ADJD vs DIFC Wills in UAE: Which Jurisdiction Is Right for You? (2026 Guide)
If you live or hold assets in the UAE, choosing the right jurisdiction for your will is one of the most important decisions you can make. Until recent reforms, UAE Federal Law applied Sharia principles to non-Muslim inheritance, often leading to unintended outcomes for expats.
Now, with Law No. 41/2024 for Abu Dhabi Judicial Department (ADJD) and Law No. 2/2025 for Dubai International Financial Centre (DIFC), non-Muslims can register civil wills that reflect their wishes.
The key choice is between ADJD (Abu Dhabi) and DIFC (Dubai). ADJD offers lower costs and UAE-wide recognition, while DIFC provides English common law for international portfolios.
ADJD vs DIFC Wills: Quick Comparison
| Feature | ADJD (Abu Dhabi) | DIFC (Dubai) |
|---|---|---|
| Eligibility | Non-Muslims and Muslims (civil option) | Non-Muslims only |
| Law Applied | UAE civil law | English common law |
| Assets Covered | All UAE emirates | UAE and worldwide |
| Cost | AED 750+ (lower) | AED 10,000+ (higher) |
| Language | Arabic or bilingual | English |
| Probate | Abu Dhabi Courts | DIFC Courts |
| Guardianship | Yes, for minors | Yes, with UAE court confirmation |
When to Choose ADJD Wills (Abu Dhabi)
ADJD wills are ideal if you live in Abu Dhabi or hold primarily UAE assets. They are more affordable (starting at AED 750) and recognised across all emirates, including Dubai. You can include guardianship for minors and specify non-Sharia distribution. Registration is straightforward via online booking or in person at the ADJD centre.
However, ADJD wills follow UAE civil law, which may not align perfectly with international common law preferences. They are best for simpler estates.
When to Choose DIFC Wills (Dubai)
DIFC wills suit Dubai residents or those with international assets. They apply English common law, making them familiar to expats from the UK, US, Australia, or Commonwealth countries. DIFC covers UAE and worldwide assets, which ADJD cannot. Costs start at AED 10,000 but reflect the international standard and faster probate.
DIFC is non-Muslim only and requires Dubai residency or assets. It is excellent for complex estates, trusts, or digital assets.
Step-by-Step: How to Register Your UAE Will
- Consult a lawyer: Choose an accredited DIFC or ADJD practitioner.
- Draft your will: Specify assets, beneficiaries, executors, and guardianship.
- Book and attend: Online for ADJD; video or in-person for DIFC.
- Sign and pay: Fees vary by estate value. Get your certificate.
Download: Free UAE Will Jurisdiction Checklist
This guide is available free in HTML now across all devices. You can also download the PDF checklist for offline reference.
Frequently Asked Questions
Can one will cover assets in Dubai and Abu Dhabi?
Yes. ADJD wills apply UAE-wide, while DIFC can cover UAE and international assets.
Do I need a lawyer?
Yes. Both typically require accredited drafting and witnessing.
What about digital assets like crypto?
DIFC can explicitly cover digital assets when they are clearly specified in the will.
Record your assets with Legacy Assured free and ensure executors know what exists across jurisdictions.