A DIFC or ADGM will lets a non-Muslim — including a Chinese national — choose their own heirs for UAE assets and appoint guardians for their children, instead of leaving the estate to default distribution; for cross-border families it is coordinated with succession in China.
Chinese families building a life and assets in the UAE often have careful succession arrangements at home but nothing in place for what they hold in Dubai or Abu Dhabi. That gap is precisely where problems arise. A registered DIFC or ADGM will closes it. Here is what the China Desk recommends families understand.
The problem a will solves
If a non-Muslim dies in the UAE without a registered will, their UAE assets can be distributed under default principles that may not match their wishes, and bank accounts and assets can be frozen while the estate is resolved — a difficult position for a family that may be split between the UAE and China. A registered will replaces uncertainty with a clear, enforceable plan.
What a DIFC or ADGM will is
The DIFC Wills Service (Dubai) and the ADGM (Abu Dhabi) offer registered wills for non-Muslims under common-law-based regimes. They allow you to leave your UAE assets to chosen beneficiaries on the basis of testamentary freedom, rather than default forced-heirship distribution. The will is registered, and on death is administered through the relevant DIFC or ADGM courts — a system designed to be predictable for international families.
Available to Chinese nationals
These wills are open to non-Muslims regardless of nationality, including Chinese nationals who own UAE assets — property, company shares, bank accounts or investments. UAE residence and your asset profile shape which will type and registration route fit best, which is part of what we advise on at the outset.
Guardianship of children
For families with children, the ability to appoint guardians — including interim guardians — is often the single most important reason to put a will in place. It gives clear instructions on who cares for your children if something happens while you are in the UAE, rather than leaving that decision to a court without guidance.
Coordinating with assets in China
A DIFC or ADGM will is designed to cover UAE-situated assets. Assets in mainland China remain governed by Chinese succession law and usually require separate, coordinated arrangements. The goal is a set of aligned wills or a coordinated plan across both jurisdictions that work together rather than conflict — and that coordination, in both languages, is exactly what our China Desk provides. It also fits naturally with the rest of a family's UAE planning: residency, wealth transfer and tax residence.
Business-owning families
Where the family owns UAE companies, the will should be paired with the corporate structure and any shareholders' arrangements, so that shares pass smoothly and control transitions cleanly. For business families, coordinating the will with the company structure is essential, not optional.
How we help
Neo Legal's China Desk advises Chinese families on the right will (DIFC or ADGM), guardianship, and the coordination of UAE and China succession, working with your structure and your China-side advisers — all in English and Chinese. 我们以中英文双语提供全程服务。
This article is general information as at June 2026 and is not legal advice. Succession outcomes depend on the will type, asset location and your circumstances; obtain advice for your situation in both jurisdictions before acting.
