Map the jurisdictions
First call. Which countries hold what, where you are domiciled, and which of your existing documents are doing anything.
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Islamic wills for families whose assets are not all in one country
Fara'id shares, a property abroad and a wallet nobody can open are three separate problems. Solved separately they contradict each other. This is the practice that treats them as one estate.
Short answer
A single English will rarely carries a Muslim expat estate. Land abroad obeys the country it sits in. UAE assets cannot be handled by a DIFC will if you are Muslim, because that service is open to non-Muslims only. Cryptoassets, on the current English approach, follow your domicile rather than any country, which makes them the one part where fara'id applies cleanly. Getting all three right means one coordinated set of documents, not three unrelated ones.
Why this combination fails so often
Take a family that is not unusual: British-domiciled, a house in Manchester, an apartment in Dubai, land inherited in Pakistan, a pension, and a hardware wallet in a drawer. They want their estate distributed according to fara'id.
They do what they are told to do. They make an English will. Someone mentions a DIFC will for the Dubai property. A cousin handles the Pakistani land. The crypto is not mentioned to anybody because it does not feel like part of the estate.
Every one of those steps is reasonable. Together they produce an estate that cannot be administered.
Where each asset actually goes
| Asset | Which law decides | What usually goes wrong |
|---|---|---|
| UK house, UK accounts | English law. Your will governs. | Little, if the will is current and formally valid. |
| Land abroad | The law of the country where it sits. | Forced heirship, or a local court that will not read an English will. |
| UAE assets (Muslim owner) | UAE federal law and Shariah, onshore. | A DIFC will is registered and later found to be unavailable to Muslims. |
| Foreign bank and investment accounts | Situs and the provider's own release rules. | Institutions that want a local grant, or a sealed and notarised English one. |
| Cryptoassets | Unsettled. On the current approach, your domicile. | Not the law. The keys. |
The Dubai trap
This is the single most common and most expensive mistake in this group, and it is almost never mentioned in the material aimed at expats.
The DIFC Wills Service, and the equivalent in Abu Dhabi Global Market, exist so that expatriates in the UAE can have their estates administered under common law principles rather than Shariah. They are genuinely useful. They are also open to non-Muslims only.
A Muslim expat who registers a DIFC will, or who is advised to, has not solved their UAE position. UAE assets are dealt with onshore, under Federal Law No. 5 of 1985 as amended and the framework now sitting alongside it in Federal Decree-Law No. 41 of 2024, which allows non-citizens to apply their home country law in some circumstances as permitted at Emirate level. That is a real option, and it needs to be exercised deliberately rather than assumed.
If you are Muslim and you hold UAE property, check what you actually have. If somebody sold you a DIFC will, it does not cover you. This is worth confirming before anything else on this page.
The crypto paradox
Cryptoassets behave differently from everything else in the estate, and in a way that happens to help.
There is no settled rule for where a cryptoasset is located. The question reached the English court in Ion Science Ltd v Persons Unknown (unreported, 21 December 2020), where, drawing on Professor Andrew Dickinson's analysis, the judge treated the lex situs as the place where the owner is domiciled. That was an interim decision made without the other side present, and the court put it no higher than a serious issue to be tried. It is a direction of travel, not settled law.
But if that approach holds, the consequence for this family is useful. Their crypto is not sitting in Dubai or Karachi. It travels with their domicile. A UK-domiciled testator can direct a fara'id distribution of it under English testamentary freedom, without any foreign forced-heirship rule cutting across.
So of the three parts of the estate, the crypto is the one where the religious distribution can be applied most cleanly.
It is also, by a distance, the one most likely to be lost outright. The Property (Digital Assets etc) Act 2025 confirmed that a digital thing can be personal property in England and Wales. It did not give anybody the password. A perfectly drafted fara'id gift of a wallet nobody can open distributes nothing.
The 1975 Act, addressed honestly
Under fara'id, a widow with children takes one-eighth. English law does not object to that. The Inheritance (Provision for Family and Dependants) Act 1975 sits alongside it, and allows a spouse, a former spouse, a child, a cohabitant of two years or more, or anyone the deceased was maintaining, to claim that the will did not make reasonable financial provision for them.
