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DIFC vs ADJD vs Dubai Courts Will: Which Is Right for Expats in the UAE?

DIFC vs ADJD vs Dubai Courts Will: Which Is Right for Expats in the UAE
DIFC vs ADJD vs Dubai Courts Will: Which Is Right for Expats in the UAE

By Thasmiya

For expats living in the UAE, making a will can be one of the most important parts of protecting property, savings, businesses and family interests.

But there is an immediate question: **where should you register it?**

Three routes commonly considered are the **DIFC Courts Wills Service**, the **Abu Dhabi Judicial Department (ADJD) Civil Wills Office**, and **Dubai Courts**. They are not interchangeable products with identical rules, fees or procedures, so the right choice depends on your religion, assets, location, family circumstances and the legal framework you want to use.

Here is a practical comparison for UAE expats in 2026.

## **Why expats in the UAE should consider making a will**

A registered will allows you to formally record how you want eligible assets handled after your death and, depending on the route used, make provisions concerning beneficiaries, executors and guardianship.

Without appropriate estate planning, distributing an estate can become more complicated and may involve court procedures that the family was not expecting.

This becomes particularly important for expats who own UAE property, operate a business, maintain significant bank or investment accounts, or have minor children.

## **Option 1: DIFC Courts Wills Service**

The ⁠DIFC Courts Wills Service is a specialised wills framework established for non-Muslims investing or living in the UAE.

DIFC says the service allows non-Muslims to pass on assets and/or appoint guardians for their children according to the instructions contained in their registered will.

### **What can a DIFC Will cover?**

DIFC offers several different will types rather than one standard product.

A **Full Will** can cover movable and immovable assets and is the broadest option. DIFC also offers specialised Property, Financial Assets, Business Owners, Guardianship and Digital Assets Wills.

For example, a Property Will can cover shares in up to five UAE properties, while a Financial Assets Will can cover up to 10 eligible UAE bank or brokerage accounts.

### **How much does a DIFC Will cost?**

Current DIFC registration fees are:

**Full Will:** AED 10,000 for a single will or AED 15,000 for Mirror Wills.

**Property Will:** AED 7,500 single or AED 10,000 mirror.

**Guardianship Will:** AED 5,000 single or AED 7,500 mirror.

**Business Owners Will:** AED 5,000 single or AED 7,500 mirror.

**Financial Assets Will:** AED 5,000 single or AED 7,500 mirror.

**Digital Assets Will:** AED 5,000 single or AED 7,500 mirror.

Mirror Wills apply where a married couple registers their wills together. Legal drafting or advisory fees, where used, are separate from the registration fee.

### **Who is DIFC best suited to?**

DIFC can be particularly attractive to **non-Muslim expats with substantial or more complex UAE estates**, including property, businesses, investments or multiple asset categories.

It may also appeal to people who specifically prefer the established DIFC Courts wills and probate framework.

The trade-off is cost: DIFC registration can be significantly more expensive than the ADJD route.

## **Option 2: Abu Dhabi Judicial Department Will**

The ⁠Abu Dhabi Civil Family Court provides a Civil Wills service through the Abu Dhabi Judicial Department.

One particularly important point is eligibility.

ADJD currently states that **a person who is not a UAE citizen may register a will regardless of religion**. That makes the Abu Dhabi option notably broader in this respect than the DIFC Wills Service, which is specifically designed for non-Muslims.

### **Do you need to live in Abu Dhabi?**

The ADJD framework should not automatically be dismissed simply because you live in Dubai or another emirate.

The Civil Wills Office provides a formal UAE will-registration route, and ADJD states that the process can be initiated online. Applicants submit the request, the authority reviews it, fees are paid, and an appointment is booked to probate/authenticate the will by video conference.

### **Can an ADJD Will include assets outside the UAE?**

ADJD’s official FAQ says it is possible to bequeath **funds and property located outside the UAE** through the will-registration service.

For expats with assets in several countries, however, cross-border succession can become complicated. A UAE will should not automatically be assumed to replace estate planning required in another jurisdiction.

### **How much does an ADJD Will cost?**

This is where the difference becomes significant.

ADJD currently lists **AED 950 for registering a regular will** and **AED 2,500 for registering a special will**.

That makes the basic ADJD registration fee considerably lower than the AED 10,000 registration fee for a DIFC Full Will.

Legal drafting, translation, attestation or professional-advice costs may still apply depending on the circumstances.

### **Who is ADJD best suited to?**

ADJD can be attractive to expats looking for a **lower-cost court-registered will**, including those who want the flexibility provided by Abu Dhabi’s Civil Wills framework.

Its eligibility for non-UAE citizens regardless of religion is another important distinction.

## **Option 3: Dubai Courts Will**

⁠Dubai Courts provides another route within Dubai’s judicial system.

Dubai Courts confirms that its Personal Status Court deals with both Muslim and non-Muslim personal-status and estate matters. Its jurisdiction includes statements concerning wills, determination of heirs, registration of estate files and related inheritance matters.

