
Shireen Kapoor
November 29, 2025
Estate planning in the UAE can feel complex, especially for expatriates navigating different legal systems. With Dubai diverse population, understanding how wills operate under both the DIFC (Dubai International Financial Centre) system and Sharia-compliant frameworks is essential for ensuring your assets are protected and distributed according to your wishes.
Whether you are working with law firms in Dubai or seeking guidance from experienced consultants, knowing which will structure best suits your needs can make all the difference.
Below, we break down the key differences between DIFC wills and Sharia-compliant wills to help you make informed estate-planning decisions
A DIFC will is registered under the DIFC Wills and Probate Registry, which operates within a common-law framework—separate from the UAE federal courts. This option was introduced to provide non-Muslim expatriates with greater autonomy in distributing their assets.
Key Features of DIFC Wills
1. Full freedom of asset distribution
DIFC wills allow non-Muslims to freely assign their assets to anyone they choose, without the restrictions that apply under Sharia inheritance rules.
2. Covers assets in Dubai and Ras Al Khaimah
These wills are specifically recognized for assets located in these emirates, making them ideal for individuals with property, bank accounts, or businesses in Dubai or RAK.
3. Guardianship provisions
Parents can specify guardians for minor children, offering peace of mind for expatriate families.
4. Faster probate process
The DIFC courts are known for efficiency, transparency, and clear timelines, a major advantage for those wanting a streamlined probate process.
Because of its flexibility and clarity, many expatriates seek help from the top law firms in Dubai to draft a DIFC will that fits their family and financial needs.
A Sharia-compliant will follows Islamic inheritance principles and is governed by UAE federal law. This form of will is typically used by Muslim residents or citizens of the UAE.
Key Features of Sharia-Compliant Wills
1. Distribution based on fixed shares
Under Sharia, inheritance is distributed according to predetermined shares for spouses, children, parents, and other relatives. This structure aims to ensure fairness within family systems.
2. Limited discretion in asset distribution
Individuals cannot freely assign all their wealth. Only up to one-third may be bequeathed outside the fixed shares, and only if no heirs object.
3. Applies across the UAE
Unlike DIFC wills, Sharia inheritance principles apply nationwide, regardless of the emirate.
4. Guardianship follows Sharia rules
Legal guardianship after the father death generally defaults to the closest male relative on the paternal side, unless otherwise approved by the courts.
Professionals often advise consulting the best lawyer in UAE to understand how Sharia-based rules impact family planning and asset distribution.
When you buy property in Dubai, make sure you review:
1. Flexibility in Asset Allocation
DIFC wills allow complete freedom, while Sharia wills follow fixed inheritance shares.
2. Applicable Legal Framework
DIFC uses a common-law system; Sharia wills follow Islamic jurisprudence and federal UAE law.
3. Guardianship Rules
DIFC wills allow parents to assign guardians, whereas Sharia assigns guardianship according to traditional Islamic rules.
4. Probate Process
DIFC procedures are generally more predictable and transparent, whereas Sharia-based probate involves multiple legal authorities and may take longer.
5. Eligibility
DIFC wills are mainly for non-Muslims; Sharia-compliant wills are typically used by Muslims.
Professional law consultants in Dubai can review these documents and highlight any hidden risks.
Choosing between a DIFC will and a Sharia-compliant will depends on your religion, family structure, and the level of control you want over your asset distribution. Non-Muslims often find DIFC wills more suitable due to their flexibility and straightforward process. Muslim residents typically follow Sharia-compliant wills that align with their faith and legal expectations.
For tailored guidance, it’s wise to work with experienced law firms in Dubai or professional consultants like theaskconsultancy, who can assess your unique circumstances and help you navigate the UAE estate-planning landscape.
Understanding the differences between DIFC and Sharia-compliant wills is crucial for safeguarding your family future. With Dubai sophisticated legal infrastructure and access to the top law firms in Dubai, expatriates and residents alike can structure their wills with confidence. Choosing the right will—and the right legal support—ensures that your assets are protected and distributed exactly as you intend.

The ASK Consultancy offers expert legal advice in the UAE, specializing in corporate law, residency, citizenship by investment, and real estate. We help clients navigate UAE laws with confidence and compliance. We are also officially registered with DIFC, ensuring adherence to the highest regulatory standards.
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