Estate Planning in the UAE

A complex legal landscape

Across the UAE, families from around the world have built lives and businesses that connect several jurisdictions at once. They own real estate in Dubai, maintain companies in free zones, hold accounts across continents and raise children who call more than one country home.

Yet when it comes to inheritance, the legal framework that governs these assets is often misunderstood. Many assume that their home-country wills will automatically apply in the Emirates.

In reality, the UAE follows a mixed system that combines civil law influenced by Sharia principles with common law frameworks operating within the Dubai International Financial Centre (DIFC) and the Abu Dhabi Global Market (ADGM). This unique legal landscape makes the UAE one of the most dynamic yet intricate jurisdictions for estate planning.

For Muslim families, succession follows the fixed-heirship principles of Sharia, which define specific shares for spouses, children and parents.

For non-Muslims, Federal Decree-Law No. 41 of 2022 allows the law of the deceased’s nationality to apply, although certain exceptions remain, particularly when UAE real estate is involved.

In fact, Non-Muslim residents may elect their home-country law for inheritance and wills under Federal Decree-Law 41/2022, but this election does not displace UAE law for UAE real estate.

The role of the DIFC and ADGM Wills Service

To bring clarity and choice to this environment, both the DIFC and the ADGM have established Wills Services based on English common-law principles.

A DIFC Will allows non-Muslim individuals to register their wishes with the DIFC Courts. It offers clear rules for asset distribution and the appointment of guardians for minor children. Probate is handled through the DIFC Courts, known for their efficiency and transparent process.

Similarly, the ADGM Wills Service in Abu Dhabi provides the same flexibility for families who prefer their arrangements to be governed under common-law principles. The ADGM framework is recognised internationally and allows testators to cover assets within the UAE and abroad.

Both jurisdictions give expatriate families the ability to plan according to their personal circumstances and avoid uncertainty in the administration of their estates.

A matter of foresight and respect

At WP Advisors, we guide families through this process with precision and respect for both legal and cultural contexts.

We work with Muslim and non-Muslim families alike, ensuring that each plan reflects their personal values, faith and long-term vision.

Some families prefer to plan within the principles of Sharia, while others opt for the flexibility of the DIFC or ADGM framework. What matters most is that each decision is informed and deliberate.

Estate planning is about foresight, continuity and the confidence that your intentions will be honoured.

If your life, assets or family are connected to the UAE, we invite you to speak with our team.

WP Advisors offers a confidential consultation to help you understand your options and identify the most suitable approach for your circumstances.

Protect today, so your legacy lives tomorrow.