A side-by-side comparison of the two leading registration routes for non-Muslims in the UAE - the common law DIFC Wills Service Centre and the civil law Abu Dhabi Judicial Department (ADJD).
Non-Muslim residents and investors in the UAE typically choose between two main Will registration routes: the DIFC Wills Service Centre, operated under a common law framework through the DIFC Courts, and the Abu Dhabi Judicial Department (ADJD) non-Muslim Wills register, operated under the UAE's civil law system.
Both routes allow testators to opt out of forced heirship rules and distribute their UAE assets according to their own wishes. The right choice depends on where assets sit, how quickly probate must move, and the family's preference for legal framework.
A common law register operated by the DIFC Courts in Dubai. Designed for non-Muslims with assets anywhere in the UAE, with Wills enforced through the DIFC's English-language judicial system.
A civil law register operated by the ADJD's non-Muslim Wills office. Particularly efficient for testators with Abu Dhabi assets, while also accepted as evidence of testamentary wishes across the wider UAE.
| Criterion | DIFC | ADJD |
|---|---|---|
| Legal framework | Common law (DIFC Courts) | Civil law (UAE federal principles) |
| Jurisdiction of assets | UAE-wide for non-Muslims | Strongest in Abu Dhabi; recognised across the UAE |
| Probate forum | DIFC Courts - English language | Abu Dhabi Civil Family Court - Arabic / English |
| Probate speed | Predictable common-law grant; typically efficient | Streamlined for Abu Dhabi estates; efficient overall |
| Registration cost | Higher government fees; range of Will types | Generally lower government fees |
| Language | Drafted and registered in English | Bilingual - Arabic and English |
| Eligibility | Non-Muslims, aged 21+ | Non-Muslims, aged 21+ |
| Witnesses | Required at registration appointment | Required at registration appointment |
| Best suited to | Common law families, multi-emirate assets, international structures | Abu Dhabi residents, investors with local real estate, cost-sensitive clients |
Abu Dhabi-heavy estates often favour ADJD; multi-emirate or Dubai-centred estates frequently choose DIFC.
DIFC offers familiar common law procedure; ADJD is highly efficient for Abu Dhabi assets.
ADJD government fees are usually lower; DIFC offers a broader range of structured Will types.
DIFC is English-language common law; ADJD is bilingual civil law - choose what your family understands best.
Our specialists can review your assets, family situation and priorities, then recommend the registration route - DIFC, ADJD or Dubai Courts - that best protects your estate.