFC will cannot act as its witnesses. The simplest fix is to use witnesses from outside the family.
- Assets outside the UAE. A full DIFC will can also cover assets in other countries, but the court itself advises checking in advance whether it can be enforced there. That is why such assets get a separate local will.
- Guardianship in two emirates only. DIFC guardians can be appointed for children living in Dubai or Ras Al Khaimah. A family in Abu Dhabi or Sharjah needs another route.
- Mortgages and off-plan units. Without a letter from the bank or developer, DLD will not transfer the property even under an undisputed will.
- A foundation does not hide assets from creditors. Under Article 14 of the DIFC Foundations Law, the court may set aside a transfer into a foundation to the extent of a debt if the founder was insolvent at the time or intended to defraud creditors.
Who it does not suit. A DIFC will does not suit Muslims or anyone who has ever converted to Islam. Without assets or children in the UAE it is pointless: there is nothing to register. A foundation is unnecessary for the owner of a single flat without a complex family, and moving assets into a foundation a few months before insolvency or a lawsuit is risky: the transfer can be set aside.
Who it suits. Non-Muslim foreigners with property in Dubai, including property bought for a residence visa (see our page on UAE residency by investment). Families with children who want to appoint a guardian. Owners of companies and accounts in the Emirates who do not want the business to stall for months. And families from countries whose inheritance rules differ sharply from those of the UAE.
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How Murblz helps with inheritance in the UAE
We work in two situations: when an estate has already opened and there is no will, and when an owner wants to settle everything in advance.
Estates without a will. Murblz specialists, together with partners holding a local licence, handle the case from the inheritance certificate to the transfer of assets:
- we gather, apostille and translate into Arabic the documents on kinship and marriage;
- we run the case in the court of the emirate where the assets are, including the Dubai Courts' non-Muslim inheritance division;
- we obtain court letters to DLD and the banks, and NOCs from the lending bank and the developer;
- we transfer property to the heirs and unfreeze the accounts.
A DIFC will in advance. We review the assets in the UAE and elsewhere, the family and the citizenships involved. We pick the will type so the owner neither overpays for a full will where a Property Will is enough nor leaves accounts and company shares uncovered. We align the text with the will in the home country, prepare the document with a partner registered with the DIFC Courts Wills Service and complete the registration. If the family needs a foundation, we compare DIFC and ADGM with trusts and foundations in other countries.
Succession planning usually runs alongside other matters in the Emirates. We support property purchases through our investment property in the UAE service, and company accounts on our page on business bank accounts in the UAE. If part of the family's assets sits in a British Virgin Islands company, a will under BVI law may help. A country overview is on our UAE citizenship, residency and taxes page, and life in the city is covered in our Dubai guide.
Murblz's fees and the DIFC registration fee are listed in the table below. Court fees, DLD fees and translations are paid separately at the authorities' rates.
Fees
| Service | Price |
|---|---|
| UAE probate support (no will) | $66 000 |
| Will drafting via DIFC Wills Service | $11 000 |
| DIFC will registration government fee | from $1 400 |
We will calculate online the full cost for your task.
FAQ
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We review your assets in the Emirates and prepare a registered will or a foundation structure so they pass according to your wishes. The catalogue covers trusts and foundations worldwide.
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