The claim exists regardless of the beliefs of the person bringing it, and regardless of whether the distribution was religiously correct. A widow who was financially dependent, and who receives one-eighth of an estate whose main asset was the family home, is exactly the fact pattern these claims are built on.
It is manageable. It is managed at the drafting stage, by looking honestly at who could claim, providing for them within the structure where possible, and recording the reasons where it is not. A will drafted as though the 1975 Act does not exist is the one that ends up litigated.
What a working structure looks like
- One coordinated set of wills, not several independent ones. An English will limited expressly to English assets, plus local wills where foreign land requires them, each confined to its own territory so the revocation clauses cannot collide.
- The fara'id shares drafted as gifts. Calculated by your own scholar or institution, then written as dispositions that a probate registry can actually execute.
- A 1975 Act analysis on the file. Who could claim, what they receive, and why.
- A digital asset schedule. What exists and where, with no keys or seed phrases in it. A will becomes a public document once probate is granted.
- An access route for the crypto that survives you. A design decision, not a legal one, and one that has to be tested rather than assumed.
- Executors who know. That they are executors, that the estate crosses borders, and where the schedule lives.
Start with the free score. The Estate Vulnerability Score covers jurisdiction, drafting, Shariah intention and digital access in twelve questions, and gives you the full written report on screen. If you are in this group it will usually flag several of the issues above by name. Get your score.
How we work on this
Draft what is missing
The English will, the schedule, the access architecture, and a brief for local counsel where a foreign will is needed.
Islamic wills →Refer what is not ours
Contentious matters, tax advice and foreign drafting go to people who do that work. You get a name, not a shrug.
How we refer →Common questions
Can a Muslim expat register a DIFC or ADGM will?
No. Both the DIFC Wills Service and the ADGM equivalent are open to non-Muslims only. This catches families out constantly, because almost every article written for Dubai expats recommends a DIFC will without mentioning the restriction. A Muslim expat with UAE assets registers onshore instead, through the Dubai Courts or the relevant judicial department, where UAE federal law and Shariah apply.
Does my English will cover my flat in Dubai or my plot in Karachi?
Not automatically, and usually not at all. Land follows the law of the country where it sits. An English will can be evidence of your wishes, but the local court decides under local rules. Most families with foreign land need a second, locally valid will, drafted so that the two documents do not revoke one another.
Is a fara'id distribution valid under English law?
Yes. England and Wales has testamentary freedom, so you may direct your estate in fara'id shares. The requirements are practical rather than religious: the will must satisfy the Wills Act 1837 formalities, and the shares must appear as actual gifts rather than as a statement of intention. A will that says \u2018my estate should be distributed according to Islamic law\u2019 and stops there is a wish, not a disposition.
Where does my cryptocurrency go?
Probably with you rather than with any country. There is no settled rule, but the English court in Ion Science Ltd v Persons Unknown treated a cryptoasset as located where its owner is domiciled. If that approach holds, a UK-domiciled Muslim\u2019s crypto passes under English law, and English law lets you direct fara'id shares. It is the one asset class in a cross-border Muslim estate where the religious distribution can be applied cleanly. It is also the one most likely to be lost entirely.
Will a Shariah-compliant will be challenged?
It can be, and the usual route is the Inheritance (Provision for Family and Dependants) Act 1975. A widow with children takes one-eighth under fara'id. If she was financially dependent and one-eighth is not reasonable provision on the facts, she has a statutory claim regardless of what the will says and regardless of her own beliefs. This is manageable, but only if it is addressed while the will is being drafted.
Do you decide the religious shares?
No, and we say so plainly. Where a share turns on a point of jurisprudence we work from the determination of your own scholar or institution, then render it as enforceable English dispositions. iProbate does not issue rulings.
What is your Estate Vulnerability Score?
Twelve questions, two minutes, no account. Scored out of 100 with the full written report on screen straight away: the jurisdictions, the forced-heirship traps and the digital assets your current arrangements will not carry across.