Prenup: France + UAE

France: The contrat de mariage is signed before a notary pre-wedding; a mid-marriage regime change also runs through a notary with no waiting period (Art. 1397 Civil Code as amended in 2019): adult children and creditors are notified, the court steps in only on objection. UAE: Under the civil regime for non-Muslims the agreement attaches to marriage registration (Art. 6 of Federal Decree-Law 41/2022; in Abu Dhabi — Emirate Law 14/2021); for Muslims the personal-status framework and mahr apply. Several legal systems are involved — one document will not cover them all. The working construction: an anchor contract in the principal jurisdiction plus mirror texts where the key assets sit, backed by local counsel opinions.

In the EU, fix the choice of law inside the contract (Regulation 2016/1103): the law of either spouse’s citizenship or habitual residence. Without a choice, the regime follows the first common residence — and migrates with you unpredictably. France: under Rome III you can also pre-select the law applicable to the divorce itself — it belongs in the same package.

France: Regime election (séparation de biens, communauté universelle, etc.) and clause tailoring; maintenance and the prestation compensatoire are only weakly contractable. UAE: Property and the financial terms of the marriage; maintenance arrangements remain subject to court control.

Full asset disclosure annexed to the contract — the main anchor against future challenge. Independent counsel for each side; one adviser for both is the classic line of attack. Translations and legalisation: every version with a notarised translation and apostille for its jurisdiction of use.

France: A mid-marriage regime change is a well-oiled notarial procedure — the standard entrepreneur move. UAE: The civil regime does not expressly provide for postnups — their status is uncertain; that is exactly why the anchor contract is made in an established jurisdiction.