About 50 countries incorporate Sharia into their legal systems in some form, but that single number hides an enormous range. How many countries follow Sharia law depends entirely on what “follow” means: a handful build their entire legal order on it, many more apply it only to family matters like marriage and inheritance for Muslim citizens, and others use it in specific provinces or for specific subjects while the rest of the country operates under secular law. Treating these as a single category misses almost everything that matters.
The Three Models That Explain the Count
The Federal Judicial Center, the research arm of the U.S. federal judiciary, sorts Sharia-applying countries into three broad groups based on how deeply Islamic law shapes the national legal system.1Federal Judicial Center. Islamic Law and Legal Systems These categories are more useful than a raw country total, because the label “Sharia country” stretches from Saudi Arabia’s comprehensive system to Indonesia’s use of Islamic courts for family disputes inside an otherwise secular framework.
In order of how extensively Sharia shapes the law, the three models are:
- Full or “classic” Sharia systems, where the state adopts Islamic law as the foundation for civil, criminal, and personal status matters, with judges deriving rulings from the Quran and Sunnah, sometimes without a formal written code.
- Dual systems, where secular or civil codes govern criminal and commercial law but Muslim citizens bring family matters to Islamic courts. This is the most common model worldwide.
- Regional or selective application, where Sharia applies in specific provinces, to particular subject areas like finance, or to certain religious offenses, while the rest of the country follows secular law.
Almost every country you might hear described as “following Sharia” fits into one of these three groups. Which group changes what the law actually looks like for people living under it.
Countries Where Sharia Is the Entire Legal System
A small group builds its entire legal order on Sharia. Saudi Arabia, Iran, and the Maldives are the clearest examples, where the state formally derives its criminal, civil, and personal status laws from Islamic legal principles.1Federal Judicial Center. Islamic Law and Legal Systems Afghanistan under Taliban rule also belongs in this category, though it was not always classified this way when a constitution referencing both Islamic and civil law was nominally in force.
Even inside this small group, “full Sharia” looks different in practice. In Saudi Arabia, Islamic law applies directly as the common law of the country. Judges historically operated without a formal written penal code, instead drawing on their training in the Hanbali school of jurisprudence to determine what counted as a crime and what punishment it carried. That has been changing. Saudi Arabia codified a Personal Status Law in 2022 and published implementing regulations in early 2025, part of a broader push to move from judicial discretion toward written legal standards.
Iran took a different path after its 1979 revolution. The constitution requires that all laws be based on Islamic criteria, and the Supreme Leader must be a qualified Islamic jurist.2University of Minnesota Human Rights Library. The Constitution of the Islamic Republic of Iran But Iran retained a codified legal structure heavily influenced by European civil law traditions, with written criminal and civil codes that judges are bound to follow. Where codified law is silent, judges turn to Islamic jurisprudence to fill the gap. Iran’s system follows the Jaʽfari school of Shia Islam, setting it apart from the Sunni-oriented systems in Saudi Arabia and most other countries on this list.
The Maldives bases its legal system on three primary sources: Sharia, the national constitution, and statutory law. Sharia is treated as the principal source, though the country also incorporates elements of English common law inherited from its colonial period.
Countries Where Sharia Governs Family and Personal Matters
The largest group of Sharia-applying countries uses Islamic law primarily for family and personal status matters while running criminal and commercial law through secular or civil codes. This dual-system model covers marriage, divorce, inheritance, child custody, and sometimes charitable endowments. Countries in this category include Egypt, Iraq, Jordan, Syria, Algeria, Morocco, Malaysia, Indonesia, and Bangladesh, among others.1Federal Judicial Center. Islamic Law and Legal Systems Gulf states like Bahrain, Kuwait, and the United Arab Emirates also fall here, applying Islamic law to personal matters while using civil or commercial codes for business and criminal law.
Bangladesh is a useful illustration. The country follows secular legal practices rooted in inherited British-era codes for criminal and procedural law, but applies Sharia to inheritance and marriage for its Muslim population, which makes up about 89 percent of the country. Jordan’s Iftaa Department issues rulings on inheritance and personal status based on Islamic jurisprudence, with the country’s Sharia courts handling these matters while secular courts take everything else.3Iftaa’ Department. According to the Personal Status Law (Jordan), Mandatory Will Applies to Ones Sons and Daughters of Sons
The UAE shows how the dual structure works in practice. Its constitution designates Sharia as “a main source of legislation” rather than “the source,” and the civil code directs courts to apply Sharia where statutory law is silent. But most commercial, criminal, and administrative law comes from codified statutes with roots in French and Egyptian civil law traditions.
What “Family Law Under Sharia” Actually Covers
Marriage in these countries requires a formal contract, not just mutual agreement. The contract includes a mahr, a dowry paid by the husband to the wife that remains her property. The specific terms, amount, and procedures vary based on which school of Islamic thought the country’s courts follow.
Divorce procedures differ by gender. A husband can initiate divorce through talaq, a unilateral declaration, though most countries now require that it be registered with a court or religious authority to take legal effect. A wife seeking divorce can pursue khula, which typically requires her to return the mahr or provide other financial compensation, or she can petition the court for a judicial dissolution if she can demonstrate grounds such as harm, abandonment, or failure to provide financial support. Saudi Arabia’s 2025 regulations expanded women’s ability to seek judicial annulment even where the husband refuses to grant a divorce or khula.
