TRW & Co · Private wealth and succession
DIFC Wills for Non-Muslims: How They Work
DIFC wills for non-Muslims let non-Muslim residents and property owners decide who inherits their UAE assets and who looks after their children, using English-language, common-law wills registered with the DIFC Courts. There are six will types with fixed fees, registration can be done by video link, and probate runs through the DIFC Courts with execution via the Dubai Courts.
Key pointA DIFC will only covers what it deals with: assets left out, or overseas assets, fall back to the courts and law where they sit. Coordinate it with your home-country will so neither revokes the other.
At a glance
Non-Muslims aged 21+
The DIFC Wills and Probate Registry Rules apply to wills of non-Muslim individuals over the age of majority, which the Rules define as 21.
Six will types
Full, Property, Financial Assets, Business Owners, Digital Assets and Guardianship Wills, each with a fixed registration fee and a mirror option for spouses.
Full Will AED 10,000
The DIFC Courts list AED 10,000 for a single Full Will and AED 15,000 for mirror Full Wills; targeted templates cost less.
Guardians in Dubai and RAK
Guardianship provisions cover minors habitually resident with the testator in Dubai or Ras Al Khaimah, with interim and permanent guardians available.
Probate via Dubai Courts
A DIFC grant of probate can be converted into a Dubai Courts judgment so banks, the land department and free zones release assets.
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DIFC wills for non-Muslims are wills registered with the DIFC Courts Wills Registry under a common-law set of rules, so that a non-Muslim's UAE assets pass, and their children's guardians are appointed, according to their own wishes rather than default rules. The will is drafted in English, signed before a registry officer and two witnesses, and later administered through a DIFC Courts grant of probate that is executed through the Dubai Courts.
This article explains how the service works in 2026: the six types of will, who can use them, the registration process and fees, how probate runs, and where a DIFC will is and is not the right tool. For the wider picture of expat succession, read our guide to wills and inheritance in the UAE for expats.
The short answer: how DIFC wills for non-Muslims work
The DIFC Courts Wills Service is a joint initiative of the Government of Dubai and the DIFC Courts. It was established by a DIFC resolution in 2014 and its authority was reaffirmed by Dubai Law No. 15 of 2017, which regulates inheritance, wills and probate for non-Muslims. In practice:
- Eligibility. The testator must be a non-Muslim over the age of majority, which the Rules set at 21. The standard forms require a declaration that the testator is not, and has never been, a Muslim.
- Six products. A Full Will, Property Will, Financial Assets Will, Business Owners Will, Digital Assets Will and Guardianship Will, each with a fixed registration fee and a cheaper mirror option for couples.
- Formalities. The will is in English, in the prescribed form, signed by the testator and witnessed by two adults in the presence of the Registrar or an authorised officer, in person or by video link.
- Effect. On death, the executor applies to the DIFC Courts for a grant of probate. The grant can be converted into a Dubai Courts judgment so that banks, the land department and free zone registries act on it.
The legal basis and the Rules
The service is governed by Dubai Law No. 15 of 2017 and by the DIFC Wills and Probate Registry Rules, issued under a Dispute Resolution Authority order and amended by later orders and practice directions. The current consolidated Rules published on the DIFC Courts Rules and Directions page took effect on 30 June 2019. They are based on common-law principles, drawing on the laws of England and Wales, Singapore and Malaysia, while remaining consistent with UAE public policy.
Federally, non-Muslims are already free to leave their UAE property by will under the 2022 Civil Personal Status Law. The DIFC route adds a specialised registry, standard English-language forms, a court with probate experience and a recognised path to execution. Our note on the UAE personal status law for non-Muslims explains the federal default rules that apply if no will is registered.
Several limits come directly from the Rules. They apply only to the part of an estate dealt with by the will; any assets the will does not cover are administered by the courts where those assets are located. And if the testator becomes a Muslim after registering, the Rules no longer apply to the will, and the estate is administered under the law of the place where it is situated.
