Do you need a DIFC or ADGM will if you already have a UK will?

The question that usually comes too late

The conversation tends to start the same way. A family has moved to Dubai, bought a villa, opened accounts, perhaps set up a company, and somewhere in a drawer in London there is a perfectly good English will. The assumption is that the will travels with them. It does not, or at least not cleanly, and the gap only shows itself at the worst possible moment, when someone has died and the bank has frozen the account.

I would rather have that conversation over a coffee than over a probate file. The short answer to the question in the title is that most UK-connected families with UAE assets need a UAE will as well as a UK one, and that the choice between the DIFC, the ADGM and the Abu Dhabi courts is a practical decision about where the assets and the children are, not a matter of prestige. The longer answer, and the part that is most often misunderstood, is that neither will changes what the UK taxes.

This note sets out why a UK will is not enough for UAE assets, how the main registration routes compare, the guardianship trap, what a UAE will does not do, and how the two wills should be made to work together.

Why a UK will is not enough for UAE assets

Two pieces of UAE law decide the point, and one of them is new.

The first is the conflict-of-laws rule. Federal Decree-Law No. 25 of 2025, the new Civil Transactions Law, replaced the 1985 code with effect from 1 June 2026. Under Article 17, succession is generally governed by the law of the country to which the deceased belonged at death, but UAE law applies to a foreigner's will concerning immovable property located in the UAE. For a British family that owns a Dubai flat, that means the flat is not simply passed under English law because the owner was English. UAE law has the final say over UAE land.

The second is the default. Federal Decree-Law No. 41 of 2022 on Civil Personal Status, in force since 1 February 2023, with its implementing rules in Cabinet Decision No. 122 of 2023, gives non-Muslims a civil framework for marriage, divorce, custody, wills and inheritance in place of the Sharia-based default that used to apply. Where a non-Muslim dies without a will the framework recognises, the UAE estate is shared half to the surviving spouse and half equally between the children, without any distinction between sons and daughters. If there are no children, it passes to the parents, then to siblings. The same federal framework requires a testator making a civil will under it to be at least 21.

That default is fair in the abstract and wrong for a great many real families. It ignores an unmarried partner entirely. It does not know about the discretionary trust the English will set up for the children. It gives a teenage child an outright share of a property the surviving parent needs to live in. A family whose plan was "everything to my wife, then to the children" finds the UAE assets split down the middle.

A UK will is not ignored. It can be relied on before a UAE court, but it has to be translated into Arabic, legally attested, and proved under the applicable conflict rules, and for UAE real estate it now sits beneath Article 17. In practice that means delay at exactly the point the family needs access to money, which is why the better answer is a will registered in the UAE for the UAE assets.

The routes side by side

There is no single UAE will. There are several registration and notarisation routes with different legal bases and different post-death procedures. The table sets the main ones against each other.

Two points from the table do most of the work. The DIFC route suits the typical British family in Dubai, because it reads like the will they already know and carries its own probate. The Abu Dhabi routes matter the moment the children live in Abu Dhabi, because the DIFC cannot appoint their guardian.

The DIFC Courts Wills Service

The DIFC Courts Wills Service is the route most British families in Dubai end up using, and for good reason. The will is drafted in English on common-law principles, it gives the testator real freedom over who inherits, and on death the DIFC Courts run the probate rather than leaving the estate to an unfamiliar onshore process. It operates under the DIFC Wills and Probate Registry Rules, within the framework Dubai set for non-Muslim wills in Dubai Law No. 15 of 2017. Eligible non-Muslims can register from the age of 18.

The current DIFC Courts fee schedule lists six types of will, and the choice turns on what the family owns.

• Full Will. The broadest option, covering movable and immovable assets and able to include guardianship. It can include assets outside the UAE, although whether a foreign court recognises it is a matter for that country's law.
• Property Will. For shares in up to five UAE properties.
• Business Owners Will. For shares in up to five UAE companies.
• Financial Assets Will. For up to ten UAE bank or brokerage accounts.
• Digital Assets Will. For digital assets, a category in its own right rather than a footnote to the others.
• Guardianship Will. Appointing guardians for children under 18.

The registration fees are modest against the assets they protect. A Full Will costs AED 10,000 for a single will or AED 15,000 for mirror wills for a couple. A Property Will costs AED 7,500 single or AED 10,000 mirror. The Guardianship, Business Owners, Financial Assets and Digital Assets Wills cost AED 5,000 single or AED 7,500 mirror, and a later modification carries a small service fee. Drafting is charged separately and varies with the complexity of the estate. The DIFC Courts publish the schedule, and it is worth checking before signing, because it changes.

The will must be signed in front of two adult witnesses who are not beneficiaries. Mirror wills, two substantially identical wills for a couple leaving everything to each other and then to the children, are the most common registration.

