In May 2015, the Dubai International Finance Centre (DIFC) established itself as the first jurisdiction in the MENA region to allow for non-Muslim individuals to register a Will under internationally recognised common law principles under the DIFC Wills and Probate Registry Rules (the 'Rules').

In 2019, the DIFC Wills Service Centre announced the DIFC Wills and Probate Registry Rules, which brought about some changes and the most significant was that Non-Muslims were now permitted to include all of their assets from around the world in a DIFC Will. However, the guardianship provisions in DIFC Wills continue to be valid only for minors habitually residing in either Dubai or Ras Al Khaimah.

The current law in the Emirate of Dubai is Dubai Law No. 15/2017 On the Administration of Non-Muslims' Legacy and the Execution of Their Wills in the Emirate of Dubai and outside of the DIFC free zone.