For non-Muslim individuals owning assets in both the UAE and their home countries, estate planning often raises the question of whether a will prepared abroad can be legally enforced in the UAE. The UAE allows for the recognition of foreign wills under specific conditions, as outlined in the UAE Civil Procedures Code—particularly Articles 222 to 225 of Federal Decree-Law No. 42 of 2022. These provisions permit the enforcement of foreign judgments, including wills and probate orders, provided they meet the conditions of reciprocity, jurisdiction, due process, and public policy compliance.

To have a foreign will recognised in the UAE, the will must first be notarised and legally validated in the country where it was made. It must then be attested by the UAE embassy in that country. Upon arrival in the UAE, the will must be attested by the Ministry of Foreign Affairs and International Cooperation, translated into Arabic by a certified translator, and further attested by the Ministry of Justice. Once these formalities are completed, the will may be submitted to the relevant Personal Status Court in the UAE for enforcement, subject to judicial review and compliance with local legal standards.

However, foreign wills are not the only option available. Non-Muslims may opt to prepare a separate will within the UAE itself, governed by laws tailored to their personal status. These include Federal Decree Law No. 41 of 2022 on Civil Personal Status, Dubai Law No. 15 of 2017 on the administration of estates for non-Muslims, and the frameworks provided by the DIFC Wills Service Centre or the ADGM Courts. These mechanisms allow for direct registration of wills concerning UAE-based assets, providing a streamlined and locally recognised probate process.

In essence, while a foreign will can be enforced in the UAE if duly legalised and compliant with UAE procedural and public policy requirements, a locally registered will may provide greater certainty and efficiency. Individuals with cross-border assets are encouraged to consult legal advisors both in the UAE and in their home countries to ensure their estate planning is valid, enforceable, and aligned with their intentions.