Your Dubai property does not follow your will home

1. The rule that catches everyone

There is one sentence in UAE federal law that decides this entire subject. In the Civil Transactions Law it reads:

"The law of the United Arab Emirates shall apply to a will made by a foreigner concerning their immovable property located in the State."

Dubai says the same thing separately. Dubai Law No. (15) of 2017 provides that the legislation in force in the Emirate applies where the estate or will relates to real property located in the Emirate — and also where determining whether the willed property is real or moveable, and where a foreign law would contradict public order.

So the position is confirmed twice, at two levels of government. Your Dubai apartment is governed by UAE law, whatever your will at home says, and whatever law that will chooses.

Everything else in this guide follows from that.

2. Why most articles on this are now wrong

If you research this yourself you will find dozens of law-firm pages and blog posts citing Article 17(5) of Federal Law No. 5 of 1985.

That law no longer exists. It was repealed on 1 June 2026, when Federal Decree-Law No. (25) of 2025 promulgating the new Civil Transactions Law came into force.

The rule itself survived the change with the same article number and the same meaning, so the substance of those articles is not wrong — but the citation is dead, and it tells you how old the page is. The same is true of anything citing the 2005 Personal Status Law, which was replaced by Federal Decree-Law No. (41) of 2024, effective 15 April 2025.

Even the government’s own general-information portal lags. At the time of writing, the u.ae page on personal status for non-Muslims still described instruments that have since been superseded. When the stakes are your estate, read the legislation portal rather than a summary of it — and check the date on anything you are relying on.

3. Does this mean Sharia applies to my flat?

This is where the internet consensus overshoots, and the accurate answer is better news than the scary one.

The rule is about which legal system applies, not about how your estate is divided. It says UAE law governs. The next question — which UAE law — depends on who you are.

For a non-Muslim, the applicable framework is Federal Decree-Law No. (41) of 2022 on Civil Personal Status, together with Dubai Law No. (15) of 2017. And that framework is expressly permissive:

"The testator shall have the right to leave a will with the entire property he owns in the State in favor of anybody he wants."

So a non-Muslim owner has broad freedom to direct their Dubai property — as a matter of UAE law, not as a matter of their home country’s law.

The real risk is not forced heirship. It is dying without a registered will. Without one, the statutory default engages, or an heir applies to have a different law applied to the estate. The 2022 law says an heir may request the application of the law applicable under the Civil Code — "unless there is a registered will to the contrary". The registered will is precisely what forecloses that argument.

And the default itself is not what most people fear. For non-Muslims under the current law the intestate split is half to the surviving spouse and the other half divided equally among the children, with no distinction between sons and daughters. That is the published rule in both the federal law and the Abu Dhabi equivalent.

4. Joint ownership does not do what you think

A very common assumption among buyers from common-law countries: the title deed is in both our names, so if one of us dies the other simply owns it.

No UAE instrument creates that right of survivorship, and the Dubai registration framework routes the share through the estate instead.

Dubai Law No. (7) of 2006 on Real Property Registration provides that where an estate contains real property rights, a certificate of inheritance must be registered in the Property Register, and that disposal by an heir is not effective against third parties unless also registered. There is no joint-ownership exception in that article. The same law provides that transactions creating or transferring real property rights are not valid unless recorded in the Property Register.

So the route is: court-issued inheritance certificate, then registration, then the heirs own it. There is no automatic vesting. If you and your spouse hold a Dubai property jointly and are relying on survivorship, you are relying on a concept the UAE registration system does not implement.

5. The DIFC Wills route

Dubai Law No. (15) of 2017 created a Register of Wills of non-Muslims at both the Dubai Courts and the DIFC Courts. The DIFC route is the one most foreign owners use.

Eligibility, from the DIFC Courts’ own published guidance:

• You are not Muslim and have never been a Muslim.
• You are at least eighteen at registration.
• You own assets in the UAE, or have minor children residing here.
• You do not need to be a UAE resident. This surprises people, and it matters for overseas investors who own a Dubai apartment and live elsewhere.

You also do not need to fly here. The DIFC Courts state that all their wills can be registered and modified online by video conference, with testators and witnesses attending from anywhere in the world — and the published fee schedule carries no separate rate for doing it virtually.

There are six will types, not the five usually listed: a Full Will, a Property Will, a Guardianship Will, a Business Owners Will, a Financial Assets Will, and a Digital Assets Will, for which the DIFC Courts operate a non-custodial wallet. The Property Will covers up to five UAE real estate properties, or shares in up to five.

One limit to know. The registry’s framework has been formally extended by practice direction to Ras Al Khaimah. Abu Dhabi is not named in the rules, the practice directions or the guidance. Abu Dhabi operates its own non-Muslim wills registry through the Judicial Department. If your property is in Abu Dhabi, take specific advice rather than assuming a DIFC will reaches it.

