DIFC vs ADJD vs Dubai Courts Wills: 2026 Expat Guide

For non-Muslim expats deciding between DIFC vs ADJD vs Dubai Courts wills in 2026, the short answer is this: choose DIFC for English-language common-law probate over Dubai or Ras Al Khaimah assets, choose ADJD for the lowest-cost federal coverage across all seven emirates with no witness logistics, and choose the Dubai Courts Notary if you want a Dubai-based civil-law route in Arabic or bilingual form. All three registries are valid under Federal Decree-Law No. 41 of 2022, which came into force on 1 February 2023 and gave non-Muslim residents full testamentary freedom over their UAE property.

The legal backdrop: Federal Decree-Law 41 of 2022

Before comparing registries, founders and SMB owners should understand what changed. Federal Decree-Law No. 41 of 2022 on Civil Personal Status came into force on 1 February 2023. Article 11(1) confirms the testator’s right to leave a will over their entire UAE property to anyone they choose, while Article 13(1) requires the will to be recorded in the designated register.

Importantly, Article 11(2) sets the default rule for intestacy. If a non-Muslim resident dies without a registered will, the estate splits 50% to the surviving spouse and 50% equally among the children, with no gender distinction. As a result, the law removed the old uncertainty around Sharia application, but it did not remove the need to register. Without a recorded will, your wishes are not enforceable in UAE courts.

Three registries currently serve non-Muslim expats: the DIFC Courts Wills Service, the Abu Dhabi Judicial Department (ADJD) non-Muslim wills register, and the Dubai Courts Notary. Each operates under a different legal logic, and the right pick depends on where your assets sit, what language you speak, and how much you want to pay. For a tailored review, our UAE Will Drafting Services map your assets, beneficiaries and guardianship needs to the correct registry before you file.

DIFC vs ADJD vs Dubai Courts wills: the side-by-side comparison

The table below summarises the practical differences founders ask about most often. Use it as a working shortlist, then read the section-by-section detail underneath.

Feature	DIFC Courts Wills Service	ADJD (Abu Dhabi Judicial Department)	Dubai Courts Notary
Legal framework	Common law (English-law based)	UAE civil law + FDL 41/2022	UAE civil law (Dubai Emirate)
Who can register	Non-Muslims only (never Muslim), 21+	Muslims and non-Muslims, 21+	Non-Muslims, 21+
Language	English only, no translation accepted	Bilingual English/Arabic	Arabic or bilingual; sworn translation required if originally English
Witnesses at registration	2 mandatory (21+, photo ID, not beneficiary/guardian/spouse)	Not required	Not required (notary acts as witness)
Asset coverage	Full Will: UAE + worldwide (foreign enforcement not guaranteed). Property/Business/Financial: UAE only	Assets anywhere in the UAE	Assets anywhere in the UAE
Government fee (single)	AED 10,000	AED 950	~AED 2,167
Government fee (mirror)	~AED 15,000	AED 1,900	~AED 4,334
Registration channel	In person at DIFC Courts or via DIFC Virtual Registry video conference	Online ADJD portal + notary video appointment	In-person attendance at Dubai Courts Notary/Online Notarisation
Best fit for	Non-Muslims with Dubai/RAK assets wanting common-law, English-language probate	Non-Muslims (or Muslims) wanting low cost, federal coverage, no witness coordination	Non-Muslims in Dubai wanting Dubai’s own civil-law notary route in Arabic

DIFC Courts Wills Service: common-law route in English

The DIFC option appeals to founders who already deal with DIFC-licensed entities or who simply prefer English-language probate. Notably, DIFC operates under common-law principles rooted in English law, which makes it familiar to British, Commonwealth and US testators.

Eligibility and witnesses

Per the official DIFC Courts Wills FAQ, the testator must be non-Muslim and have never been Muslim, be at least 21 years old, and either own assets in the UAE or have minor children in Dubai or Ras Al Khaimah. Furthermore, two witnesses must attend the signing. Each witness must be 21 or older, hold a valid government-issued photo ID, and must not be a beneficiary, guardian, or spouse of any beneficiary.

Language, assets and fees

DIFC drafts, registers and administers wills in English only. The service does not accept translators, so the testator and witnesses both need a working grasp of English. A DIFC Full Will can cover movable and immovable property anywhere in the UAE and optionally extend to non-UAE assets, although foreign enforcement is not guaranteed. The fee is AED 10,000 for a single Full Will and approximately AED 15,000 for mirror wills, with modifications at AED 550 per will. For complex multi-jurisdiction estates, our team often pairs this route with DIFC Will Registration support and a parallel corporate structuring review of UAE holding entities.