The six types of DIFC wills for non-Muslims and their fees
The table summarises the registration fees published by the DIFC Courts for each will. Draftsmen's fees are separate. Mirror wills are for spouses registering at the same time.
| Will | What it covers | Single | Mirror pair |
|---|---|---|---|
| Full Will | All types of asset, with optional guardianship provisions and an optional digital assets section | AED 10,000 | AED 15,000 |
| Property Will | Up to five UAE real estate properties, or shares in them | AED 7,500 | AED 10,000 |
| Financial Assets Will | Up to ten bank or brokerage accounts held at UAE branches of regulated institutions | AED 5,000 | AED 7,500 |
| Business Owners Will | Up to five shareholdings in UAE-incorporated companies | AED 5,000 | AED 7,500 |
| Digital Assets Will | Supported crypto-assets held in the DIFC Courts' non-custodial wallet | AED 5,000 | AED 7,500 |
| Guardianship Will | Appointment of interim and permanent guardians only, no assets | AED 5,000 | AED 7,500 |
A Full Will is the default choice for anyone with more than one type of asset or who wants both asset and guardianship provisions in one document. The narrower templates suit people with a single, well-defined asset class. Fees can change, so confirm the current schedule on the DIFC Courts website before you book.
Asset scope: UAE and beyond
The standard forms are made in respect of property in the UAE. The Full Will form also allows the testator to specify a wider geographical scope, with an express warning that independent legal advice should be taken on whether the will is enforceable in any other jurisdiction. In most cases, it is safer to cover UAE assets in the DIFC will and assets elsewhere in a will made under the law of the country where they sit.
Registering DIFC wills for non-Muslims: step by step
- Choose the will type. Decide between a Full Will and one of the targeted templates, and whether you need guardianship provisions.
- Decide whether to use a draftsman. The Wills Service publishes a list of approved wills draftsmen who meet minimum standards on the Rules. A Full Will with trusts, tiered gifts or business assets almost always justifies professional drafting.
- Gather information. Identification documents, full details of executors, beneficiaries and guardians, and precise descriptions of property title deeds, bank and brokerage accounts and company shareholdings.
- Prepare the will on the portal. The will is completed in the prescribed form through the DIFC Courts' online portal, with executors and beneficiaries entered there.
- Arrange guardian undertakings. If guardians are appointed, they must undertake to act under the Rules and submit to the DIFC Courts' jurisdiction, in person or by a verified witness statement.
- Book and pay. Pay the registration fee and book an appointment. Registration appointments can be held by video conference, with the testator and two witnesses joining from anywhere.
- Sign and register. The testator signs, the witnesses attest, and the will is stored electronically. The electronic version held by the Registry is treated as the original, and the testator receives a copy.
Choose witnesses who are over 21, not beneficiaries, and available on the appointment date with valid identification. Many registrations are delayed not by drafting but by a witness who cannot attend or whose documents do not match the booking.
Changing or withdrawing a registered will
A registered will is not fixed for life. It can be modified for a fee, for example to add guardianship provisions after children are born or to change beneficiaries. Under the Rules, a testator can also apply in writing to withdraw a will from the Registry; the will is then treated as revoked from the date the application is received and is no longer eligible for probate. Registered wills are open to inspection only by the testator or their authorised representative during life, and after death by executors, guardians and beneficiaries.
Guardianship of children in DIFC wills for non-Muslims
For many parents, guardianship is the main reason to register. The Rules allow a will to appoint guardians for a minor who habitually resides with the testator in Dubai or Ras Al Khaimah. After death, the DIFC Courts can issue both interim and permanent guardianship orders, provided the nominated guardians meet the eligibility requirements and the appointment does not contravene UAE public policy.
The Guardianship Will page explains the distinction. An interim guardian is someone nearby, often a friend or relative in the UAE, who looks after the children immediately. Permanent guardians may live elsewhere and take over once arrangements are in place. Appointing both avoids children being placed with authorities while relatives travel.