Abu Dhabi, the ADJD and the ADGM Courts Wills Office

Abu Dhabi got there first. Abu Dhabi Law No. 14 of 2021 created a civil family framework for non-Muslims in November 2021, a year before the federal law, and the Abu Dhabi Judicial Department runs a dedicated Civil Family Court for non-Muslims. Civil wills are registered with the ADJD, with templates in Arabic and English and registration available remotely. The volumes show how quickly expatriate families have adopted it: the ADJD recorded 4,566 civil wills in the first quarter of 2026 alone, within 8,886 civil marriage and will transactions.

The ADGM route is often confused with the DIFC one, and it is not the same thing. The ADGM Courts Wills Office, through the ADGM Courts Notary Public, is authorised by the ADJD to notarise non-Muslim wills. It can notarise a will dealing with the estate, with guardianship of minor children, or both, covering assets inside or outside the UAE, and its guidance sets a minimum age of 21. What it does not do is probate. When the testator dies, the probate application goes to the ADJD's Wills and Probate Office, not to the ADGM Courts.

For a family living in Abu Dhabi, or holding property there, these routes are usually simpler than forcing the estate through the DIFC. For guardianship of children who live in Abu Dhabi, they are the right answer, because the DIFC cannot do it.

Dubai Courts and simpler estates

Dubai Courts keep a register of non-Muslim wills under Dubai Law No. 15 of 2017 and deal with non-Muslim estates onshore. For a Dubai resident with a straightforward estate, no strong attachment to English-style drafting and a tighter budget, this can be a sensible route. For the cross-border family with assets in several countries, a company, and children who may later move, the DIFC route tends to be the better fit, which is why most corridor families end up there.

What a UAE will does not do

A UAE will answers one question well: who receives the UAE assets, and who is in charge of getting them there. It does not answer the questions that usually carry the larger number.

It does not remove UK inheritance tax. Since 6 April 2025 the UK taxes the worldwide estate of a long-term resident, broadly someone UK resident for at least 10 of the previous 20 tax years, under section 6A of the Inheritance Tax Act 1984. That exposure does not end on the day of departure. It runs on for between three and ten tax years depending on how long the person was resident, the tail set out in the note on the long-term resident IHT tail. A villa in Dubai is foreign property, and for a long-term resident that no longer keeps it outside the charge, as the note on UK inheritance tax on Dubai property explains.

It does not keep pensions out. From 6 April 2027 unused pension funds and death benefits come within the UK inheritance tax estate. A family that has carefully registered a DIFC will can still find a UK pension pot taxed at 40% on death, the change examined in the note on UK pensions and inheritance tax from 2027.

It does not decide residence. Registering a will in Dubai is not evidence of leaving the UK. UK residence turns on the Statutory Residence Test in Schedule 45 of the Finance Act 2013, and UAE tax residence on Cabinet Decision No. 85 of 2022, each on its own facts.

It does not replace a UK will for UK assets. A UK bank, a UK pension provider and HM Land Registry will want an English grant of probate before they release anything. A foreign will can be admitted, because the Wills Act 1963 accepts a will executed under the law of the place it was signed, or of the testator's domicile, habitual residence or nationality. For someone who died domiciled abroad, though, the grant is obtained under rule 30 of the Non-Contentious Probate Rules 1987, which adds steps and time. One nuance catches people out here. Finance Act 2025 removed domicile from UK tax, but domicile still governs English succession law, so a family can be outside the old non-dom rules for tax and still have a domicile question for probate.

It does not change a trust. If the principal settled a trust, the settlor and beneficiary charges run at the UK tax level whatever the will says, as set out in the note on protected settlements after April 2025.

It does nothing while the principal is alive. A will speaks on death. If the principal loses capacity, an ordinary UAE power of attorney falls away, and the family is left without authority over the assets while everyone is still alive. That gap is dealt with separately, in the note on incapacity planning across the corridor.

Five traps worth avoiding

One will for everything. A Full Will registered in the DIFC can reach assets abroad, but that does not make it the right instrument for a London flat and a UK pension. The cleaner design is two coordinated wills, a UAE will for UAE assets and a UK will for UK assets, each with a clear statement of what it covers.

Revoking the other will by accident. Most standard wills open by revoking all earlier wills. A Dubai will signed with that clause can wipe out the English one, or the reverse. Each will needs revocation language limited to its own assets and jurisdiction.

Guardianship in the wrong emirate. A DIFC guardianship provision only works for children living in Dubai or Ras Al Khaimah. A family that registered in the DIFC and later moved to Abu Dhabi has a will that still distributes the assets but no longer appoints the guardian. The fix is an Abu Dhabi registration for the guardianship, and a review every time the family moves.

