Key Differences Between the U.S. and Italian Real Estate
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The differences between the U.S. and Italian real estate systems are significant. Some are structural and regulatory; others reflect different market practices and cultural expectations.
With 25 years of real estate experience—including 13 years in Florence and more than a decade in California, where I have been licensed since 2015 and a real estate broker since 2017—I have worked directly within both systems. The following ten differences help explain why Americans purchasing property in Italy need to approach the process with a different set of expectations. |
Model used for Lorenzo International Real Estate
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1. The Role of the Agent
In the United States, agency relationships are formally disclosed. A seller is generally represented by a listing agent, while a buyer is typically represented by a separate buyer’s agent. In some states, including California, dual agency is legally permitted when properly disclosed and consented to by both parties, although it is far less common than separate representation.
In Italy, the traditional real estate agent acts as a mediatore—a mediator who facilitates the transaction without formally representing either party exclusively. The same agent commonly works with both buyer and seller and may receive a commission from each. This creates an important difference for American buyers: the Italian listing agent may assist with the transaction, but should not automatically be understood as the buyer’s exclusive representative.
2. Licensing and Agencies
In the U.S., there are two main types of real estate licenses: salesperson and broker. Salespersons typically work under a broker but operate with a high degree of autonomy. Large franchises, such as Keller Williams, coexist with small boutique agencies like my own, Lorenzo International Real Estate. In California, becoming a broker requires additional experience, education, and passing the state broker examination.
In Italy, there is one license: agente di affari in mediazione immobiliare. Courses and exams are required, and many agents also handle rentals. Cases of people conducting real estate activity without the proper qualifications are unfortunately not uncommon.
3. Exclusivity
In the U.S., exclusivity is standard. The seller works with a single listing agent, and often the buyer is bound by agreement to a buyer’s agent.
In Italy, written exclusive agreements are challenging to obtain. Sellers often list with multiple agencies, thinking it increases their chances. Buyers may view dozens of properties with one agent, only to close with another.
4. Commissions
In the U.S., real estate commissions are negotiable. In many California markets, the seller continues to pay both the listing agent and the buyer’s agent, meaning the buyer often pays no separate commission directly. However, buyer-agent compensation must be clearly established in advance and agreed upon in writing. Commissions are generally paid at closing through escrow.
In Italy, both seller and buyer usually pay commissions—often about 3% each. The payment timing may vary and should be agreed upon in advance. Unlike in California, commissions are not managed through escrow, and “going around” the agent remains a common risk.
5. MLS
The U.S. has the Multiple Listing Service (MLS): a comprehensive database accessible to all licensed agents. It provides property history, comparable sales, and a wealth of data.
In Italy, MLS systems are rare, local, and far less developed. Many properties are not “market-ready” due to irregularities or unauthorized modifications, which can delay or even block sales.
6. Signs and Lockboxes
In the U.S., properties get a For Sale sign with “SOLD” or “PENDING” updates. Vacant homes often use lockboxes, sometimes electronic, to facilitate showings by any agent.
In Italy, small “Vendesi” signs are placed outside properties, often with multiple agencies’ names. Lockboxes are virtually unknown; sometimes keys are left with a nearby bar or neighbor.
7. Open Houses
In the U.S., Open Houses are standard weekend events, open to the public and a key source of buyer leads.
In Italy, Open Houses are far less common and are not yet a standard part of the selling process, although some agencies use them for selected properties and new developments.
8. Preparation and Home Staging
In the U.S., sellers and agents carefully prepare the home: repairs, repainting, professional photos, drone videos, and home staging are common.
In Italy, home staging is rare. Most properties are presented “as is,” often with little attention to detail.
9. Escrow and Inspections
In the U.S., once an offer is accepted, the transaction typically moves into escrow, often for 20–40 days. Escrow and title professionals act as neutral third parties, manage funds and documents, verify title, and coordinate the closing. Buyers commonly conduct a home inspection and, when the contract includes an inspection contingency, may renegotiate or withdraw according to its terms.
In Italy, the notary performs the required legal and title-related checks and finalizes the transfer, but technical due diligence must generally be coordinated separately with a surveyor or other qualified professional. Transaction timelines can vary from several weeks to several months, depending on the documentation, property condition, financing, and complexity of the purchase.
10. Referrals
In the U.S., referrals are common: agents pass clients across states or countries, earning a percentage of the commission (typically 25%). In Italy, collaboration exists, but formal referral networks are rare, outside of certain franchises.
Conclusion
The American Realtor works in a highly regulated, structured system with strong tools like the MLS. Transactions move quickly once an offer is accepted.
In Italy, every deal is unique, often complex, and heavily shaped by bureaucracy and cultural habits such as constant negotiation. While U.S. agents would likely struggle with the Italian system, Italian agents are seasoned at navigating these challenges.
Having lived and worked in both worlds, I can confirm: real estate in Italy is more unpredictable, but also rich with history, nuance, and unique opportunities.
In the U.S., referrals are common: agents pass clients across states or countries, earning a percentage of the commission (typically 25%). In Italy, collaboration exists, but formal referral networks are rare, outside of certain franchises.
Conclusion
The American Realtor works in a highly regulated, structured system with strong tools like the MLS. Transactions move quickly once an offer is accepted.
In Italy, every deal is unique, often complex, and heavily shaped by bureaucracy and cultural habits such as constant negotiation. While U.S. agents would likely struggle with the Italian system, Italian agents are seasoned at navigating these challenges.
Having lived and worked in both worlds, I can confirm: real estate in Italy is more unpredictable, but also rich with history, nuance, and unique opportunities.
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