Real Estate Agent Commissions Around the World: What Do Buyers and Sellers Pay in Different Countries?
Real estate agent commissions are an important part of the total cost of buying or selling a property. However, there is no single international model. In some countries, the seller typically pays the agent’s commission; in others, the cost may be shared between the buyer and seller. In many markets, the final fee depends on the agreement between the real estate professional and their client.
For anyone buying or selling property internationally, understanding these differences is essential. The cost of traditional brokerage services for a residential property can be very different from the fee charged by a professional who identifies an off-market investment opportunity, negotiates a below-market purchase price or supports a complex real estate transaction.
This guide examines typical real estate commission practices in selected international markets, explains who usually pays, and outlines what buyers, sellers and investors should consider before agreeing to a fee.
1. How Are Real Estate Agent Commissions Calculated?
Real estate agent commissions can be structured in several ways:
- Percentage-based commission: A percentage of the final transaction price, such as 2% of the agreed sale price.
- Fixed fee: A predetermined amount, regardless of the property’s value.
- Success fee: A fee payable when a specified outcome is achieved, typically the successful completion of a transaction.
- Hybrid fee structure: A combination of a fixed fee and a percentage-based commission, or an additional fee linked to clearly defined and agreed performance criteria.
A commission is not determined solely by the property’s market value. Other factors include the complexity of the transaction, the exclusivity of the mandate, the scope of services, the time required and the agent’s ability to identify suitable buyers or properties.
In many markets, commissions are negotiable. Consequently, percentages published in comparative guides should generally be understood as indicative commercial practices rather than legally mandated rates.
2. Real Estate Agent Commissions in Different Countries
The following table provides indicative commission ranges for residential property transactions in selected markets. Actual fees vary according to location, property type, service level, contractual arrangements and applicable taxes.
| Country | Indicative commission | Who typically pays? |
|---|---|---|
| Greece | 2% + VAT per party | Buyer and seller |
| United Kingdom | 1%–3% | Usually the seller |
| Germany | Approximately 3.57%–7.14% combined, including VAT where applicable | Often shared under specific legal rules |
| France | Approximately 4.5%–8% | Usually the seller, depending on the agreement |
| Spain | Approximately 3%–5%, with higher fees in some cases | Usually the seller |
| Italy | Approximately 3%–4% per party | Buyer and seller |
| Portugal | Approximately 3%–5% | Usually the seller |
| United States | Approximately 5%–6% combined as an indicative market range | Negotiable; sellers may contribute to the compensation of both parties’ agents |
| Australia | Approximately 2%–3% | Usually the seller |
| United Arab Emirates | Often 2% for the buyer in Dubai transactions | Depends on the transaction and contractual arrangements |
These figures are not directly comparable in every case. Some sources quote commissions per party, while others refer to the total commission. Tax treatment also varies. Before comparing fees, buyers and sellers should establish whether the quoted percentage includes VAT or other applicable taxes and whether it represents the commission for one party or the entire transaction.
3. Greece: A Liberalised Market with Negotiable Commissions
The Greek real estate market operates under a system of freely negotiated brokerage fees. Under Greek Law 4072/2012, the commission is agreed between the real estate agent and their client; the law does not impose a mandatory commission percentage.
In practice, a common arrangement for a property sale is 2% of the final transaction price payable by the seller and 2% payable by the buyer, with VAT added where applicable.
This is an established commercial practice, not a legally compulsory rate. The agreed commission and the relevant terms should be documented in writing in accordance with the applicable legal requirements.
When Can a Higher Commission Be Agreed?
Not every real estate transaction is a conventional residential sale. Investment transactions can involve a substantially different level of expertise, research and negotiation, particularly when a professional identifies a property that is not widely available on the market or secures favourable acquisition terms for an investor.
Examples include:
- Properties offered significantly below their substantiated market value.
- Opportunities identified through specialist research, professional networks or direct access to property owners.
- Properties with potential for renovation, conversion or redevelopment, subject to planning permission, feasibility and applicable regulations.
- Investment properties with demonstrable rental income potential or a credible resale strategy.
- Complex transactions requiring extensive negotiation, market analysis and coordination between multiple parties.
In these circumstances, a buyer may agree to pay a higher fee for specialised property sourcing and investment-focused services. In exceptional, individually negotiated cases, this may amount to 4%, 6% or even 10% of the purchase price.
Such percentages should not be interpreted as standard commissions for ordinary residential transactions or as established market averages in Greece. They represent possible arrangements for specific services where the agreed fee reflects the scope of work and the value sought by the investor.
The assessment may take into account the discount against a substantiated market valuation, the expected return on investment (ROI), the potential economic benefit and the difficulty of identifying the opportunity. However, a high projected ROI does not automatically justify a higher commission, nor does it guarantee a future profit.
Example: Acquiring a Property Below Market Value
Suppose a property has a substantiated estimated market value of €300,000, but an investor acquires it for €210,000 following targeted property sourcing and negotiation.
The €90,000 difference represents a 30% discount against the estimated market value.
If the parties have agreed on a 5% commission calculated on the purchase price, the fee amounts to €10,500, plus VAT where applicable.
The investor acquires the property at a price substantially below its estimated market value, while the professional is compensated for the sourcing, access to the opportunity and negotiation services covered by their agreement.
The €90,000 difference should not automatically be regarded as a realised profit. The actual financial benefit depends on the property’s condition, acquisition costs, renovation expenses, resale prospects and prevailing market conditions.
The key takeaway: An investment transaction may justify a different fee structure from a conventional brokerage transaction, provided that the fee has been agreed in advance and reflects clearly defined services and genuine added value.