ADJD non-Muslim wills: the witness-free federal route

ADJD has become the most popular choice for expats prioritising cost and convenience. Critically, ADJD will registration is witness-free. According to the official ADJD process, documents required are simply a passport, Emirates ID, and a signed bilingual English/Arabic will.

How the ADJD process works

The ADJD registration is a six-step flow: draft the will, obtain an Arabic translation, access the ADJD online portal, upload documents, receive initial approval and pay the fee, then complete a notary video appointment. Because there is no in-person witnessing step, couples and busy founders can complete the entire process remotely. For procedural support, see our ADJD Will Registration service page.

Cost, coverage and who it suits

The ADJD government fee is AED 950 for a single will and AED 1,900 for mirror wills. Moreover, ADJD-registered wills are valid across all seven UAE emirates under the federal framework of FDL 41/2022. ADJD is also unusual in that it is open to both Muslims and non-Muslims; non-Muslim testators can opt out of Sharia-based inheritance by registering an ADJD will.

Dubai Courts Notary will: the civil-law Dubai route

The third option, the Dubai Courts Notary will, is often overlooked but useful for testators who want a Dubai-issued document under UAE civil law without DIFC’s English-only constraint.

Language and attendance

A Dubai Courts Notary will must be presented in Arabic or in bilingual form. Wills not originally drafted in Arabic require translation by a sworn legal translator, followed by notarisation at the Dubai Notary Public. Each testator must attend in person; however, no separate witnesses are required because the notary acts as the witness.

Fees and coverage

Government fees are approximately AED 2,167 for a single will and AED 4,334 for mirror wills. A Dubai Courts-registered will covers assets located anywhere in the UAE, not only in Dubai. Consequently, this route can be a sensible middle ground for residents who want lower cost than DIFC, but prefer a Dubai-based civil-law registry over an Abu Dhabi one. If your situation also involves cross-border documents, pair the will with a properly attested power of attorney.

How to choose between the three registries in 2026

As of 2026, the decision usually turns on four practical factors. First, your asset footprint. If everything sits in Dubai or Ras Al Khaimah and you want common-law treatment, DIFC fits. If you hold assets across multiple emirates, ADJD’s federal coverage is efficient. Second, language preference: English-only testators lean DIFC, Arabic-comfortable testators lean Dubai Courts Notary, and bilingual testators happily use ADJD.

Third, budget and family setup. ADJD is roughly one-tenth the cost of a DIFC Full Will, which matters when registering mirror wills for a couple. Finally, complexity: if you run multiple companies, hold shares in free zone entities, or have minor children needing guardianship clauses, a structured drafting review through legal consultation usually pays for itself by reducing probate friction later.

Frequently Asked Questions

What is the main difference between a DIFC, ADJD, and Dubai Courts will?

DIFC wills run under common-law principles in English with two mandatory witnesses, while ADJD and Dubai Courts wills run under UAE civil law without witnesses and accept Arabic or bilingual documents. DIFC is restricted to non-Muslims who have never been Muslim, ADJD is open to both Muslims and non-Muslims, and the Dubai Courts Notary serves non-Muslim residents who prefer a Dubai-based civil-law registry.

Do I need witnesses to register an ADJD will?

No, ADJD will registration does not require witnesses. The documents required are your passport, Emirates ID and a signed bilingual English/Arabic will, and the process is completed online via the ADJD portal followed by a notary video appointment.

How much does a DIFC will cost compared to an ADJD will?

A DIFC Full Will costs AED 10,000 for a single will and around AED 15,000 for mirror wills, whereas ADJD charges AED 950 for a single will and AED 1,900 for mirror wills. ADJD is therefore roughly ten times cheaper, although DIFC offers English-language common-law administration that some testators prefer.

Can a non-Muslim expat register an ADJD will?

Yes, non-Muslim expats can register an ADJD will and use it to opt out of Sharia-based inheritance rules. ADJD is open to both Muslims and non-Muslims, and non-Muslim testators rely on Federal Decree-Law 41 of 2022 to distribute their UAE estate according to their own wishes.

Is a Dubai Courts Notary will valid for assets outside Dubai?

Yes, a Dubai Courts Notary will covers assets located anywhere in the UAE, not only those in Dubai. The will must be presented in Arabic or in bilingual form, with sworn legal translation if it was originally drafted in English.

Does Federal Decree-Law 41 of 2022 replace the need to register a will?

No, Federal Decree-Law 41 of 2022 does not remove the need to register. Article 13(1) specifically requires the will to be recorded in the designated register, and Article 11(2) imposes a default 50/50 split between spouse and children if you die without one.

Disclaimer: This article is for general informational purposes only and does not constitute legal, tax, or regulatory advice. Rules and fees in the UAE change frequently. Before acting on anything you read here, speak to a qualified advisor — we are happy to help.