How to Register an International Will in ADGM or DIFC, Step by Step

What this guide covers: For globally mobile clients considering the DIFC Courts Wills Service or the ADGM Courts non-Muslim Wills service, it is important to distinguish between the two mechanisms. DIFC provides a dedicated wills registration and probate framework, while ADGM Courts Notary Public provides an ADJD-authorised service for notarising non-Muslim wills, with probate handled through the Abu Dhabi Judicial Department. This article explains the eligibility requirements, documents, execution and notarisation or registration procedures, fees, timelines and cross-border considerations for each route.

Intro, the quick answer and what you will learn

Globally mobile clients considering a UAE will can choose between different mechanisms, including the DIFC Courts Wills Service and the non-Muslim Wills service offered through ADGM Courts Notary Public. DIFC operates a dedicated Wills Service and Wills Registry for Non-Muslims, with probate handled by the DIFC Courts. ADGM Courts Notary Public, by contrast, is licensed and authorised by the Abu Dhabi Judicial Department to notarise non-Muslim wills and does not operate a separate ADGM probate service. A will submitted through ADGM must be in bilingual Arabic-English format certified by a legal translator licensed by the UAE Ministry of Justice.

This guide walks through both processes in detail. You will learn who is eligible, which documents each service requires, how execution, notarisation and witnessing differ, the practical steps for ADGM notarisation and DIFC registration, indicative timings and fees, and the issues that arise where assets are located in other jurisdictions. We also set out a direct comparison and a decision checklist to help determine which route is appropriate for the client’s circumstances.

What is an international will, ADGM & DIFC explained

The term “international will” is used here descriptively rather than as the formal name of a will category offered by either service. A DIFC Courts Will is registered under the DIFC wills framework and may, depending on the type of Will, govern specified UAE assets and, in the case of a drafted Full Will, may extend to assets outside the UAE subject to enforceability in the relevant foreign jurisdiction. A will notarised through ADGM Courts follows the Abu Dhabi notarial framework: it must be bilingual in Arabic and English and may cover assets within or outside the UAE, although probate for assets outside the UAE remains subject to the law and procedures of the jurisdiction where those assets are located.

The appeal lies in greater certainty over how the relevant UAE assets will be dealt with after death. DIFC provides a dedicated wills registration and probate framework administered through the DIFC Courts. ADGM Courts provides an ADJD-authorised notarisation service, but a will notarised through ADGM is not placed within a separate ADGM common-law probate regime; probate applications must be made through ADJD’s Wills and Probate Office. For assets outside the UAE, the effect of either will depends on the succession and recognition rules of the jurisdiction where those assets are located.

It is worth noting that federal law has evolved in recent years. Federal reforms (including Federal Decree-Law No. 41 of 2022 on Civil Personal Status for non-Muslim foreigners) expanded the options for non-Muslims to have their estates dealt with under non-Sharia principles. The ADGM and DIFC registries remain widely used options, but advisers should consider the current federal framework alongside the free-zone routes when planning.

Legal basis, ADGM Wills Registry and the DIFC Wills Service

The two services have different legal and institutional bases. ADGM Courts Notary Public is licensed and authorised by the Abu Dhabi Judicial Department under Abu Dhabi Law No. 11 of 2017 concerning the Notary Public to notarise non-Muslim wills. It is not a wills registry operated by the ADGM Registration Authority, and ADGM Courts does not provide probate services for those wills. The DIFC Courts Wills Service, by contrast, supports the DIFC Courts Wills Registry for Non-Muslims and operates under Dubai Law No. 15 of 2017 and the DIFC Wills and Probate Registry Rules, with probate matters handled through the DIFC Courts.

Why choose an international will in ADGM or DIFC, key benefits

Registering a will in one of these registries can deliver tangible advantages for clients whose lives and assets span multiple countries:

• Defined legal route. DIFC provides a dedicated wills registration and probate framework, while the ADGM Courts service provides ADJD-authorised notarisation of eligible non-Muslim wills.
• Language and procedure. DIFC Will registration is conducted electronically through the DIFC Courts Wills Service. A will submitted to the ADGM Courts Wills Office must be bilingual in Arabic and English and certified by a legal translator licensed by the UAE Ministry of Justice.
• Eligibility for non-Muslim testators. DIFC and ADGM both offer routes for eligible non-Muslims, but their age, asset and procedural requirements differ.
• Post-death procedure. DIFC probate applications are handled through the DIFC Courts. ADGM Courts does not provide probate services; applications relating to wills notarised through ADGM must be made through ADJD’s Wills and Probate Office.
• Official registration or notarisation. DIFC Wills are registered electronically with the DIFC Courts Wills Registry, while ADGM Courts electronically notarises wills through its ADJD-authorised Notary Public service.