Families living in Abu Dhabi, Sharjah or the other emirates should check whether a DIFC guardianship appointment will cover their children, and consider the onshore route instead. Our article on Abu Dhabi non-Muslim wills covers the capital's own registry.
Probate of DIFC wills for non-Muslims after death
The executors named in the will apply to the DIFC Courts Wills Registry for a grant of probate, in the prescribed form and with the applicable fee. The Registry assigns a case progression officer as the executors' point of contact. Executors may handle the application themselves or instruct a lawyer, including under a power of attorney.
Under the protocol of enforcement between the DIFC Courts and the Dubai Courts, a grant of probate or guardianship order can be converted into a Dubai Courts judgment. The Execution Department of the Dubai Courts then instructs the authorities holding the assets, such as the Dubai Land Department, free zone authorities and banks, to distribute them according to the will, as explained on the DIFC Courts probate page. Claims and objections during probate are dealt with by the DIFC Courts.
Digital assets
The Digital Assets Will links the will to a non-custodial wallet provided by the DIFC Courts, built on distributed ledger technology. After registration, the testator can allocate supported assets to listed beneficiaries during their lifetime without further cost; changing the beneficiaries requires a paid modification of the will. Only assets moved into that wallet are covered, so exchange-held assets and unsupported tokens need separate arrangements. For disputes and recovery issues involving crypto, see crypto disputes and asset recovery in the UAE.
An illustrative scenario
Illustrative only; the parties are generic. A non-Muslim couple from Singapore live in Dubai with two children aged six and nine. They own an apartment in joint names, hold salary and savings accounts with UAE banks, and one spouse owns a free zone trading company. Their parents live in Singapore; close friends live in Dubai.
They register mirror Full Wills. Each leaves their UAE estate to the other, then to the children on trust until a stated age, and names a friend in Dubai as interim guardian and a sibling in Singapore as permanent guardian. The company-owning spouse coordinates the will with the company's articles and appoints an alternate signatory. Their Singapore wills are revised to cover only Singapore assets and not to revoke the DIFC wills.
If both died together, the friend could care for the children at once under an interim guardianship order, and the executors could apply for probate with a clear path to execution through the Dubai Courts.
Risks and common mistakes
Assuming the DIFC will covers everything
A DIFC will covers only the assets it deals with. Any assets left out are administered by the courts where they are located under the applicable law. Overseas assets are best covered by a local will, and assets added after registration, such as a new property, may require the will to be updated if a targeted template was used.
Conflicting wills in two countries
A home-country will that revokes "all previous wills" can revoke a DIFC will, and vice versa. Each will should state its geographical scope and expressly preserve the other. Review both whenever either is changed.
Change of religion or circumstances
If the testator becomes Muslim, the Rules no longer apply to the will. Marriage, divorce, the birth of children or a move to another emirate can also change what the will should say or whether guardianship provisions remain effective. Diarise a review at least every few years.
Trusts and gifts that fail
Gifts are valid only to the extent that they are made in favour of persons, including legal entities. Gifts to pets, purposes or uncertain classes can fail. Life-interest and trust provisions need careful drafting to work within the Rules; this is where an approved draftsman adds most value.
Overlooking liquidity and incapacity
Probate takes time, and bank accounts are usually frozen in the meantime. A will does nothing if you lose capacity during your lifetime. Keep separate accounts for the surviving spouse, and plan for incapacity through business continuity arrangements and, for larger estates, structures such as a DIFC foundation.
When a DIFC will is the right choice, and what to do next
DIFC wills for non-Muslims are usually the right choice for non-Muslim residents of Dubai or Ras Al Khaimah who want English-language documents, common-law drafting, guardianship appointments and a predictable probate route. They are also useful for non-resident owners of Dubai property, such as buyers covered in our guide to buying property in Dubai as a foreigner.