4. United Kingdom: The Seller Usually Pays
In the United Kingdom, estate agent fees are commonly calculated as a percentage of the final sale price and are usually paid by the seller.
Different arrangements are available, including sole agency and multi-agency agreements. The chosen arrangement can affect the commission, contractual obligations and circumstances under which the fee becomes payable.
The agency agreement should specify the commission, included services and any additional costs. Sellers should also confirm whether VAT, marketing expenses and other charges are included.
Official guidance: GOV.UK – Getting an Estate Agent.
5. Germany: Commission Sharing Under Specific Legal Conditions
Germany is an example of a market where legislation directly affects how real estate commissions may be allocated.
For certain residential purchases involving apartments and single-family houses acquired by consumers, German civil law establishes specific rules governing the allocation of brokerage fees. Where an agent agrees to receive compensation from both parties, the relevant legal provisions require equal obligations. Additional rules apply where only one party initially engaged the agent but the other party is also expected to contribute.
These provisions should not be generalised to every property or transaction. Commercial real estate, corporate investment transactions and other specialised cases may be subject to different arrangements.
Legal references: German Civil Code, Section 656c and Section 656d.
6. France and Spain: Contractual Terms and Local Practices Matter
In France, real estate commissions can be relatively high as a percentage of the property price, particularly in certain residential market segments. The ultimate cost and the party responsible for payment depend on the agency agreement and how the property’s asking price and fees are presented.
In Spain, commissions vary by region, property type and service level. The seller frequently pays the agent, but practices are not uniform across all transactions.
In both markets, reviewing the agency agreement is essential to establish whether the commission is included in the advertised price, who is contractually responsible for payment and whether additional taxes or charges apply.
7. Italy: Buyers May Pay Their Own Commission
In Italy, it is common for both the buyer and seller to incur brokerage fees when the agent has contributed to the transaction under the conditions established by Italian law.
This is particularly important for international buyers who assume that the seller always covers the entire real estate commission. Before submitting an offer, buyers should request written clarification of the amount payable, the applicable tax treatment and the event that triggers the payment obligation.
8. United States: Negotiable Compensation and Greater Emphasis on Buyer Agreements
In the United States, real estate commissions are not set at a single legally mandated rate. They are negotiable and may be structured as a percentage, a fixed amount or another agreed form of compensation.
Changes introduced on 17 August 2024 under the National Association of REALTORS® (NAR) settlement placed greater emphasis on written compensation agreements for buyers working with professionals subject to the relevant Multiple Listing Service (MLS) rules.
Compensation must be clearly agreed upon. A seller may, subject to the applicable rules and contractual arrangements, contribute towards the compensation of the buyer’s agent.
It should therefore not be assumed that the seller will always cover the entire commission for both sides of the transaction.
Source: National Association of REALTORS® – Compensation, Commission and Concessions.
9. Portugal and Australia: Different Markets, Different Agreements
In Portugal, the agency fee is agreed under the relevant brokerage agreement and is frequently paid by the seller. The applicable tax treatment should be considered separately when assessing the total cost.
In Australia, commission is usually paid by the seller and can vary according to the state or territory, location, property value and type of service. Alternative fee structures, including fixed-fee arrangements, are also available.
For international investors, the key is not simply to compare percentages. They should also understand the services provided and the total cost of completing the transaction.
10. What Should Buyers Check Before Agreeing to a Commission?
Before signing a real estate agency agreement, buyers and sellers should clarify the following:
- Who pays? Is the commission payable by the buyer, the seller or both?
- How is the fee calculated? Is it based on the final transaction price, a fixed amount or another agreed formula?
- What services are included? Does the agreement cover property sourcing, negotiations, viewings, transaction coordination and other services?
- When is payment due? Is it payable upon completion, signing of the final contract or another clearly defined stage?
- Which taxes apply? Does the quoted fee include VAT, or is it charged separately?
- Is the mandate exclusive? What is its duration, and what obligations does each party undertake?
- Are both parties represented? Has any dual representation or other relevant arrangement been clearly disclosed and agreed upon?
- How is investment value assessed? Are there comparable sales, rental data and realistic assumptions supporting the projected ROI?
A written agreement protects both parties by reducing misunderstandings and clearly establishing the scope of services, the fee and the conditions under which it becomes payable.
11. Why Commission Should Be Evaluated in Relation to the Value of the Service
The lowest commission does not necessarily produce the best financial outcome. Equally, a higher fee does not automatically indicate a superior service.
For sellers, the value of a real estate professional lies in effective marketing, access to suitable buyers, skilled negotiation and the final price achieved.
For buyers, particularly investors, value may lie in finding a property that meets specific investment criteria, negotiating favourable acquisition terms and avoiding a poor purchase decision. Delivering this type of service may require specialist expertise, considerable time and access to opportunities that are not readily available on the open market.
A commission should therefore be assessed in relation to the agreed scope of work, the quality of the service and the outcome that can reasonably be pursued, rather than solely by comparing percentages.
Conclusion
Real estate agent commissions vary considerably around the world. Greece operates under a system of freely negotiated fees, with 2% from each party being a common market practice. Other markets typically place the cost on the seller or apply specific legal rules governing how the commission is shared.
In investment transactions, the agreed fee may differ substantially from a conventional brokerage commission when the scope of work and the value delivered are materially different. Even in these cases, transparency, a written agreement and a clear understanding of the services provided remain fundamental.
For buyers and sellers, the most important question is not simply, “How much does the agent charge?” but what service is being provided, what outcome is being pursued and how the fee relates to the agreement between the parties.
Disclaimer: This article is intended for general informational purposes only and does not constitute legal, tax or investment advice. Commission practices and legal requirements vary by jurisdiction and transaction. Applicable local regulations should be checked before entering into a specific agreement.
