Two frameworks. Different rules. Real consequences
Non-Muslim residents in the UAE often hear about both DIFC wills and other UAE wills options and are not sure which one applies to them. The frameworks are different, and the choice has consequences for distribution, validity, and ease of administration.
DIFC Wills Service Centre
Operated by the DIFC Courts and the Government of Dubai. Designed exclusively for non-Muslims. Applies to assets in the UAE and Ras Al Khaimah. Built on common law principles of testamentary freedom. Strongly established framework with significant case-law support. Available in English.
Dubai Courts non-Muslim wills register
A register operated by the Dubai Courts for non-Muslim wills. Different procedural framework. Available for non-Muslim residents in Dubai. Used by clients who prefer to work with the local court system directly.
Abu Dhabi Judicial Department (ADJD)
Registers non-Muslim wills under the Abu Dhabi civil personal status framework introduced by Law No. 14 of 2021. Strong framework, particularly for Abu Dhabi residents and assets located in the emirate.
Key practical differences
- Geographic scope: DIFC wills cover UAE-wide; ADJD primarily Abu Dhabi
- Language: DIFC wills in English; Dubai Courts register in Arabic
- Legal tradition: DIFC follows common law; Dubai Courts follow civil law
- Fees and procedures: each register has its own fee schedule
- Enforcement: each register provides distinct enforcement pathways
Which one is right for you?
It depends. Residency, location of assets, language preference, family structure, and other factors all matter. The choice is rarely obvious without legal advice. In some cases, a coordinated approach using more than one framework for different asset categories is optimal.
Get a clear answer for your situation
Confidential consultation. Fixed-fee will drafting. Coordination with the appropriate register.