And a housekeeping note that catches people: the old difcprobate.ae address is no longer the service — as at late 2026 that domain hosts something entirely unrelated, while plenty of older articles still link to it. The DIFC Courts site is the live one.

6. What it costs

These are the DIFC Courts’ published registration fees. "Mirror" means two wills registered together, typically a couple.

Full Will	AED 10,000 single · AED 15,000 mirror
Property Will (up to five UAE properties)	AED 7,500 single · AED 10,000 mirror
Guardianship Will	AED 5,000 single · AED 7,500 mirror
Business Owners Will	AED 5,000 single · AED 7,500 mirror
Financial Assets Will	AED 5,000 single · AED 7,500 mirror
Digital Assets Will	AED 5,000 single · AED 7,500 mirror
Modifying a will later	AED 550 per will
Inspecting a registered will	AED 375
Withdrawing a will	No fee

The booking fee is not an extra. Each service carries a booking fee paid up front — AED 1,000 on a Full Will, AED 750 on a Property Will — and the published schedule states it is deductible from the service fee. It is non-refundable if you cancel, reschedule more than three times, or push the appointment more than ninety days out.

For context on the other side of the transaction: transferring an inherited property at the Dubai Land Department is a published flat fee of AED 1,000 per property, plus AED 250 for the title deed and map fees, completed in eight working hours. The usual four per cent transfer fee does not appear on that service. What the process needs is the court-issued inheritance certificate — which is exactly the document that takes time and money to obtain when there is no registered will.

7. What happens if you do nothing

The most quoted claim here is that bank accounts freeze on death. We could not find that stated as a published rule by any official source, so we are not going to repeat it as one.

What is official is stronger and more precise. Dubai Law No. (15) of 2017 provides that no disposition in respect of an estate may be undertaken before an estate administration judgment or order is issued. Not just accounts. The estate.

The same law sets the order in which money leaves the estate before anyone inherits anything: funeral expenses first, then estate administration and will implementation costs, then the remuneration of executors and administrators, then the debts of the estate. Only what remains is distributed.

Administrators are appointed by the court, must file an inventory of the estate within six months, and must report quarterly.

On foreign wills. They are not excluded in principle — the ordinary choice-of-law rules apply — but Dubai real property is carved out of those rules, Arabic is the language of the courts, and foreign-language documents must be certified translations. The DIFC Courts themselves say a will drafted or notarised abroad does not comply with their rules and "would most certainly need to be re-drafted."

Registering a will here does not stop you having one at home. The DIFC Courts confirm there is no restriction on making another will in another country afterwards. They are for different assets.

8. What to actually do

If you own property in Dubai and have no will registered here, the practical sequence is short.

1. Check what you actually own and how. Sole name, joint names, company name — each behaves differently, and the joint-name assumption is the one most often wrong.
2. Decide the scope. If Dubai property is the main UAE asset, a Property Will covering up to five properties is the cheaper route. If there are also accounts, a business or minor children here, a Full Will is the one instrument that covers them.
3. Name your nationality in the will. Dubai Law No. (15) of 2017 provides that where a testator has multiple nationalities, the applicable law follows the nationality specified at registration — and where none is specified, a default rule decides for you.
4. Take proper advice. This guide is general information, not legal advice. The law here changed materially in 2025 and 2026, and anyone advising you from a page citing the 1985 Civil Code is working from a repealed statute.

The thing worth holding on to: the fix is cheap relative to the asset. A Property Will covering up to five Dubai properties costs less than the transfer fee on a modest apartment. The expensive version is the one where nothing was registered and the estate waits on a court.

9. Frequently asked questions

Sources & verification. Legal position per Federal Decree-Law No. (25) of 2025 Promulgating the Civil Transactions Law, in force 1 June 2026, which repealed Federal Law No. (5) of 1985; Federal Decree-Law No. (41) of 2022 On the Civil Personal Status and its Executive Regulation, Cabinet Resolution No. (122) of 2023; Federal Decree-Law No. (41) of 2024 issuing the Personal Status Law, effective 15 April 2025; Dubai Law No. (15) of 2017 Concerning Administration of Estates and Implementation of Wills of Non-Muslims; and Dubai Law No. (7) of 2006 Concerning Real Property Registration — all published on the UAE Legislation portal and the Dubai Government Legislation Portal. Will types, eligibility and fees per the DIFC Courts published Schedule of Fees and Wills Service pages. Inheritance transfer procedure and fees per the Dubai Land Department service pages. This guide is general information and not legal advice; take advice on your own circumstances. Position as at 16 September 2026.