Buying Property in France: Key Differences from the U.S. Market

The absence of a Multiple Listing Service (MLS) in Paris is a key difference from the US market. While American buyers can easily access comprehensive market data through the MLS, a comprehensive French property search requires scouring a dozen different listing websites, working with multiple agencies and dealing with direct sellers, who comprise close to 20% of the market. All of these moving parts make the process of finding a property more complex and time-consuming than its American counterpart.

Another significant departure from U.S. practices is the role of the notaire, a government-appointed official essential to every property transaction. While American real estate attorneys represent individual parties’ interests, French notaires serve as neutral intermediaries who verify property authenticity, handle transfers, and collect taxes. The “notaire fees” that are due at the close of the sale include these taxes and costs and the notaire’s own fee, which is set by law rather than market rates. While both parties can share a single notaire, I send my clients to one who specializes in the tax and inheritance concerns particular to international buyers.

The French purchase process follows a distinct two-step format. Buyers first sign a preliminary contract (promesse de vente) within several weeks of an accepted offer. This includes a mandatory 10-day reflection period—a consumer protection absent in U.S. transactions—during which buyers can withdraw without penalty. The final sale (acte de vente) typically occurs months later, though cash buyers can now opt for an expedited process.

French law requires sellers to provide eight specific diagnostic tests, covering elements from lead paint to energy efficiency. In Paris, sellers must also certify apartment square footage—if measurements prove more than 5% inaccurate, buyers can claim proportional compensation. While these diagnostics offer comprehensive disclosure, they differ from U.S. home inspections in that it is not customary to ask the seller to address any issues discovered.

French mortgages often offer more favorable rates than U.S. loans but come with stricter lending criteria. Banks typically cap non-resident loans at 75% of the property’s value and require life insurance policies to secure mortgages—a requirement that can particularly impact older buyers. This conservative approach contrasts sharply with the more flexible U.S. lending market.

French property purchases involve higher transaction costs than U.S. deals, with buyers paying 6.5-7.5% of the purchase price in taxes and notaire fees. This represents a substantial increase from the typical 1-3% closing costs in U.S. transactions. However, for Paris apartments, carrying costs such as property taxes, building fees and even phone/Internet home service are a fraction of what they are in US cities. Seller agent commissions are usually 4-5%, and are included in the published listing price.

French inheritance law marks another significant divergence from U.S. practices. While American property owners enjoy considerable freedom in estate planning, French law includes forced heirship provisions that can supersede an owner’s wishes. Since 2016, non-residents can opt out of these restrictions by executing a French will that applies their home country’s inheritance laws.

The French property market offers strong consumer protections through standardized procedures and government oversight, though the process requires more patience and documentation than U.S. transactions. Success depends largely on understanding these systemic differences and working with experienced professionals who can effectively bridge both markets. While the French approach may seem complex to American buyers, its structured nature ultimately provides a clear framework for property acquisition.

Join our panel of experts from Paris Property Group, Moneycorp, Societe2Courtage and Lexidy, for our free Moving to France as an American in 2025 webinar. From managing your finances and securing the right visa, to understanding the French property market and securing a mortgage, this event will be packed with need-to-know info and tried-and-tested advice. Register now to make sure you don’t miss out!

Moving to France as an American in 2025:Your Essential Guide

Thursday 7th November
6pm ET