Relying on the default. A family that assumes English law will apply simply because they are English meets the federal default instead: half to the spouse, half to the children. Unmarried partners, step-children and adult children who need protection are the people that default treats worst.

Treating the will as tax planning. The will is an administration tool. It routes the assets and appoints the people. The UK inheritance tax position, the pension position from April 2027 and any trust charges have to be planned separately, and usually in the same exercise.

Making the two wills work together

The sequence that works in practice is short. List every asset by country, including pensions, company shares and digital assets. Decide which will governs which assets and say so in each document. Choose the UAE route by where the family lives and holds property, with guardianship registered in the right emirate. Draft the UK will to cover UK assets only and to leave the UAE will intact. Then put the inheritance tax position beside both, because that is where the larger number sits.

Where the family's wealth is moving to the next generation through structures rather than outright gifts, the will sits underneath a wider decision about trusts, companies and foundations, set out in the notes on passing wealth to the next generation and on choosing between a foundation, a family investment company and a UK trust. For a family still planning the move, the will belongs in the documentation phase of the pre-exit year, not in the weeks after arrival.

Frequently asked questions

Is my UK will valid in Dubai?

It can be relied on, but not cleanly. A UK will has to be translated into Arabic, legally attested and proved before a UAE court, and since 1 June 2026 Article 17 of Federal Decree-Law No. 25 of 2025 applies UAE law to a foreigner's will over UAE real estate. In practice that means delay and uncertainty when the family most needs access to the assets. A will registered in the UAE for the UAE assets, alongside the UK will for UK assets, is the more reliable design.

What happens if a non-Muslim dies in the UAE without a will?

The UAE estate follows the civil default in Federal Decree-Law No. 41 of 2022. Half goes to the surviving spouse and half is shared equally between the children, with no distinction between sons and daughters. If there are no children, it passes to the parents and then to siblings. The default applies to UAE assets; assets abroad follow the law of the country where they sit. It often produces a different result from the family's UK estate plan, especially for unmarried partners and blended families.

What is the difference between a DIFC will and an ADGM will?

A DIFC will is registered through the DIFC Courts Wills Service, drafted in English on common-law principles, available from age 18, and probated by the DIFC Courts. An ADGM will is notarised by the ADGM Courts Wills Office under authority from the Abu Dhabi Judicial Department, available from age 21, and probated through the ADJD's Wills and Probate Office, because the ADGM Courts do not provide probate. The DIFC route usually suits Dubai-based families; the Abu Dhabi routes suit families living or holding property in Abu Dhabi.

How much does a DIFC will cost in 2026?

The DIFC Courts registration fee for a Full Will is AED 10,000 for a single will or AED 15,000 for mirror wills for a couple. A Property Will costs AED 7,500 single or AED 10,000 mirror. Guardianship, Business Owners, Financial Assets and Digital Assets Wills cost AED 5,000 single or AED 7,500 mirror. Legal drafting is charged separately and depends on the complexity of the estate. The schedule changes, so it should be checked with the DIFC Courts before registering.

Can a DIFC will appoint a guardian for children in Abu Dhabi?

No. Guardianship provisions in a DIFC will apply only to children living in Dubai or Ras Al Khaimah. For children living in Abu Dhabi, guardianship should be dealt with through the Abu Dhabi Judicial Department or the ADGM Courts Wills Office. A family that registered in the DIFC and later moved to Abu Dhabi should review the will, because the asset provisions may still work while the guardianship appointment no longer does.

Do I need both a UAE will and a UK will?

For most UK-connected families with assets in both countries, yes. UK banks, pension providers and HM Land Registry expect an English grant of probate, and a UK will makes that straightforward for UK assets, while a UAE-registered will deals with UAE assets under UAE rules. The two must be drafted together, each limited to its own assets, so that neither revokes the other by accident.

Does a UAE will protect my estate from UK inheritance tax?

No. A UAE will decides who inherits; it does not change what the UK taxes. A long-term UK resident, broadly someone resident for 10 of the previous 20 tax years, remains within UK inheritance tax on the worldwide estate under section 6A of the Inheritance Tax Act 1984, and that exposure continues for three to ten tax years after leaving. From 6 April 2027 unused pension funds are also brought into the estate. The tax position has to be planned separately from the will.

When should a family moving to the UAE make its UAE will?

Before or shortly after the first UAE asset is bought, and ideally as part of the move itself rather than months later. Property is usually the asset that makes it urgent, because it is the one UAE law governs most directly, and children arriving in the UAE need their guardianship settled from the start. The will should then be reviewed after any marriage, divorce, birth, property purchase, business change or move between emirates.

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A UAE will is one of the cheapest and most useful pieces of planning a family in the corridor can do, and one of the most frequently left undone. It settles who inherits the villa and who looks after the children. It does not settle the UK tax bill, and the families who do well are the ones who deal with both at the same sitting.