Writing a Will as an Expat in Bahrain (2026) — Manama Estate Planning Guide

Bahrain is the most liberal and internationally integrated of the Gulf Cooperation Council (GCC) states. The island nation has long been a hub for international finance, hosting the Bahrain Financial Harbour and a dense cluster of international banks, asset managers, and professional service firms. Its social environment is notably more relaxed than its Gulf neighbours, and its regulatory framework has repeatedly demonstrated a willingness to accommodate international residents and business.

Nowhere is this more apparent than in estate planning. In 2017, Bahrain enacted Law No. 26 of 2017 on Non-Muslim Personal Status — a landmark piece of legislation that explicitly allows non-Muslim expatriates to have their succession matters resolved according to their home country's law rather than Sharia. This makes Bahrain the most progressive country in the Gulf for non-Muslim expat estate planning.

But the existence of a good legal framework only helps if you use it. Thousands of expats in Bahrain have never registered a will and remain exposed to default Sharia succession rules. This guide explains what Bahrain's law provides, how to register a will at the NLSC, and what practical steps every expat in Bahrain should take.

Bahrain's Non-Muslim Succession Law: Law No. 26 of 2017

Law No. 26 of 2017 on Non-Muslim Personal Status (Qanun al-Ahwal al-Shakhsiyya li-Ghair al-Muslimin) is one of the most significant pieces of expat-friendly legislation enacted in the Gulf in recent years. Its key provisions for succession purposes:

• Choice of law: Non-Muslim residents of Bahrain may elect to have their succession governed by the law of their nationality (home country) rather than Sharia.
• Will registration: Non-Muslims can register a will with the Non-Muslim Legal Services Centre (NLSC) at the Ministry of Justice. A registered will is enforceable in Bahraini courts.
• Full testamentary freedom: Unlike Sharia, which limits the bequest (wasiyya) to one-third of the estate, a non-Muslim's registered will under Law 26 can dispose of the entire estate freely.
• Court administration: The NLSC has its own dedicated court procedures for non-Muslim succession and family law matters.

Compared to Kuwait (which provides a general court mechanism for non-Muslim wills without a dedicated legal framework), Oman (which relies on Ministry of Justice registration without a specific non-Muslim law), and Qatar (which only recently added QFC-based will mechanisms), Bahrain's approach is significantly more robust and comprehensive.

The Non-Muslim Legal Services Centre (NLSC)

The Non-Muslim Legal Services Centre (NLSC) is a dedicated unit within Bahrain's Ministry of Justice, Waqf and Islamic Affairs, established specifically to serve non-Muslim residents. Located at the Ministry of Justice in Manama, the NLSC handles:

• Registration of wills for non-Muslims
• Succession proceedings for non-Muslim decedents
• Divorce and family law matters for non-Muslims

The NLSC is staffed by professionals experienced in working with international residents and will assist with the will registration process in English. Contact details and appointment booking are available through the Ministry of Justice website.

How to Register Your Will at the NLSC

1. Prepare your will: Draft a will in English (or Arabic, or bilingual) that meets the formal requirements of your home country's law. For UK expats, this means a will signed in the presence of two independent witnesses; for US expats, state-specific requirements apply. Consult an international law firm in Manama for assistance with structuring.
2. Notarise the will: Have the will certified by a Bahraini notary or by a lawyer at a registered law firm in Bahrain.
3. Register at the NLSC: Submit the notarised will to the NLSC for registration. Pay the applicable registration fee (modest — typically BHD 50–100).
4. Receive confirmation: The NLSC will provide confirmation of registration. Keep this document and the original will in a secure location.
5. Inform your executor: Ensure your executor (and key family members) know the will is registered with the NLSC and have the registration details.

Manama's Bahrain Financial Harbour and the surrounding business district host numerous international law firms — including Al Tamimi & Company, Trowers & Hamlins, and Eversheds — that regularly assist expats with NLSC will registration.

Property Ownership in Bahrain

Unlike Kuwait and Qatar, Bahrain has actively opened its property market to foreign ownership. Non-Bahraini nationals may own freehold real estate in a number of designated areas, including:

• Amwaj Islands — a popular waterfront development
• Reef Island
• Juffair — the most expatriate-dense residential area in Bahrain, adjacent to the US Naval Support Activity base
• Seef District
• Bahrain Financial Harbour
• Other designated areas under the Foreign Real Estate Ownership Law

For non-Muslim expats with freehold property in Bahrain, this property can be fully devised by a will registered under Law No. 26 of 2017. This is a significant advantage over Kuwait, where there is essentially no expat property to plan for, and Oman, where expat property ownership is limited to ITC zones with no dedicated non-Muslim succession framework.

End-of-Service Gratuity in Bahrain

Bahrain's Labour Law (Legislative Decree No. 36 of 2012) provides for end-of-service indemnity for employees who complete one year or more of service. The indemnity rate is:

• Half a month's pay per year for the first three years
• One month's pay per year for each subsequent year

On death, this indemnity forms part of the estate. For non-Muslim expats with a registered will under Law No. 26 of 2017, the indemnity can be directed to whomever the will specifies. Check your employment contract for any nominee provisions and confirm with your HR department that the NLSC will registration is reflected in their records.

Bahrain vs the Rest of the Gulf: An Estate Planning Comparison

To understand why Bahrain's position is so valuable, a quick comparison:

• Bahrain: Dedicated Non-Muslim Succession Law (Law 26/2017), NLSC court system, full testamentary freedom, covers all assets in Bahrain including freehold property, bank accounts, and EOSB. Most comprehensive non-Muslim framework in the Gulf.
• UAE: DIFC Wills Service Centre (for DIFC-employed expats and those with qualifying assets) and ADGM Wills (Abu Dhabi Global Market). Excellent for their specific jurisdictions but not comprehensive for all UAE assets.
• Qatar: Ministry of Justice will registration for non-Muslims; QFC will system for QFC-employed expats. Two-track system, less integrated than Bahrain.
• Oman: Ministry of Justice registration; no dedicated non-Muslim succession law. Useful but not as legally robust as Bahrain.
• Kuwait: Court/Ministry of Justice registration; no dedicated legal framework; no freehold property for expats. Most limited of the major Gulf states.
• Saudi Arabia: Very limited options for non-Muslim will registration; the most restrictive Gulf jurisdiction for non-Muslim succession.

Practical Steps for Expats in Bahrain

1. Engage an international law firm in Manama to draft and register a will under Law No. 26 of 2017 at the NLSC.
2. Use ExpatLegalWills to structure your home-country and international estate plan before meeting with local counsel.
3. Register your Bahraini property ownership if not already done and ensure the title documents identify you clearly as the owner.
4. Check your EOSB and pension nominee designations with your employer.
5. Review your bank account structure — ensure your spouse or dependants have access to emergency funds.
6. Confirm your home-country tax position — UK IHT and US estate tax may apply to your worldwide assets including your Bahrain apartment and bank accounts.

Frequently Asked Questions