Dubai Courts has also specifically stated that wills can be registered through **Dubai Courts’ notary public**, in addition to the DIFC Courts route.

### **How is Dubai Courts different from DIFC?**

Although both are in Dubai, they should not be treated as the same will-registration system.

DIFC Courts operates its own specialised Wills Service with specific will products and published registration fees.

Dubai Courts operates through Dubai’s local judicial and notarial framework and handles broader personal-status, inheritance and estate matters.

That difference in legal framework and procedure is one of the main reasons expats should not choose between the two based on price alone.

### **What about foreign law?**

Dubai Courts has explained that non-Muslims may request application of a foreign law in relevant inheritance circumstances, subject to legal requirements and supporting documentation.

However, the treatment of UAE real estate and situations where foreign rules conflict with UAE principles can introduce additional considerations.

This is one area where professional legal advice may be particularly valuable rather than assuming that a will drafted overseas will automatically produce the same result in the UAE.

## **DIFC vs ADJD vs Dubai Courts: the simple comparison**

**Choose DIFC Courts if:** you are a non-Muslim expat who wants a specialised wills framework, particularly if you have a substantial or complex UAE estate and are comfortable with the higher registration cost.

**Consider ADJD if:** affordability is important, you want a UAE court-registered civil will, or DIFC’s non-Muslim eligibility does not fit your circumstances. ADJD expressly says non-UAE citizens can register regardless of religion.

**Consider Dubai Courts if:** you want to use Dubai’s local judicial/notarial framework, particularly where your estate planning is closely connected to Dubai and you are comfortable working within its personal-status and inheritance procedures.

## **What if you own property in Dubai?**

Owning Dubai property does not automatically mean that a DIFC Full Will is your only option.

DIFC does, however, offer a dedicated Property Will covering shares in up to five UAE real-estate properties, currently priced at AED 7,500 for a single registration.

If you own property alongside bank accounts, company shares and other assets, compare a specialised Property Will against a broader Full Will and the alternatives available through ADJD or Dubai Courts.

The correct structure can depend on ownership arrangements, mortgages, joint ownership, beneficiaries and assets held outside the UAE.

## **What about parents with children under 18?**

Guardianship should be considered separately from simply deciding who receives your money or property.

DIFC has a dedicated **Guardianship Will**, currently costing AED 5,000 for a single will and AED 7,500 for Mirror Wills. It covers guardianship provisions for minors below 18.

Parents considering any of the three routes should confirm how guardianship instructions will operate in their particular circumstances rather than assuming an asset-only will automatically addresses everything concerning their children.

## **What about married couples?**

DIFC offers discounted Mirror Wills for married couples registering two wills simultaneously.

For example, two Full Wills registered as Mirror Wills currently cost AED 15,000 rather than AED 20,000 if two individual Full Wills were registered separately.

Couples should still consider whether their assets and intended beneficiaries actually justify mirrored provisions. One spouse may have assets, children or inheritance wishes that differ from the other’s.

## **Do you need a lawyer?**

Not necessarily for every registration process, but professional advice can be valuable.

DIFC explicitly allows someone who has prepared their own will to proceed without appointing a draftsman, while strongly recommending that testators consider legal advice because the document must satisfy its registration requirements.

The more complicated your circumstances become—multiple properties, business ownership, children from previous relationships, overseas assets or different nationalities among beneficiaries—the stronger the case for getting qualified UAE succession advice.

## **Don’t compare registration fees alone**

A AED 950 registration fee and a AED 10,000 registration fee do not necessarily represent identical services.

When comparing your options, consider what assets the will covers, applicable legal framework, eligibility, guardianship needs, probate and enforcement process, amendment requirements, translation requirements and professional drafting costs.

For example, DIFC currently charges AED 550 to modify a registered will.

## **So which UAE Will is best for an expat?**

There is no single option that is automatically best for every expat.

For a non-Muslim Dubai resident with significant property, businesses and financial assets, the specialised DIFC framework may justify its higher cost.

For someone looking for a considerably lower registration fee, ADJD deserves serious consideration, particularly because its Civil Wills Office states that non-UAE citizens may register regardless of religion.

Dubai Courts remains another important option for those who want their estate planning handled within Dubai’s local judicial framework.

Before registering, list your UAE and overseas assets, identify your intended beneficiaries and executors, consider guardianship if you have minor children, and then compare what each registration route actually covers.

## **Why this matters**

A UAE will is not simply paperwork for wealthy property owners.

For expats, it can form an important part of deciding what happens to property, savings, investments, businesses and family interests after death.

The key is not choosing the cheapest or most familiar name. It is choosing the legal route that fits your assets, family circumstances and succession objectives.

For complex estates or cross-border assets, obtaining advice from a UAE-qualified succession lawyer before registration can help prevent expensive problems later.

*This article provides general information and is not legal advice. Will, inheritance and succession outcomes depend on individual circumstances and applicable law.*

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