An Indian will can, in principle, cover assets anywhere in the world. But for clients with assets in the UAE, we generally recommend a second, locally registered will covering UAE assets only. For a non-Muslim Indian expatriate holding UAE property, bank accounts and investments, it is a small amount of work up front that removes a disproportionate amount of difficulty later.

The reason is procedural rather than legal. UAE inheritance rules for non-Muslims changed in 2023 and no longer default to Sharia, so the substantive outcome is usually not the concern. Recognition of the document is. A family relying only on an Indian will must have it authenticated by an Indian court, then legalised through the UAE embassy, attested locally and translated by a licensed legal translator. UAE bank accounts are typically frozen from the point the bank learns of the death until the estate is settled — realistically many months. A will registered with the DIFC or Abu Dhabi registry is handled directly by the local courts and usually resolves in weeks.

If you have children living in the UAE, there is a second reason: a registered local will is the only reliable way to appoint guardians. Without one, that decision sits with a UAE court.

Where clients run into trouble is with two wills cancelling each other out. Most templates open with a clause revoking all previous wills, and if that language survives into a UAE will it can void your Indian one. So the UAE will should be expressly limited to UAE assets, the Indian will re-executed to exclude them, and each should reference the other.

Given two legal systems are involved, we recommend a practitioner who handles India–UAE succession specifically. Note that this applies to non-Muslim clients — for a Muslim Indian national the position is materially different and needs separate advice.