The Key Differences Between U.S. Real Estate and Italian Real Estate

Key Differences Between the U.S. and Italian Real Estate

The differences between the U.S. real estate and the Italian immobiliare are significant. Some are structural and regulatory, while others are purely cultural. Having worked for 13 years as a real estate agent in Florence, and now for more than a decade as a licensed Realtor in California (and since 2017, as a licensed Broker), I’ve identified at least 10 major differences. Here’s a comparison of how things work in the U.S. versus Italy:

Buying in Italy Unseen

Model used for Lorenzo International Real Estate

1. The Role of the Agent
In the U.S., the Realtor works specifically for one party. The seller has a listing agent, while the buyer has a buyer’s agent. Over 95% of transactions involve agents, who are indispensable figures in the process.
In Italy, instead, the agent acts as a neutral intermediary, often working simultaneously for both parties. The proportion of transactions handled through agents is still much lower, and unfortunately the public perception of Italian agents is not always as strong—though many excellent professionals do exist.

2. Licensing and Agencies
In the U.S., there are two licenses: salesperson (Realtor) and Broker. Realtors 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. To become a Broker in California, you must first work two years as a Realtor, then pass the state exam and join the National Association of Realtors (NAR).
In Italy, there is one license: agente di affari in mediazione immobiliare. Courses and exams are required, but many agents also handle rentals. Cases of unlicensed “agents,” especially among young newcomers, 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., the seller typically pays the entire commission (5–6% of the sales price), split between the listing and the buyer’s agent. The buyer pays nothing, making it advantageous for them to work with an agent. Commissions are paid at closing via escrow.
In Italy, both seller and buyer usually pay commissions (about 2–3% each), at the compromesso or no later than the rogito. The payment is not managed by the notary, and “going around” the agent is 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, something similar exists mainly for new developments or large-scale projects.

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 moves into escrow (20–40 days). Escrow companies act as neutral third parties, manage deposits, verify title, and handle closing. Buyers also conduct a home inspection, with the right to withdraw if significant defects are found.
In Italy, the notary finalizes the transfer and ensures legal compliance, but the process can be lengthy (up to 12 months). Technical reports and energy certificates are required, and bureaucracy is often heavy.

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.