UAE Inheritance Law for Expats

A practical English-language guide for American and other non-Muslim residents who own assets, run companies or have minor children in the United Arab Emirates.

1. The Default Rule

Historically, UAE courts applied Sharia inheritance rules to the estate of any person who died in the country, including non-Muslims, unless a valid election was made. Federal Decree-Law No. 41 of 2022 on Civil Personal Status now allows non-Muslims to be governed by the law of their nationality for personal status matters, including inheritance, and recognises wills registered in the UAE for non-Muslims.

2. Why a UAE-Registered Will Still Matters

Even with the new framework, a UAE-registered will is strongly recommended because:

• It avoids the time, cost and uncertainty of proving foreign law and a foreign will in UAE courts.
• It allows you to nominate a guardian for minor children resident in the UAE.
• It speeds up the unfreezing of UAE bank accounts (which are normally frozen on death).
• It clarifies how UAE real estate, shares in UAE companies and end-of-service gratuity are distributed.

3. Where to Register the Will

• DIFC Wills Service Centre — Dubai International Financial Centre, English-language common-law framework, covers assets across the UAE and Ras Al Khaimah for non-Muslims.
• Abu Dhabi Judicial Department (ADJD) Non-Muslim Wills Register — bilingual registration of wills for non-Muslims with assets in Abu Dhabi.
• Dubai Courts Notary Public — alternative registration for wills covering Dubai assets.

4. Will Templates Commonly Used

• Full Will — all UAE assets and guardianship.
• Guardianship Will — only nominates guardians for minor children.
• Property Will — covers a specific UAE property.
• Business Owners Will — passes shares in UAE entities.
• Financial Assets Will — UAE bank and brokerage accounts.

5. What to Bring to a Drafting Session

• Passports and Emirates IDs of testator, executors and beneficiaries.
• Title deeds for UAE property.
• Trade licenses and share certificates for UAE companies.
• List of UAE bank and investment accounts.
• Existing foreign will (US trust, pour-over will, etc.) — we coordinate so the two do not conflict.

6. Coordinating with US Estate Planning

US persons should not rely solely on a UAE will for worldwide assets. A UAE will typically governs only UAE-situs assets and should be drafted to dovetail with — not replace — your US revocable trust or pour-over will. US federal estate tax may still apply to your worldwide estate.