Wills in the UAE: Mainland vs Free Zone Options - A Practical Overview for Muslims

Choosing the right jurisdiction for Will registration in the UAE is critical, particularly for Muslims seeking Sharia-compliant estate planning. Below is a brief overview of the available mainland and free zone options, highlighting the most suitable route for Muslim testators.

1. Abu Dhabi Judicial Department (ADJD) - Preferred Option for Muslims

The Abu Dhabi Judicial Department (ADJD) is widely regarded as the most suitable and robust option for Muslims in the UAE.

• Accepts Wills for both Muslims and non-Muslims
• Wills are prepared in bilingual format (Arabic and English), with Arabic as the legally binding version
• Fully Sharia-compliant for Muslim testators
• Can cover assets in Abu Dhabi as well as across the UAE
• Registration is completed through the ADJD courts, typically via a registered law firm
• Offers a structured process covering notarisation, registration, and execution
• Provides strong legal recognition and enforceability, reducing the risk of disputes

2. Dubai Mainland & Other Emirates

(Sharjah, Ajman, Ras Al Khaimah, Fujairah, Umm Al Quwain)

• Mainland courts register Wills for assets located within their respective emirates
• For Muslims, inheritance is governed by Sharia law
• Non-Muslims may register Wills in Arabic or bilingual format
• Procedures vary by emirate and are generally less standardised than ADJD
• Often require local legal support for drafting and registration

These jurisdictions are viable but are typically considered secondary options due to procedural variability.

3. Free Zones (DIFC and Others)

• The DIFC Wills Service Centre is available only to non-Muslims
• Operates under common law principles and uses English-language Wills
• Other free zones (such as JAFZA, DMCC, and ADGM) do not maintain independent Wills registries
• Assets in these free zones are generally covered through:

• DIFC Wills (for non-Muslims), or
• ADJD or local mainland court Wills (for Muslims)

As such, free zone Will structures are not suitable for Muslims seeking Sharia-compliant estate planning.

Conclusion

For Muslims residing in the UAE, the Abu Dhabi Judicial Department (ADJD) remains the most appropriate and legally recognised forum for registering Sharia-compliant Wills with UAE-wide coverage.

DIFC and other free zone Will regimes are designed exclusively for non-Muslims, while other mainland emirate courts serve as alternative options with less uniform procedures.