Countries Where Sharia Applies Regionally or Selectively
Some countries apply Sharia only in certain geographic areas or to specific legal subjects, creating a patchwork where the law you live under depends on where in the country you are.
Nigeria is the most prominent example. Twelve northern states adopted Sharia-based criminal and civil codes beginning in 1999, while the southern states and the federal system operate under secular law. In the northern states, Sharia courts handle criminal offenses and have occasionally imposed hudud sentences including amputation, though in practice these sentences are rare and appellate courts have overturned the most severe ones.
In the Philippines, the Bangsamoro Autonomous Region in Muslim Mindanao operates its own legal framework incorporating Sharia for the Muslim population.1Federal Judicial Center. Islamic Law and Legal Systems Indonesia, often described as a personal-status country, is actually a hybrid. Most of the country limits Sharia to family courts, but Aceh province applies Sharia to criminal matters as well, including offenses like gambling and alcohol consumption.
Brunei is another variation. The country runs a parallel legal system where secular common-law courts operate alongside Sharia courts. A Sharia Penal Code phased in starting in 2014 technically prescribes severe punishments including stoning and amputation for offenses like adultery, theft, and blasphemy. In practice, a longstanding moratorium on the death penalty has remained in place, and no capital or corporal punishments beyond caning have been carried out since 1957.4United States Department of State. 2021 Report on International Religious Freedom: Brunei The Sharia Penal Code in Brunei applies to both Muslims and non-Muslims, though non-Muslims are exempted from some provisions. In most other Sharia-applying countries, non-Muslims fall outside the jurisdiction of Islamic courts for religious offenses and use secular courts or special tribunals for personal status matters.
Why the Same Label Produces Such Different Systems
Sharia is not a single code that every Muslim-majority country downloads and applies. It is a body of principles derived from the Quran and the Sunnah, interpreted through centuries of scholarly reasoning. The variation in how countries apply it comes down to which interpretive tradition they follow, how much room they leave for judicial reasoning, and how deeply colonial-era legal systems reshaped their institutions.
The Four Sunni Schools and the Jaʽfari School
Sunni Islam, which accounts for roughly 85 to 90 percent of Muslims worldwide, recognizes four major schools of legal thought. Each takes a distinct approach to interpreting Islamic sources.
- Hanafi is the most flexible in its use of analogical reasoning and judicial opinion. Predominant in South Asia, Turkey, the Balkans, and parts of the Arab world.
- Maliki places significant weight on the practices of early Medina and incorporates local custom. Dominant in North and West Africa and parts of the Arabian Peninsula.
- Shafi’i emphasizes systematic legal methodology and the use of consensus. Prevalent in East Africa, Egypt, and Southeast Asia.
- Hanbali is the most text-focused, relying heavily on the Quran and Hadith with less room for analogical reasoning. Centered in the Arabian Peninsula, particularly Saudi Arabia.
These schools recognize each other’s legitimacy, but their rulings can differ on practical matters ranging from the requirements for a valid marriage contract to how inheritance is calculated for grandchildren. The school a country’s courts follow is one of the biggest determinants of what “Sharia law” actually looks like on the ground. Shia Islam has its own major school, the Jaʽfari, which predominates in Iran, Iraq, and parts of Lebanon and South Asia.
How Much Room for Independent Reasoning
Ijtihad is the process of independent scholarly reasoning used to address situations not explicitly covered by the Quran, Hadith, or prior consensus. It is what allows Islamic law to adapt to circumstances that did not exist in the seventh century, from digital contracts to organ transplantation. Whether and how much ijtihad is permitted is itself a point of debate. Some conservative traditions argue that the “gates of ijtihad” effectively closed centuries ago, while reform-minded scholars insist it remains essential. Countries that embrace ijtihad more freely tend to produce legal systems that look quite different from those hewing strictly to classical rulings, even when both claim Sharia as their source.
The Direction of Change
The picture of Sharia application worldwide is not static. Several countries have undertaken significant legal reforms in recent years, mostly moving toward codification, predictability, and expanded individual rights.
Saudi Arabia’s reforms are the most sweeping. The kingdom codified its Personal Status Law in March 2022, followed by implementing regulations published in February 2025 that curtailed male guardianship, expanded women’s divorce rights, and standardized child custody rules. Saudi Arabia has also reformed its commercial agency law, explicitly codifying grounds for contract termination and building in arbitration mechanisms that mark a departure from the older system where judges had broad and sometimes unpredictable discretion.
Iran’s legal system, while firmly rooted in Sharia, is codified and has its own internal reform dynamics driven by the tension between conservative religious authorities and technocratic legal professionals. The country maintains written criminal and civil codes that are periodically amended through a legislative process, even though all legislation must pass the Guardian Council’s review for compliance with Islamic principles.2University of Minnesota Human Rights Library. The Constitution of the Islamic Republic of Iran
The broader trend across Muslim-majority countries is toward written law rather than open-ended judicial interpretation, even when the substance of that written law remains grounded in Sharia principles. Codification creates something that uncodified judicial discretion does not: the ability for citizens to read the law before they need to go to court, and for appellate courts to apply consistent standards. So the answer to how many countries follow Sharia law is roughly 50, but the more useful answer is that those 50 sit across three very different models, and the models themselves are still moving.