Guide · updated 02.09.2026 · 15 min read · Lucent Legal team

Dubai Courts Will vs DIFC Will: What Heirs in Russia Will Actually Receive

You registered a will with the Dubai Courts notary, and now someone tells you your children will struggle to inherit under it. That is close to the truth. The will is valid, but your executors will enforce it through the onshore Dubai court, in Arabic, over several months.

What happens with no will, and where citizenship comes in

With no will, a non-Muslim's UAE assets are split by civil law, not Sharia. That is Federal Decree-Law No. 41 of 2022 on Civil Personal Status, in force since 1 February 2023. The formula is short: half to the surviving spouse, half split equally among the children. Abu Dhabi runs its own Law No. 14 of 2021 on personal status for non-Muslim foreigners in parallel, and wills there go into the ADJD register.

A Russian national can ask the court to apply the law of his home country instead of the UAE civil regime. There are two ways to do it. Lock the choice into a registered will in advance, or prove Russian law in court afterwards, with an expert opinion, translations and legalisation. The second route takes longer and guarantees nothing.

The full breakdown of default shares by family composition is in our guide on inheritance in the UAE without a will.

A Dubai Courts will: price, Arabic, and what comes next

A notarial will (wasiyya) is attested at the Dubai Courts notary public. The published fee is AED 2,000 per non-Muslim will, plus AED 20 in Knowledge and Innovation fees, plus AED 100 per signature if the notary enters the data. Law firms quote the total as AED 2,167 for a single will and AED 4,334 for a mirror pair.

The document is drafted in Arabic, or bilingually with a certified translation. That is the first source of trouble for heirs: any later argument will turn on the wording of the Arabic text.

Then comes probate. The executor applies to the Dubai court for an estate administration order. The court verifies the will, the death, the list of assets, and confirms the administrator. Proceedings run in Arabic under the onshore civil procedure. Lawyers put this at three to six months with a registered will, and a year or more without one.

Heirs do not have to fly in. They need a power of attorney for a representative, and every Russian document behind it has to be legalised. The UAE is not a party to the Hague Apostille Convention, so full consular legalisation applies. Both chains are set out in our guide to document legalisation between the UAE and Russia. Throughout all of it, the deceased's accounts stay frozen.

The DIFC Wills Service Centre: types and 2026 fees

The DIFC Wills Service Centre is a will register attached to the DIFC Courts, running on common law and in English. There are six will types, and the price depends on what you are covering. The official DIFC Courts price list, single document and mirror pair:

• Full Will — AED 10,000 and AED 15,000.
• Property Will — AED 7,500 and AED 10,000.
• Guardianship, Business Owners, Financial Assets, Digital Assets Will — AED 5,000 and AED 7,500 each.

A non-refundable booking fee sits on top: AED 500–2,000 depending on type, credited against the final amount. Modifying a registered will costs AED 550 plus AED 55 for the appointment. Withdrawal carries no fee on the current price list.

One limit hides in the small print. Guardianship clauses only work for minors habitually resident in Dubai or Ras Al Khaimah. The registration process is covered step by step in our DIFC will guide, and the price comparison with ADJD and the notarial route is in how much a will costs in Dubai.

DIFC probate and Dubai Law No. 2 of 2025

Executors file an application for a Grant of Probate at the DIFC Courts Registry. The case gets a dedicated Case Progression Officer. A lawful attorney can file on the executors' behalf, so nobody has to fly to Dubai. Lawyers describe the process as roughly a month; the DIFC Courts publish neither a target timeline nor a probate fee.

The big change is Dubai Law No. 2 of 2025 on the DIFC Courts, issued on 3 March 2025. Article 31(5) gives the DIFC Enforcement Judge jurisdiction over the enforcement of non-Muslim wills registered in the DIFC. Whether the asset sits inside or outside the DIFC no longer matters.

One honest caveat. The official DIFC probate page still describes the older route: the grant is converted into a Dubai Courts judgment, and the Execution Department then instructs the Dubai Land Department, free zone authorities and banks. Ask the Registry how your own case will run.

Outside Dubai the picture shifts. DIFC is built around Dubai and Ras Al Khaimah. An ADJD will in Abu Dhabi is recognised by courts in all seven emirates, which matters if assets are scattered across the country.

Side by side: Dubai Courts vs DIFC

Two wills at once: allowed, with one condition

Nothing stops you from holding both a Dubai Courts notarial will and a DIFC will. The danger sits elsewhere: a later will can be read as revoking an earlier one. So each document should state plainly which assets it covers and that it does not revoke the others.

The same rule applies to the pairing with a Russian will. Cross-border estate lawyers recommend a separate document per jurisdiction with an explicit territorial clause. That pairing is unpacked in our guide on inheritance between Russia and the UAE.

The simpler answer is not to accumulate paper. Keep one working document for UAE assets and revoke the old will.

Russia: what gets recognised there, and does a Russian will work here

Russia and the UAE have no treaty on legal assistance in civil matters. The Russian Ministry of Justice lists three treaties with the UAE, and all three are criminal: legal assistance in criminal matters, extradition, and transfer of sentenced persons. Civil and commercial matters are absent from the list.

So judgments travel on reciprocity rather than treaty, and reciprocity has to be proved case by case. Lawyers who work this route call it difficult and advise planning around the reality rather than the theory.

For an estate this hurts less than it sounds. Russian assets are handled by a Russian notary anyway, and he needs no UAE court order. The deadline there is hard: six months from the date of death.

The reverse direction is worse. A Russian will over a Dubai apartment is not a working instrument by itself. The UAE court will want a legalised translation plus expert proof of Russian law — exactly the long road you were trying to avoid.

Children, guardianship and bank accounts after a death

If both parents die, the children go to whoever you nominated in advance. A DIFC Guardianship Will lets you appoint an interim guardian and a permanent guardian. The interim guardian lives nearby and steps in immediately; the permanent guardian can live anywhere in the world. The DIFC Courts then issue guardianship orders following your instructions.

The same limit applies: guardianship clauses cover minors habitually resident in Dubai or Ras Al Khaimah. The difference between custody and guardianship is covered in our guide to child custody in the UAE.

Accounts freeze either way. The bank blocks them the moment it learns of the death, and a joint account offers no protection. Lawyers describe one case where a widow spent five months locked out of roughly a million dirhams. A will does not cancel the freeze; it shortens the wait for the order that lifts it.

The unfreezing process is in our guide on frozen accounts after a death, and what happens to the apartment is in inheriting property in the UAE.

What to redo, and in what order

1. List your UAE assets. Property, accounts, company shares, crypto. The mix decides the will type and the price.
2. Settle the applicable law question. If you want Russian law to govern the split, it goes into the will's text — not into a court argument years later.
3. Register the right DIFC will type. One apartment only: a Property Will at AED 7,500. Everything plus children: a Full Will at AED 10,000.
4. Handle guardianship separately if the children live in Dubai or Ras Al Khaimah — inside the Full Will or as a standalone Guardianship Will.
5. Revoke the Dubai Courts notarial will, or expressly limit it in the new document. Two competing wills are a ready-made dispute.
6. Make a Russian will for Russian assets, stating that it does not revoke the UAE document.
7. Leave your heirs instructions: where the will sits, who the executor is, and which lawyer to call on day one.

Topic: UAE Inheritance & Wills for Non-Muslims 2026

This material is for information only and is not legal advice. UAE law changes — a lawyer will assess how it applies to your situation.