In practice, the most common driver is risk reduction. Globally mobile clients want to know that one coherent estate plan will hold across the countries where they live, work and own assets, and that the UAE portion of that plan is secure.

Eligibility and scope, who can use ADGM/DIFC international wills

Eligibility differs materially between the two services. DIFC requires the testator to be a non-Muslim aged at least 18 who owns assets in the UAE and/or has qualifying minor children residing in the UAE. UAE residence or a UAE visa is not required. The published ADGM Courts Wills Office criteria state that its service is available to non-Muslim individuals aged 21 or over who own assets in the UAE. Eligibility should therefore be checked against the requirements of the particular service rather than treated as identical.

Natural persons and testamentary capacity

The testator must have testamentary capacity and satisfy the eligibility requirements of the chosen service. For DIFC, the testator must be a non-Muslim aged at least 18 and must own assets in the UAE and/or have qualifying minor children residing in the UAE; UAE residence is not required. For the ADGM Courts Wills Office, the published criteria require a non-Muslim testator aged 21 or over who owns assets in the UAE. Capacity should be assessed at the time of execution, particularly where age, illness or other circumstances could later give rise to a challenge.

Assets and territorial scope, coverage of UAE assets

Asset coverage differs between the two services. The DIFC Courts Wills Service offers several Will types: a Full Will can cover movable and immovable assets in the UAE and, if appropriately drafted, may extend to assets outside the UAE, while Property, Business Owners and Financial Assets Wills are subject to specified UAE asset limits. The ADGM Courts Notary Public can notarise wills covering assets located elsewhere in the UAE and assets outside the UAE, although any grant of probate for foreign assets must be obtained in the jurisdiction where those assets are located.

For background on the wider national framework, see the UAE Government Portal. Confirm the current asset-coverage options directly with each registry.

Required documents, ADGM checklist

The ADGM Courts process is a will notarisation process rather than registration with an ADGM wills registry.

• The will must be in bilingual Arabic-English format and certified by a legal translator licensed by the UAE Ministry of Justice.
• The submission must include the testator’s passport and, for a UAE resident, Emirates ID; the current ADGM service page also requires a valid UAE visit visa or entry stamp for a non-resident.
• Where the will specifically describes assets to be distributed, supporting documents proving ownership of those assets, translated into Arabic, are required.
• The will must also contain the information required by the Wills Office, including the testator’s details and religion, the appointment and powers of the executor, beneficiary details and, where applicable, guardianship and asset-distribution provisions.

Requests are submitted through the digital ADGM Courts process.

Common document pitfalls

The documentary risks differ by route. For the ADGM Courts service, the key requirements include the bilingual certified will, complete testator and beneficiary information, the required identity documents and, where specific assets are described, translated evidence of ownership. For DIFC, the required documents vary according to the Will type and include the testator’s identification, identification for the two witnesses and specified ownership or guardianship documents where applicable. Any authentication or legalisation requirement for foreign documents should be confirmed for the particular document and authority rather than assumed to apply to every registration.

Required documents, DIFC checklist

The DIFC document requirements are distinct from the ADGM notarisation requirements.

• Through the Wills Service portal, the testator must upload a valid passport and Emirates ID if applicable, together with valid identification for the two witnesses.
• Additional mandatory documents depend on the Will type: for example, a Property Will requires the relevant title deed or Oqood certificate, a Business Owners Will requires evidence of the relevant shareholding, and a Guardianship Will or Full Will containing guardianship provisions requires signed Guardianship Statements from the appointed guardians.
• Other documents, such as a letter of wishes, asset list or identification for executors and beneficiaries, may be uploaded where relevant but are not generally mandatory registration documents.

DIFC-specific evidentiary requirements

The DIFC Wills Service Centre uses a structured appointment and verification process, and confirms document sufficiency as part of that appointment. Because the DIFC model emphasises verification at the point of registration, it is worth confirming the precise current form set and any evidentiary requirements directly via the official DIFC channels before booking, as the service periodically updates its forms and fees.

