Non-Muslim families

Since 1 February 2023, the federal law on civil personal status has set the default for non-Muslim foreigners living in the UAE. Abu Dhabi has had its own law since late 2021. [1][2] Where there's no will:

Who survives Who inherits
Spouse and children Half to the spouse; half equally between the children, sons and daughters alike [1]
Spouse, no children Abu Dhabi's courts say the spouse keeps half and the rest goes to the parents. If only one parent is alive, that parent shares with the brothers and sisters. [1][3]
No spouse, children or parents Brothers and sisters, equally [1]

Any heir can ask the court to apply the law of the country the deceased belonged to instead, unless a registered will says otherwise. [1][8]

Assets owned jointly with a Muslim may still be subject to Shariah rules, according to the law firm Withers. [4]

Muslim families

For Muslims, inheritance follows the UAE's personal status law, in force since 15 April 2025. It sets fixed shares for each heir by their relationship to the deceased. A will can cover up to one third of the estate. More than that, or any gift by will to an heir, needs the other heirs' consent. [5]

A Shariah-compliant family foundation can be funded during the founder's lifetime through gifts (hibah). [12] Whether such a gift can later be challenged under the inheritance rules is not settled: in January 2021 the DIFC Court of Appeal declined to answer that question. [13]

Frozen bank accounts

UAE banks freeze a deceased person's accounts as soon as they are told of the death, joint accounts included, until a court order releases the money. [6] The UAE has no automatic right of survivorship, so jointly owned property doesn't pass straight to the surviving owner. [7]

A registered will makes this quicker. In Dubai, a registered will is carried out by a written order, while an unregistered one needs a court judgment. [9] Abu Dhabi's courts warn that having no registered will can delay the distribution of an estate. [3]

Estates with no heirs: the 2026 change

Since 1 June 2026, under the Civil Transactions Law, money in the UAE belonging to a foreigner who has no heir becomes a charitable endowment (waqf). Under the old law, it went to the State. [8][10]

How to plan ahead

  • A registered UAE will, for UAE assets. See Wills in Dubai and the UAE.
  • A will in your home country for assets there, worded so the two don't conflict.
  • A foundation or holding company, for property, businesses or investments that should pass in a particular way. See DIFC, ADGM or RAK ICC foundation?
  • Guardianship for young children. A DIFC will can name guardians for children living in Dubai or Ras Al Khaimah. [14]

How Marlborough Gulf helps

What we do:

  • We set out who would inherit each of your assets today, country by country.
  • We design the wills and structures that change it.
  • We coordinate the people who put it in place.

What others do: Law firms draft wills and legal documents, and a court registry registers the will. You appoint and contract with the law firm directly.

Book a consultation

Questions people ask

Is there inheritance tax in Dubai?

No. The UAE has no inheritance, estate or gift tax on individuals. Your home country may still tax your estate; see UK inheritance tax after you leave. [11]

Does Shariah law apply to non-Muslim expats in the UAE?

Not by default since 1 February 2023. The federal civil law applies instead: half to the spouse, half to the children. Joint assets with a Muslim may be treated differently. [1][4]

Can my family ask for my home country's law to apply?

Yes. An heir can ask the court to apply the law of the country you belonged to, unless a registered will says otherwise. [1][8]

How long are accounts frozen after a death?

Until a court order releases the money. A registered will shortens the process. [6][9]

What happens if I have no family at all?

Since 1 June 2026, a foreigner's money in the UAE with no heir becomes a charitable endowment, not State property. [8][10]

This guide is general information, not legal advice. Inheritance depends on your faith, nationality, family and assets. Take advice from a qualified lawyer.

Related guides

Sources

  1. Federal Decree-Law No. 41 of 2022 on Civil Personal Status, Articles 1(1), 11(2), 11(3) and 18 (in force 1 Feb 2023). https://uaelegislation.gov.ae/en/legislations/1586
  2. Abu Dhabi Law No. 14 of 2021, Abu Dhabi Official Gazette, 30 Nov 2021 (in force one month after publication, Article 20). https://www.abudhabi.gov.ae/-/media/sites/adgov/gazettes/2021/en/11english2021.ashx
  3. Abu Dhabi Judicial Department, Civil Family Court: civil wills and inheritance, questions 4 and 6, viewed 28 Oct 2026. https://www.adjd.gov.ae/en/Pages/CivilFamilyCourt.aspx
  4. Withers, "Estate planning for non-Muslims and residents in the UAE", 7 Oct 2024. https://www.withersworldwide.com/en-gb/insight/read/estate-planning-for-non-muslims-and-residents-in-the-uae
  5. Federal Decree-Law No. 41 of 2024, Personal Status Law, Articles 173, 184, 193 and 206 (in force 15 Apr 2025). https://uaelegislation.gov.ae/en/legislations/2770
  6. Gulf News, "Do UAE banks freeze accounts after death? What expats need to know", 22 Nov 2025. https://gulfnews.com/living-in-uae/banking/do-uae-banks-freeze-accounts-after-death-what-expats-need-to-know-1.500355572
  7. Kingsley Napley, "Dubai wills for British expats and non-Muslims: FAQs". https://www.kingsleynapley.co.uk/services/department/private-client/wills-succession-planning-and-trusts/dubai-wills-for-british-expats-and-non-muslims-frequently-asked-questions
  8. Federal Decree-Law No. 25 of 2025, Civil Transactions Law, Article 17(1) and (2) (in force 1 Jun 2026). https://uaelegislation.gov.ae/en/legislations/4011
  9. Dubai Law No. 15 of 2017 on the estates and wills of non-Muslims in Dubai, Article 18. https://dlp.dubai.gov.ae/Legislation%20Reference/2017/Law%20No.%20%2815%29%20of%202017.html
  10. Federal Law No. 5 of 1985, Civil Transactions Law (replaced), Article 17(2). https://uaelegislation.gov.ae/en/legislations/1025/download
  11. PwC Worldwide Tax Summaries, UAE: individual, other taxes, reviewed 9 Sep 2026. https://taxsummaries.pwc.com/united-arab-emirates/individual/other-taxes
  12. Ocorian with Ebdaa Islamic Finance Consultancy, "Shari'ah-compliant family foundations in the UAE", 25 Aug 2026. https://www.ocorian.com/knowledge-hub/insights/shariah-compliant-family-foundations-uae
  13. DIFC Courts, DIFC Authority [2020] DIFC CA 002, Court of Appeal judgment, 18 Jan 2021 (Question 9). https://edge.sitecorecloud.io/dubaiintern0078-difcexperie96c5-production-3253/media/project/difcexperiences/difc/difcwebsite/documents/familydocs/ca-002-2020-judgment---18-january-2021.pdf
  14. DIFC Courts, Full Will service page. https://www.difccourts.ae/difc-courts-wills/services/full-will