If you're looking into making a will in the UAE, you'll quickly encounter two main registration options: the ADJD (Abu Dhabi Judicial Department) system and the DIFC Wills Service Centre. Both produce legally enforceable wills for non-Muslims, but they operate under different legal frameworks, carry different costs, and have slightly different coverage areas.
Here is a clear comparison to help you decide which is right for your situation.
ADJD Wills: Overview
The Abu Dhabi Judicial Department operates a will registration system that is enforceable across all seven Emirates of the UAE. It was established to provide an accessible, cost-effective route for non-Muslims to register wills that override Sharia inheritance defaults.
- Legal framework: UAE Federal law (Civil Law system)
- Coverage: All UAE assets across all seven Emirates
- Language: Must be in Arabic (translation provided)
- Government fee: AED 950 per will
- Availability: For residents and non-residents with UAE assets
- Typical total cost with a service like OwnX: AED 1,699 (individual) / AED 3,399 (mirror wills)
DIFC Wills: Overview
The DIFC Wills Service Centre (WSC) is operated by the Dubai International Financial Centre and governed by DIFC laws, which are based on English Common Law. It offers several will types covering different asset categories.
- Legal framework: DIFC law (Common Law system, similar to English law)
- Coverage: Primarily Dubai immovable assets, with options for broader coverage
- Language: English (no Arabic translation required)
- Registration fees: AED 3,600–10,000 depending on will type
- Additional will types: Guardianship Will, Financial Assets Will, Business Owners Will
- Availability: For residents and non-residents
Key Differences at a Glance
- Cost: ADJD is substantially cheaper (AED 950 government fee vs AED 3,600–10,000 for DIFC)
- Legal system: ADJD uses UAE Federal (Civil) Law; DIFC uses Common Law, more familiar to UK/US expats
- Coverage: ADJD covers all UAE Emirates; DIFC primarily covers Dubai (though cross-Emirate options exist)
- Language: ADJD requires Arabic; DIFC is in English
- Specialised products: DIFC offers separate Guardianship Wills and Financial Assets Wills
- Enforceability: Both are fully enforceable, ADJD through UAE courts, DIFC through DIFC courts with recognition across the UAE
Who Should Choose ADJD?
The ADJD system is the right choice for the majority of UAE expats. If you have standard UAE assets, salary account, car, household contents, savings, and possibly a property, an ADJD will is more cost-effective and covers you across all Emirates.
- You want the lowest total cost
- Your assets are spread across multiple Emirates
- You want a straightforward, single will covering all UAE assets
- You are comfortable with the required Arabic translation (provided by your service)
Who Should Consider DIFC?
The DIFC system may be preferable in more specific circumstances:
- You hold significant assets within DIFC-regulated structures
- You strongly prefer a Common Law framework and English-language document
- You need a separate Guardianship Will for minor children (DIFC offers a dedicated product)
- You have complex cross-border estate planning where Common Law recognition is important
- Your legal advisor has recommended it for your specific estate structure
Can You Have Both?
Yes, and some expats do. For example, someone might register an ADJD will covering all UAE movable assets (accounts, vehicles, personal property) and a DIFC will specifically for their Dubai real estate, to take advantage of the DIFC's established real estate transfer protocols. This adds cost and complexity but may be justified for high-value or complex estates.
For most people, one well-drafted will under a single jurisdiction is sufficient, speak to OwnX about which suits your situation.
OwnX can register your will under ADJD, DIFC, or Dubai Courts, whichever is right for your estate. Start from AED 749 and we'll guide you through the options.
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Aanchal Adhikari (Advocate, LL.B., LL.M. (Cand.))
Senior Specialist & UAE Estate Planning Advocate
Aanchal Adhikari is a Nepal-licensed Advocate with 4+ years of legal practice, specialized in ADJD Wills, DIFC wills, and UAE inheritance. She has drafted and overseen 800+ ADJD Wills in the UAE and is currently pursuing an LL.M. at Middlesex University Dubai.
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