The Differences Between America and Italy When Dealing With Realtors

Tuesday, September 30, 2025

Buying or selling real estate is always complex, but the experience varies dramatically depending on the country. In the United States, real estate transactions are shaped by a well-established system of licensed realtors, standardized contracts, and multiple listing services. In Italy, on the other hand, the process is deeply influenced by civil law traditions, regional practices, and the role of the agente immobiliare (real estate agent), who functions quite differently from an American realtor.

Understanding these differences is crucial for buyers, sellers, and investors navigating both markets. This essay explores the contrasting approaches to real estate transactions in America and Italy, focusing on licensing, representation, commission structures, listing practices, cultural expectations, and the legal framework.

1. Licensing and Professional Standards

United States:
In America, realtors (often members of the National Association of Realtors, or NAR) are licensed professionals who must complete education, pass examinations, and adhere to a strict code of ethics. Licensing requirements vary by state but generally involve pre-licensing courses, continuing education, and ongoing oversight by state real estate commissions. Buyers and sellers expect professional expertise, strong ethical conduct, and clear fiduciary duties from their agents.

Italy:
In Italy, real estate professionals are known as agenti immobiliari. To operate legally, they must be registered with the Chamber of Commerce (Camera di Commercio) and pass qualifying exams that test knowledge of civil law, real estate practices, and taxation. Unlike in the U.S., the emphasis is less on fiduciary duties and more on the agent’s role as an intermediary (mediatore) who facilitates negotiations between parties. The Italian agent’s primary obligation is neutrality—serving both buyer and seller—rather than advocating exclusively for one side.

2. Representation and Agency Relationships

United States:
Agency relationships in the U.S. are well defined. A realtor may represent the buyer (buyer’s agent), the seller (listing agent), or both (dual agency, though this is regulated and sometimes restricted). The agent has fiduciary duties to their client: loyalty, confidentiality, disclosure, and obedience. Buyers often rely on their agents for detailed market analysis, price negotiations, and protection throughout the transaction.

Italy:
In Italy, the agente immobiliare typically represents both parties simultaneously. Their role is to connect buyer and seller and facilitate the deal, rather than exclusively advocate for one side. Italian agents do not assume fiduciary duties in the same way U.S. realtors do; instead, they are bound to fairness and transparency. This can be surprising for Americans accustomed to having an advocate, as Italian agents often maintain neutrality and avoid deep involvement in negotiations beyond bridging communication.

3. Commission Structures

United States:
Real estate commissions in the U.S. are usually paid by the seller, typically around 5–6% of the final sale price, split between the listing and buyer’s agents. Buyers generally do not directly pay their agent, though the cost is implicitly factored into the transaction. Negotiations over commission do occur but the system is relatively standardized nationwide.

Italy:
In Italy, commissions are paid by both the buyer and the seller. It is common for each side to pay a percentage (usually 2–3% each) of the sale price directly to the agent. This shared cost underscores the agent’s neutral role in the transaction. For American buyers, this can feel unusual, since in the U.S. the seller generally shoulders the agent’s fee.

4. Listings and Market Transparency

United States:
The American Multiple Listing Service (MLS) provides a centralized, transparent system where virtually all homes for sale are visible to both buyers and agents. This open access promotes efficiency, competition, and broad exposure for listings. Buyers can browse homes online with photos, data, and price histories, and agents use MLS tools to guide clients.

Italy:
Italy does not have a nationwide MLS. Instead, listings are fragmented across individual agencies, local networks, and property portals. Buyers may need to contact multiple agencies to get a full view of available homes. Transparency is lower; property histories, exact square footage, and comparable sales data are often incomplete or inconsistently reported. As a result, due diligence requires more legwork, and buyers often rely heavily on their notaio (notary) and legal counsel to verify details.

5. Legal Framework and Documentation

United States:
In the U.S., realtors use standardized contracts provided by state associations. Attorneys may or may not be directly involved, depending on the state (they are common in the Northeast but not in many western states). Title companies or attorneys ensure clear title transfer, and escrow services handle funds. The realtor helps guide clients through inspections, contingencies, and appraisals.

Italy:
In Italy, legal formalities are stricter and more centralized. The notaio (notary) is a public official who must oversee every real estate transaction. The notary verifies ownership, ensures taxes are paid, confirms compliance with zoning, and records the sale. While the agente immobiliare facilitates introductions and negotiations, the notary provides the binding legal framework. For Americans, this can feel like a heavier reliance on legal professionals and less on the realtor for contractual oversight.

6. Cultural Expectations and Negotiation Styles

United States:
Americans expect their realtor to be proactive, communicative, and client-focused. Realtors are often deeply involved in advising on pricing, staging, marketing, and negotiation strategies. Aggressive representation is seen as part of the agent’s duty.

Italy:
In Italy, the process is more formal and less client-centric in the American sense. The agente immobiliare introduces opportunities and facilitates discussion but is less likely to push aggressively for one side’s advantage. Buyers and sellers negotiate more directly with each other, often at the table. The culture values direct relationships and bargaining, with the agent maintaining impartiality.

7. Timeframes and Bureaucracy

United States:
A real estate transaction in the U.S. typically closes within 30–60 days, assuming financing and inspections proceed smoothly. Realtors help coordinate the process to keep it on track.

Italy:
In Italy, transactions often take longer, sometimes several months, due to additional bureaucracy, property checks, and the notarial process. Buyers must also account for higher transaction costs, including notary fees, registration taxes, and agency commissions. The agente immobiliare has less control over speeding up the process compared to a U.S. realtor.

8. Buyer Preparation and Due Diligence

United States:
Realtors guide buyers through pre-approval, home inspections, appraisals, and contingencies. Much of the due diligence is coordinated by the realtor in collaboration with inspectors and lenders.

Italy:
Italian agents provide less hands-on guidance. Buyers themselves, often with the help of an attorney or notary, must verify property boundaries, building code compliance, and mortgage liens. Cultural expectations place more responsibility on the buyer to investigate thoroughly before signing.

Conclusion

The role of the realtor in the United States and Italy reflects two very different real estate cultures. In America, the realtor is an advocate, advisor, and transaction manager, representing one side with loyalty and fiduciary duties. In Italy, the agente immobiliare is a neutral mediator whose goal is to connect parties and facilitate agreements, with the notary ensuring legality.

For young or international buyers, the differences can be striking: commissions are shared, listings are less transparent, and agents play a less advocacy-driven role in Italy compared to the U.S. Yet both systems function within their cultural and legal frameworks. Understanding these contrasts can prevent misunderstandings and empower buyers and sellers to approach each market with realistic expectations.

Ultimately, dealing with realtors in America emphasizes representation, advocacy, and efficiency, while in Italy it emphasizes neutrality, legal oversight, and tradition. Both systems reveal how property transactions mirror broader cultural values—individual advocacy in the U.S., and shared mediation within Italy’s civil law framework.

Please call me right away to get started at 860-966-1617 or email me at matt@mattsellsrealestate.com