The United Kingdom has more nationals living in the UAE than almost any other country. Many of them have a UK will, drafted before they moved to Dubai, or maintained as part of their UK estate planning. The assumption is often that this UK will covers everything, including their UAE assets. It does not.
Why Your UK Will Doesn't Cover UAE Assets
A will's enforceability depends on the jurisdiction where probate is sought. UAE courts do not automatically recognise or enforce foreign wills. To have a UK will enforced in the UAE, it would need to go through a process of authentication, attestation, and ratification by UAE courts, a process that takes months and costs significant legal fees.
In practice, this means a UK will provides very limited protection for UAE assets. During the authentication process, UAE law, including Sharia default inheritance rules, applies to your UAE assets.
A UK will does not prevent UAE bank accounts from being frozen, UAE property from passing through Sharia distribution, or your UAE estate from going through UAE probate courts.
What UAE Law Applies to British Expats
For a British national who dies in the UAE without a registered UAE will, UAE courts apply Sharia principles to all UAE-based assets. The fact that you are British, Christian, atheist, or of any other background is irrelevant to this default rule.
The assets affected include: UAE bank accounts and savings, property in Dubai or other Emirates, UAE investments and brokerage accounts, vehicles, household contents, and end-of-service gratuity.
What You Need: A UAE Will Alongside Your UK Will
The correct approach for British expats is to maintain both:
- A UK will covering UK assets (property, accounts, investments in the UK)
- A UAE will covering UAE assets (registered with ADJD or DIFC)
Critically, the two wills need to be co-ordinated. A standard UK will often includes a clause revoking all previous wills, which could accidentally revoke your UAE will if made later. Your UK solicitor should include language like 'this will does not revoke any will I have made or may make governing assets outside the UK'.
Does the UK-UAE Treaty Help?
There is no bilateral treaty between the UK and UAE that automatically makes UK wills enforceable in the UAE or vice versa. Succession law in the UAE is governed by UAE Federal law, which requires either a locally registered will or a full probate process for foreign wills.
How British Expats Register a UAE Will
British expats can register a UAE will through either the ADJD system (covering all UAE assets, government fee AED 950) or the DIFC Wills Service Centre (Common Law framework, covering Dubai assets, fees from AED 3,600).
With OwnX's ADJD service, no travel to the UAE is required. The court verification is conducted via video call, so British expats can complete their UAE will entirely from the UK, or wherever they are in the world.
- Complete the will questionnaire online, takes 15–25 minutes
- OwnX prepares the draft and court-certified Arabic translation
- Sign the bilingual will in your OwnX account, no printing or posting required
- You upload your completed will to the court portal
- The court contacts you to arrange payment and schedules a short video verification call
- Will is registered, usually the next working day after the call
British expat? Prepare your UAE will online from the UK, then complete ADJD registration and video verification remotely. No UAE travel required. From AED 749.
Start Your WillWhat About British Nationals Who Have Left the UAE?
If you have left Dubai but still own property, investments, or other assets in the UAE, those assets remain subject to UAE law on your death. You can still register a UAE will as a non-resident, and with OwnX's ADJD service, no visit to the UAE is needed. Everything is done online with a video verification call.
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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