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International family law

French couples separating in the UAE: the first questions to ask

10 October 2026 · 5 min read

Where to file, which law will apply, and will the decision be effective in the other country? A few landmarks to decide with clarity rather than in a rush.

One separation, two legal systems

When a French couple lives in the United Arab Emirates, a separation immediately brings two legal systems into play. French law often remains applicable or relevant, while the UAE courts may also have jurisdiction because of the couple's residence.

The first mistake is to act quickly and alone, without measuring the consequences of choosing the country where proceedings will be brought.

Which court?

Jurisdiction depends in particular on the spouses' nationality, their habitual residence and, where relevant, the children's residence. Several courts may have jurisdiction at the same time: the choice is not neutral, as it shapes the applicable law, timeframes and how the decision will later be recognised.

Which law will apply?

Since 2023, the UAE has had a civil personal status framework for non-Muslims, which has significantly changed divorce for expatriates. At the same time, French and European private international law may point to a different law.

Understanding how these interact helps anticipate questions of maintenance, children's residence and division of assets.

A decision must work in both countries

A judgment obtained in one country does not automatically produce all its effects in the other. Recognition and enforcement follow their own conditions, which must be built into the strategy from the outset — especially when assets or children are located in both countries.

What you can do now

Gather key documents (marriage certificate, any marriage contract, residence permits, financial information), avoid any unilateral decision regarding the children, and take stock before starting proceedings.

A strategic legal consultation provides a 360° view of the situation. Where action before the UAE courts is required, it is coordinated with duly authorised professionals.

This article is for general information only and does not constitute legal advice. Every situation requires a personalised analysis.