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Fifteen months after Federal Decree-Law No. 41 of 2024 took effect, the reform has handed international families in the UAE more control over their own legal affairs than they have ever had. The families benefiting most are the ones putting their choices on paper.
When the UAE’s rewritten Personal Status Law came into force on 15 April 2025, most of the attention went to the headline changes: custody for both parents until a child turns 18, up from the previous thresholds of 11 for boys and 13 for girls, a child’s right at 15 to choose which parent to live with, and fines of AED 5,000 to AED 100,000 for offences including travelling abroad with a child without consent.
The provision with the widest reach sits further down the text.
The clause doing the quiet work
Couples can now elect which country’s law governs their marriage and any future divorce. If no election is made, UAE law applies. The law took effect immediately, applying its modernised provisions including to cases already underway.
The election is available to Muslim and non-Muslim residents alike, across marriage, divorce, custody and inheritance, a degree of flexibility few jurisdictions anywhere offer international residents. British families, for example, can keep English principles of financial fairness and sharing if they choose to. The couples who are surprised later are the ones who assumed their home law follows them automatically. It never has, anywhere. What is new is that the UAE now lets them choose.
The corridor keeps filling
The population gaining that choice is growing fast. The United Kingdom was projected to lose 16,500 millionaires in 2025, the largest single-country outflow ever tracked, according to Henley & Partners’ Private Wealth Migration Report. The UAE sat at the other end of the flow, attracting a net inflow of roughly 9,800 millionaires with an estimated USD 63 billion in associated wealth, its fifth consecutive year as the world’s top destination.
The 2026 edition of the report projects 165,000 millionaires relocating internationally this year, up from a record 142,000 in 2025. Henley describes the UAE story as one of diversification and optionality rather than exodus, and the new law fits that picture: every arriving family now lands with a choice of governing law that the previous generation of expatriates never had.
Money moves up the queue
The financial provisions carry their own weight. The law allows a wife to claim maintenance backdated up to six months, ranks alimony and child support ahead of other debts in court proceedings, and prohibits the sale or lease of jointly owned assets without the other spouse’s written consent.
For banks, family offices and anyone lending against assets held by married couples in the UAE, that ordering matters: a spousal maintenance claim can now sit ahead of a commercial creditor, a deliberate strengthening of protection for spouses and children that wealth advisers in the region are adjusting to.
The will that doesn’t travel
The same principle, choose deliberately and choose early, runs through estate planning, and it is where practitioners on the corridor are most direct. Samara Iqbal, founder and managing partner of Aramas International Lawyers, a family and matrimonial finance firm working across the UK and the UAE from its base in Abu Dhabi Global Market, and ranked by Chambers in both jurisdictions, has warned publicly that expatriates routinely overestimate what their home country will can do for them.
“The sad reality is there is a high possibility that it won’t work here,” Iqbal said of relying on a foreign will in the UAE. “It is highly advisable that you get a UAE will done here in one of the appropriate courts, with the documents registered, and make sure everybody knows you also have a UAE will alongside the home country will. People have different wills for different jurisdictions.”
The registries suggest the message is landing. The DIFC Courts Wills Service registered 922 wills in the first half of 2025, up 14 per cent year on year, taking total registrations past 13,400 since the service launched, according to figures reported by law firm Motei & Associates. Dubai Law No. 2 of 2025 has since given the DIFC exclusive probate jurisdiction over its registered non-Muslim wills, and Abu Dhabi Global Market operates a parallel common-law registry, giving residents a choice of platforms depending on where their assets sit. The infrastructure is built and growing. The opportunity for arriving families is simply to use it early.
Choice is the reform’s real gift
That is the thread running through the law’s first year. Every cross-border family in the UAE now has more say over the law governing its marriage, its money and its estate than in almost any jurisdiction they could have moved to. The reform built the options. Putting them on paper is the one step it leaves to families, and the ones moving early are getting the full value of what the UAE has built.
