Filipino with assets in the UAE: how Philippine law and a UAE will fit together
A Filipino working in Dubai or Abu Dhabi may hold savings, a car or a property in the UAE and family in the Philippines. Two legal systems can speak to the same estate. Here is what each publishes and where a lawyer is needed.
A UAE will can be registered by a Filipino, but the Philippine Civil Code also has its own rule for succession, so the two need to be read together. The Code states that succession is regulated by the national law of the person whose estate it is. UAE registries publish who may register a will and what it covers. Whether one overrides the other for your estate is a lawyer's question, not one this page can settle.
Can a Filipino in the UAE register a will there?
Yes, at either of two registries, depending on your religion and your assets. They ask different questions.
- DIFC Courts (Dubai) publishes that a person may register a DIFC Courts Will if they are at least 18, are not Muslim and have never been Muslim, and own assets in the UAE or have minor children residing with them in the UAE. Residence is not a condition: the FAQ states "You do not need to be a resident of the UAE to register a DIFC Courts Will."
- Abu Dhabi Civil Wills (ADJD) publishes a rule framed around citizenship, not religion. Its FAQ states: "If you are not a UAE citizen, then, regardless of your religion, you may register a Will with Abu Dhabi Civil Wills Office."
The distinction matters because most Filipino workers are not Muslim and qualify at DIFC, while a Filipino Muslim who cannot use DIFC has the Abu Dhabi route published for non-citizens of any religion. Our comparison of DIFC, Dubai Courts and Abu Dhabi wills sets the registries side by side.
Sources: DIFC Courts Wills FAQ · ADJD Civil Family Court
What does the Philippine Civil Code say about succession?
It sends succession to the deceased's national law. Article 16 of Republic Act No. 386, the Civil Code of the Philippines, states that intestate and testamentary successions "shall be regulated by the national law of the person whose succession is under consideration". Article 17 separately provides that the forms and solemnities of wills are governed by the laws of the country where they are executed.
Read plainly, the first rule points to Philippine law for a Filipino's succession, and the second points to the law of the place of signing for the form of the will. How a Philippine court, a UAE registry or a bank in either country applies them to a particular UAE will is a legal question. This page does not answer it, and we cannot.
That is the honest limit. What we can say is that both systems exist, that neither registry's published guidance says the other does not matter, and that a Filipino with assets in both countries should not assume one document settles both.
Source: Republic Act No. 386, Civil Code of the Philippines (Lawphil)
How do the two sides line up?
| Question | UAE registries publish | Philippine Civil Code | Who to ask |
|---|---|---|---|
| Who can register a will in the UAE? | DIFC: non-Muslims with UAE assets or minor children here. ADJD: any non-UAE citizen | Not addressed | The registry |
| What law governs succession? | Each registry publishes the rules it applies to the wills it registers | Article 16: the deceased's national law | A lawyer qualified in both |
| What about the form of the will? | DIFC: two witnesses, electronic signing, English required | Article 17: the law of the place of execution | The registry, then a lawyer |
| Can I sign from the Philippines? | DIFC: yes, virtually from any part of the world | Not addressed | DIFC Courts Wills Service |
| What if I make a second will abroad? | DIFC: allowed, but a poorly coordinated one could invalidate the registered will | Not addressed | A lawyer qualified in both |
What does DIFC publish about signing and witnesses?
The mechanics are specific, and they matter for a Filipino who is in the Philippines, or whose witnesses are.
DIFC Courts states that all registration appointments are booked through the Wills Service portal and are signed electronically, virtually or in person, in about 20 minutes. It requires two witnesses who are at least 18, hold a valid government-issued photo ID, and are not named as beneficiaries or guardians. They may attend virtually from anywhere in the world. Guardians and their spouses may not attend.
It also states that the service does not accept translators or a power of attorney at the signing, and that testators and witnesses must have a basic grasp of English. A will cannot be signed for you by an agent, so a power of attorney is no substitute for attending.
If the reason you are thinking about a will is a UAE property, a car or savings, the DIFC will service is where we prepare the document for that appointment, and the fees guide lists each authority's published charges with the date it was checked.
What about a power of attorney for family in the Philippines?
A will and a power of attorney do different jobs. A will takes effect on death. A power of attorney lets someone act for you while you are alive. If you need a relative in the Philippines to act for you, or need to act from the UAE for a Philippine matter, that is a separate document with its own chain. Our guides cover both directions: a power of attorney from the UAE for the Philippines and, for a document signed in the Philippines for UAE use, the Philippines-to-UAE route. The Philippine missions in the UAE publish their own notarial steps, which the first guide follows.
Frequently asked questions
Can a Filipino make a will in the UAE?
Yes, at DIFC Courts if not Muslim and holding UAE assets or minor children here, or with the Abu Dhabi Civil Wills Office if not a UAE citizen, whatever your religion.
Does a UAE will override Philippine law for my estate?
This page cannot say. Article 16 of the Philippine Civil Code points succession to the deceased's national law, and how that interacts with a UAE will is a legal question for a lawyer qualified in both systems.
Can I register a DIFC will from the Philippines?
Yes. DIFC Courts states that testators and witnesses may attend the appointment virtually from any part of the world and need not visit the UAE. You must attend yourself, with two eligible witnesses and enough English to sign without a translator.
Can my sibling sign the will appointment for me with a power of attorney?
No. The Wills Service states that it does not accept a power of attorney for signing appointments.
Do I need a Philippine lawyer as well?
If you hold assets or have heirs in both countries, advice from someone who knows Philippine succession law is sensible before you register. The Deedbox prepares documents and is not a law firm.