# Inheritance in the UAE: Sharia defaults, DIFC Wills and ADJD > What happens to UAE assets on the owner’s death: frozen accounts, Sharia and Decree-Law 41/2022 defaults, DIFC Wills (AED 10,000) vs ADJD (AED 950), probate, guardianship of minors and how the UAE fits a multi-jurisdiction estate plan. Author: Maria Plotnikova — Lawyer, Family Office (https://wiki.private.law/en/authors/plotnikova) Last modified: 2026-08-14T13:16:00.000Z Canonical: https://wiki.private.law/en/uae-inheritance-difc-wills Topics: structures Jurisdictions: uae Product tags: estate-planning, wealth-planning Semantic tags: estate-planning, wealth-planning --- A typical client family in the UAE holds a whole perimeter: an account with [Emirates NBD](https://wiki.private.law/en/emirates-nbd), an apartment in Dubai Marina, a stake in a free-zone company. What happens to that perimeter when the owner dies is usually something nobody in the family knows — and the default answer is unpleasant: the bank freezes the accounts, joint ones included, and distribution goes to court under rules the family did not expect. # What happens without a will The first and most painful issue is liquidity. On learning of a client’s death, a UAE bank blocks the accounts until a court succession order; a joint spousal account is no exception, and powers of attorney die with the principal. A family living off a Dubai account is left without access to money for months. Then comes the substantive law. For Muslims, Sharia distribution in fixed shares applies. For non-Muslims, since 1 February 2023 [Federal Decree-Law 41/2022 on Civil Personal Status](https://uaelegislation.gov.ae/en/legislations/1586) governs: with no will, half of the estate goes to the surviving spouse and the other half to the children equally, regardless of gender; with no children — to parents and siblings. A foreigner may instead elect the law of their citizenship. That sounds tolerable, but procedure eats the entire gain: an intestacy case runs through court with translation and legalisation of every document — certificates, apostilles, proof of kinship. Minor children are a separate story: [guardianship is decided by the court](https://wiki.private.law/en/minor-heirs-guardianship), and the court’s view of a suitable guardian may not match the family’s plans. > 🍓 The substantive defaults for non-Muslims have been civilised since 2023: half to the spouse, the rest equally to the children \(Decree-Law 41/2022\). Procedurally, intestacy still means frozen accounts, court, document legalisation and months without liquidity. # Three ways to put your wishes on record A non-Muslim resident has three routes. First — a DIFC Will: an English-language common-law will registered with the DIFC Courts. Second — [an ADJD will](https://www.adjd.gov.ae/en/Pages/CivilFamilyCourt.aspx) \(Abu Dhabi Judicial Department\): a bilingual English-Arabic document at AED 950 \(AED 1,900 for a mirror pair\), valid across all seven emirates. Third — a notarised will in the local courts, in Arabic. All three displace the defaults and fix your own distribution. # DIFC Wills: how it works The Wills Service at the DIFC Courts is a registry for non-Muslims over 21. The design is modular, with five types: Full Will \(all UAE assets\), Property Will \(real estate only\), Business Owners Will \(company shares\), Digital Assets Will \(crypto — with a non-custodial wallet secured on the Hedera blockchain\) and Guardianship Will \(appointment of guardians for minor children only\). [Registering a single Full Will costs AED 10,000](https://www.difccourts.ae/about/fees) — a flat fee regardless of asset value; amendments are AED 550. Since 2019 a DIFC will may cover assets in all emirates and, with advice, worldwide. Dubai Law No. 2 of 2025 gave the DIFC Courts exclusive jurisdiction over non-Muslim wills: probate orders are issued by the DIFC Courts and executed by banks and the Dubai Land Department directly, without a duplicate process in the local courts. > 🍓 The DIFC Will is the premium route: AED 10,000, English language, common-law probate with direct enforcement. ADJD is the economical one: AED 950, a bilingual document, all seven emirates. The choice turns on the asset mix and the language the family is prepared to live in during the procedure. # Matching the will to the assets Real estate: the probate order is executed at the DLD; if the only UAE asset is an apartment, a Property Will suffices. Bank accounts: the bank unfreezes them against the grant of probate — name the banks in the will. Company stakes: Business Owners Will works for mainland and free zones, while for [ADGM and DIFC structures](https://wiki.private.law/en/uae-fund-manager-adgm-difc) a foundation is the alternative to a will — a foundation does not die with its founder. Crypto: the Digital Assets Will addresses the [private-key succession problem](https://wiki.private.law/en/crypto-inheritance). Minors: a Guardianship Will fixes the guardian — without it the question goes to court. # Fitting the UAE into the wider estate plan The UAE is not part of Brussels IV, so a European [choice of applicable law](https://wiki.private.law/en/succession-applicable-law) does not reach here: real estate follows lex rei sitae and procedure follows the local courts. A home-country will can formally be recognised, but translation, legalisation and time make it a poor key to a Dubai bank. The working scheme is [parallel wills](https://wiki.private.law/en/multi-jurisdiction-wills): a local one \(DIFC or ADJD\) for UAE assets, coordinated with the wills of other jurisdictions so that a later will does not revoke the earlier ones. [The UAE has no inheritance tax](https://wiki.private.law/en/inheritance-tax-map), but the heirs’ tax treatment is set by their own jurisdictions, and US or UK assets in the portfolio carry [their own exposure](https://wiki.private.law/en/us-estate-tax) regardless of the Emirati will. The full toolkit is in [succession planning](https://wiki.private.law/en/succession-planning); asset-specific pieces — [accounts](https://wiki.private.law/en/foreign-accounts-succession) and [real estate](https://wiki.private.law/en/foreign-real-estate-succession). > 🍓 The rule is simple: UAE assets need a local will \(DIFC or ADJD\) coordinated with the others, plus a guardianship block where there are minors. Without it, even a perfect estate plan from other jurisdictions will not reach a Dubai bank. This material is for general information and is not individual legal advice. --- ## Factual claims - Then comes the substantive law. - The Wills Service at the DIFC Courts is a registry for non-Muslims over 21. - Registering a single Full Will costs AED 10,000 — a flat fee regardless of asset value; amendments are AED 550. - The UAE is not part of Brussels IV, so a European choice of applicable law does not reach here: real estate follows lex rei sitae and procedure follows the local courts.