How they compare with onshore wills
Compared with a notarised onshore will or an Abu Dhabi Judicial Department will, DIFC wills for non-Muslims offer English-language drafting from start to finish, standard forms tested over many years, and a probate registry used to dealing with executors, trusts and guardians. The trade-offs are cost, the limit on guardianship to children resident in Dubai or Ras Al Khaimah, and the extra step of converting the DIFC grant for execution through the Dubai Courts. For a single property owned by a non-resident, a Property Will is often the most efficient choice; for families with children and mixed assets, a Full Will usually is.
They are not available to Muslims, and residents of Abu Dhabi or other emirates should compare the onshore options. Where heirs dispute a will, see inheritance and private client disputes.
- List your UAE assets and decide whether a Full Will or a targeted template fits.
- Choose executors, interim and permanent guardians, and two independent witnesses.
- Coordinate the DIFC will with any home-country will so neither revokes the other.
- Book a registration appointment and keep the registered copy accessible to your executors.
- Review the will after major life events and whenever you buy or sell significant assets.
TRW & Co advises on DIFC wills for non-Muslims as part of our wills and succession work, including drafting strategy, cross-border coordination and estate administration. Registration of the will itself takes place before the DIFC Courts Wills Registry, and where representation before the DIFC Courts is required we work alongside registered practitioners. To start, contact our Dubai team or email info@trw.co.
Frequently asked questions
01Who can register a DIFC will?
Non-Muslim individuals over the age of majority, which the DIFC Wills and Probate Registry Rules set at 21. The standard forms require the testator to declare that they are not, and have never been, a Muslim. Residents and non-residents with UAE assets can use the service. Muslims cannot, and should consider onshore registration routes and lifetime planning instead.
02How much does a DIFC will cost?
The DIFC Courts publish fixed registration fees: AED 10,000 for a single Full Will and AED 15,000 for mirror Full Wills; AED 7,500 for a Property Will (AED 10,000 for a mirror pair); and AED 5,000 for Financial Assets, Business Owners, Digital Assets and Guardianship Wills (AED 7,500 for a mirror pair). Drafting fees are additional, and fees can change.
03Does a DIFC will cover property outside Dubai?
The standard forms cover property in the UAE, so a DIFC will can deal with assets across the emirates. The Full Will also allows a wider geographical scope, but the DIFC Courts recommend independent advice on enforceability abroad. For assets outside the UAE, a separate local will is usually more reliable.
04Can I register a DIFC will without visiting Dubai?
Yes. Registration appointments can be held by video conference, with the testator and two witnesses joining from anywhere, and the will is signed electronically. The Rules allow witnesses to be physically or virtually present before the Registrar or an authorised officer. Make sure witnesses have valid identification and are available at the booked time.
05Can a DIFC will appoint guardians for my children?
Yes, for minors who habitually reside with the testator in Dubai or Ras Al Khaimah. You can appoint interim guardians to care for children immediately and permanent guardians for the longer term, either in a Guardianship Will or within a Full Will. Guardians must undertake to act under the Rules and submit to the DIFC Courts' jurisdiction.
06What happens to my DIFC will if I convert to Islam?
The Rules state that if the testator becomes a Muslim after registration, they no longer apply to the will, and the estate is administered according to the applicable laws of the place where it is situated. Islamic succession rules would then govern the estate. Anyone whose circumstances change should take advice and review their planning.
Sources and official materials
- DIFC Courts Wills Service — Overview of the service, its legal basis and the will types
- DIFC Courts: Full Will — Scope, guardianship options and fees for a Full Will
- DIFC Courts: Guardianship Will — Interim and permanent guardianship appointments
- DIFC Courts Wills: Rules and Directions — DIFC Wills and Probate Registry Rules and practice directions
- DIFC Courts: Probate — Grant of probate and conversion through the Dubai Courts
- DIFC Courts: Digital Assets Will — Digital assets will and non-custodial wallet
General information only, current as at 27 October 2026. It is not legal advice and does not create a lawyer–client relationship. UAE law differs between the onshore jurisdiction, the DIFC, ADGM and the free zones, and changes frequently; check current official sources and take advice on the facts of your matter.