Execution formalities, witnessing, language, notarisation and capacity

Execution formalities differ materially. DIFC registration appointments must be attended by the testator and two witnesses, whether the appointment takes place virtually or in person, and the Will is executed electronically. DIFC witnesses must be at least 18 and must not be beneficiaries or guardians named in the Will, or spouses of beneficiaries or guardians. The ADGM Courts process is a notarial process: the will must be bilingual in Arabic and English and certified by a UAE Ministry of Justice-licensed legal translator, and the testator attends the virtual appointment with the Notary Public for electronic notarisation.

Capacity must be present at the time of execution or notarisation. For DIFC, the two witnesses must satisfy the Wills Service eligibility requirements and must not be beneficiaries or guardians, or spouses of beneficiaries or guardians, named in the Will. The ADGM Courts Wills Office follows a different notarisation procedure and its published submission and appointment requirements should not be described as the same two-witness registration process used by DIFC.

Remote witnessing and video execution

Both services currently provide remote procedures, although the mechanics differ. The ADGM Courts Notary Public and Wills Office is fully digital and conducts the testator’s notarisation appointment virtually. DIFC Courts Wills may also be registered or modified online by video conference from anywhere in the world, with the testator and two witnesses signing electronically; an in-person DIFC appointment remains available as an alternative.

How to register an international will in ADGM, the ADGM workflow

The ADGM Courts process is a digital notarisation process:

1. Prepare the will. The will must be in bilingual Arabic-English format and certified by a legal translator licensed by the UAE Ministry of Justice, and it must contain the information required by the Wills Office.
2. Assemble the supporting documents. This includes the testator’s identification and, where specific assets are described, the required evidence of ownership.
3. Submit the notarisation request. The request and supporting documents are submitted electronically through the ADGM Courts process.
4. Pay the applicable fees and attend the virtual appointment. Once the request has been reviewed and accepted, the applicable fee process is completed and the testator attends the appointment remotely with the Notary Public.
5. Complete electronic notarisation. The Notary Public notarises the will electronically and the notarised copy is issued electronically. ADGM Courts does not provide probate services; after death, the relevant probate application must be made through ADJD’s Wills and Probate Office.

The ADGM Courts Notary Public and Wills Office is currently fully digital. Before submitting the request, confirm that the bilingual certified will contains all required information and that the testator’s identification and any required ownership documents are available. Once the submission has been accepted and the required payment steps completed, the testator attends the scheduled virtual appointment with the Notary Public.

Step-by-step registration process, DIFC workflow

The DIFC process is an electronic registration process:

1. Prepare or upload the relevant DIFC Courts Will through the Wills Service portal and upload the mandatory identification and Will-specific supporting documents.
2. Book and pay for the registration appointment online.
3. Attend the registration appointment. The testator and two witnesses must attend, either virtually or in person, with the identification submitted through the portal available for verification.
4. Execute the Will electronically. The testator and witnesses sign electronically during the appointment.
5. Obtain the registered Will. Once the electronic signatures have been completed and accepted, the registered electronic Will can be downloaded. The electronic Will is treated as the original; the Wills Service does not register or retain a hard-copy original.

For the DIFC route, confirm the appropriate Will type before preparing the document and ensure that the mandatory identification and Will-specific evidence have been uploaded before the appointment. All DIFC Courts Wills can currently be registered electronically by video conference, and the testator and both witnesses may participate from outside the UAE. Current fees and registration requirements should be checked through the DIFC Courts Wills Service before booking.

Timelines, fees and practical timings, ADGM versus DIFC

The two services have different fee structures. DIFC publishes registration fees for each type of DIFC Courts Will. For ADGM, the non-Muslim Wills service involves the applicable ADGM Courts fee together with the ADJD notarisation fee. Current fees and appointment requirements should be confirmed from the relevant official pages before advising a client or quoting costs.

Where estate planning is urgent, the testator should first confirm eligibility and ensure that the mandatory documents for the chosen route are complete before seeking the earliest available appointment. For ADGM, the bilingual certified will and supporting documents must satisfy the Notary Public’s requirements. For DIFC, the required identification and Will-specific documents must be uploaded before registration. Authentication or legalisation requirements for any foreign documents should be determined by reference to the particular document and authority rather than assumed to apply generally.

