Free Bahrain guide: what a Manama court needs from your will

Free guide for British expats in Bahrain

Bahrain sends a non-Muslim estate to your own national law.

A 17 page guide for British expats in Bahrain. It sets out the two 1971 statutes that send a non-Muslim foreigner's estate to the law of their own country, the drafting points that let a Bahraini court act quickly, and the UK inheritance tax rules that follow you to the Gulf. It also walks through the administration chain your executors would work through after a death.

17 pages
Updated August 2026
No payment details
Why Bahraini law points at your national law
Will options that work for British expats
Court steps, legalisation and UK inheritance tax
Why UK inheritance tax still reaches Gulf residents

Twenty minutes of reading that could save your family months at a Bahraini bank.

What happens to your estate

With a valid will

Article 21(6) of Legislative Decree No. 12 of 1971 refers the heirs of a non-Muslim, their shares and the devolution of the estate to the law of the deceased's country, and Legislative Decree No. 11 of 1971 repeats that reference for the estates of non-Muslim foreigners. GOV.UK's family law guidance for Bahrain, updated in February 2026, says the court will distribute assets according to the will whether it was issued in Bahrain or abroad. Under Article 5 of Decree-Law 11/1971 the court must confirm a liquidator the deceased appointed, so naming one gives the court an appointment to ratify rather than construct.

Without a will

English intestacy would still decide who inherits, because the reference in Article 21(6) does not switch off when there is no will, but your family proves entitlement from scratch. Somebody in the UK applies for letters of administration before the Bahraini chain begins, the court appoints a liquidator rather than confirming your choice, and the accounts stay frozen meanwhile. English intestacy also does less than most people assume: a surviving spouse does not automatically take everything where there are children, and an unmarried partner takes nothing.

Outside your will entirely

Bank of Bahrain and Kuwait's published terms stop any drawing on a joint account when one owner dies, and the survivors carry a ten day duty to notify. Group life cover, which most banking and energy employers carry, usually pays a nominated beneficiary outside the estate, and the nomination is often a decade old. Article 94 of the Labour Law, Law No. 36 of 2012, apportions compensation for a death caused by an employment injury in accordance with the rules of sharia inheritance, and the guide flags how that reads for a non-Muslim as a question for Bahraini counsel.

With a valid will

Without a valid will

Assets outside the will

Key facts

BD 5 The Survey and Land Registration Bureau charges BD 5 per transaction plus BD 1 for the form to register property by inheritance, against 2% of the value to register a sale. Buying is where the money goes, inheriting is where the time goes.
Two months Under Decree-Law 11/1971 the liquidator calls on creditors and debtors by public notice to state their rights within two months, and the wills are executed once the debts are settled. That period is in the statute, unlike the practitioner estimates of three to six months for a foreign heirship certificate.
3 to 10 years UK inheritance tax has followed long-term residence since 6 April 2025, and after leaving the UK a tail of three to ten years keeps you within it on worldwide assets. The length depends on how many of the previous 20 tax years you were UK resident.
BD 5 Why it matters. Registering an inherited property costs BD 5 plus BD 1 for the form, so it is the waiting that hurts, not the fee.
Two months Why it matters. Your executors wait two months while the liquidator advertises for creditors, because wills are executed only once the debts are settled.
3 to 10 years Why it matters. UK inheritance tax follows you for three to ten years after you leave, depending on your recent record of UK residence.

What is inside the guide

Wills and estate planning for British expats in Bahrain How Bahrain's written law treats a British estate, what your will needs to say for a Manama court to act on it, and what your family would face at the bank and the land registry. Free download · 2026 edition · 17 pages

Common questions

Do I need a separate Bahraini will as well as my English one?

GOV.UK's family law guidance for Bahrain says the court will follow the will whether it was issued in Bahrain or abroad, so there is no need to re-execute locally. Notarising in Bahrain is possible for non-Muslims but nowhere stated to be compulsory, and it adds nothing to validity. If you do hold two documents, they must be drafted to acknowledge each other, because most professionally drafted wills open by revoking all earlier wills and the second can quietly cancel the first.

Do I need a separate Bahraini will as well as my English one?

GOV.UK's family law guidance for Bahrain says the court will follow the will whether it was issued in Bahrain or abroad, so there is no need to re-execute locally. If you do hold two documents, they must be drafted to acknowledge each other, because most professionally drafted wills open by revoking all earlier wills.

Is it really free?

Yes. No payment details, no trial, no catch. The guide shows you how we think before you decide whether to use us for anything.

Will you fill my inbox?

We send the guide, and nothing else unless you tick the box for the email series. Every email in it has an unsubscribe link that works first time.

Is this legal advice?

No. The guide is general information for British expats, written in plain English. Expat Legacy is a will writing service rather than a law firm.

About the author

Jamie Lee, founder of Expat Legacy, has drafted more than 2,000 wills for British expats. He has lived the expat life himself since 2004.

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