Comparison table, ADGM versus DIFC side by side

Recognition and enforcement across jurisdictions

The post-death process depends on the route and the location of the assets. A registered DIFC Courts Will is dealt with through the DIFC Courts probate framework. A will notarised through ADGM Courts does not proceed through ADGM probate; ADGM expressly states that probate applications must be registered with ADJD’s Wills and Probate Office. For assets outside the UAE, separate probate, succession or recognition procedures may be required in the jurisdiction where those assets are located.

For assets outside the UAE, recognition and administration depend on the private international law and succession procedures of the jurisdiction where the assets are situated. A UAE probate order or notarised will does not automatically take effect abroad, and the relevant foreign jurisdiction may require a local grant, recognition proceeding, translation or document authentication. UAE-issued documents may also require UAE Ministry of Foreign Affairs attestation and any additional formalities required by the destination jurisdiction. Cross-border planning should therefore be based on the specific countries involved rather than assuming a uniform recognition or apostille process.

A practical checklist for counsel: map every asset to its jurisdiction; confirm the recognition route and documentary requirements for each; determine whether apostille or consular legalisation applies; and coordinate the sequence of grants so that each jurisdiction’s requirements are satisfied in the right order.

When to choose ADGM versus DIFC, practitioner decision checklist

The choice should be based on the legal and procedural differences between the two routes rather than simply whether the client has an Abu Dhabi or Dubai connection:

• DIFC route. Consider whether the testator satisfies DIFC eligibility requirements, which type of DIFC Courts Will covers the relevant assets, whether guardianship provisions are required and whether the dedicated DIFC probate framework is appropriate.
• ADGM route. Consider whether the testator satisfies the ADGM Wills Office eligibility requirements and is comfortable using the bilingual ADJD-authorised notarisation route, with probate subsequently handled through ADJD.
• Multi-jurisdictional estates. Determine separately whether assets outside the UAE can effectively be governed by the UAE will and what probate or recognition procedures will be required in each foreign jurisdiction.
• Business owners. Coordinate testamentary provisions with the company’s constitutional documents, ownership structure and any transfer restrictions rather than selecting a wills service solely by reference to the company’s emirate of incorporation.

Coordinating registration and enforcement for globally mobile clients

For clients with assets across several countries, the hardest part is not registration itself but ensuring the whole plan holds together. Effective coordination means engaging local counsel in each relevant jurisdiction, aligning the UAE will with wills or estate instruments elsewhere, managing the filing and execution steps, and preparing in advance for probate, including representation in the relevant court and the recognition of foreign grants where assets sit abroad. Taking a single, coordinated view across jurisdictions is what reduces the risk of conflicting instruments, duplicated or delayed grants, and assets that cannot be released because a recognition step was missed.

Common pitfalls and how to avoid them

• Using an ineligible DIFC witness. DIFC witnesses must be at least 18 and must not be beneficiaries or guardians, or spouses of beneficiaries or guardians, named in the Will.
• Assuming a general authentication rule applies. Requirements for foreign documents depend on the document, issuing country and authority involved and should be checked for the specific process.
• Using the wrong language or format. ADGM wills must be bilingual Arabic-English and certified by a UAE Ministry of Justice-licensed legal translator, while DIFC Wills must comply with the applicable DIFC Wills and Probate Registry Rules and Will form.
• Assuming the two services have the same territorial or probate effect. DIFC Will types have different asset scopes, while ADGM Courts provides notarisation rather than a separate ADGM probate regime.

Conclusion and next steps

For UAE succession planning, the DIFC and ADGM routes should not be treated as equivalent registries. DIFC provides a dedicated Wills Service and probate framework for eligible non-Muslims, with the scope of the Will determined by the Will type selected. ADGM Courts provides an ADJD-authorised service for notarising eligible non-Muslim wills, with probate handled through ADJD rather than ADGM Courts. The appropriate route should be determined by eligibility, asset coverage, guardianship requirements, post-death procedure and any foreign-law issues affecting assets outside the UAE. Current forms, fees and procedural requirements should be verified with the relevant authority before proceeding.

This article is provided for general informational purposes only and does not constitute legal advice. The information is subject to changes in applicable laws and regulations. Professional legal advice should be sought in relation to specific circumstances.