Who Actually Pays the Estate Agent? (2026): Commission Rates and Who Foots the Bill, Country by Country

Published on: June 16, 2026

Here is a question that decides whether you have budgeted correctly, and one that almost no listing answers honestly: when you buy this property, who pays the agent, and how much?

The instinct of most buyers, shaped by their home market, is wrong somewhere. A British buyer assumes the seller always pays. A Dubai buyer assumes the buyer always pays. An Italian buyer knows that both sides pay, and is surprised when other countries don't work that way. The truth is that estate agent commission is one of the least standardised costs in international real estate, and getting it wrong can add or subtract thousands from your real purchase price.

This guide breaks down, country by country, who pays the agent, the typical rate, and whether tax is added on top.

Read this first. Commission is almost always negotiable and varies by agency, property type (new-build vs. resale), and price bracket. The figures below are typical market ranges as of 2026, not fixed tariffs. Always confirm the exact fee and who pays it in writing before you commit.

The quick answer

Spain, the seller pays

In Spain the seller pays the estate agent, typically 3–6% plus 21% IVA. As a buyer working with the listing agent, you generally pay them nothing, the commission is already baked into what the seller nets. The exception is if you hire your own buyer's agent (a personal shopper inmobiliario), who works for you and charges you directly. That is a separate, optional cost that buys you representation rather than a salesperson.

Portugal, the seller pays

Same logic as Spain: the seller pays, typically 3–5% plus 23% IVA. Buyers dealing with the listing agency usually don't pay a separate fee. Portugal's high IVA rate means the seller's effective cost is meaningful, which is worth remembering if you are negotiating, there is room in that number.

Italy, both sides pay

Italy is the classic two-sided market. The agente immobiliare is paid by both the buyer and the seller, each typically 2–4% plus 22% IVA. So as a buyer in Italy, you should budget for an agent fee that buyers in Spain or the UK never see. This is legitimate and standard, but only if the agent is properly registered. Always confirm the buyer-side percentage before you view, not after you fall in love with a house.

Greece, both sides pay

Like Italy, Greece splits the commission: both buyer and seller typically pay around 2% each plus 24% VAT. Budget for the buyer's 2% as a real line item in your total acquisition cost.

France, usually folded into the price

French commission (frais d'agence) is higher on paper, often 4–8%, but how it is paid depends on the mandate. Most commonly the fee is "FAI" (frais d'agence inclus), meaning it is included in the advertised price and effectively borne by the seller. In some mandates it is charged to the buyer. Because the notaire's fees and transfer taxes are separate and substantial in France, read the listing carefully to see whether the price is net-seller or commission-inclusive.

Turkey, both sides, modestly

In Turkey, both buyer and seller customarily pay the agent around 2% each plus KDV (VAT), particularly on resale properties. New-build sales handled directly by developers often work differently, with the agency paid by the developer. For foreign buyers, clarify upfront whether you are buying resale (where the 2% buyer fee usually applies) or new-build (where it may not).

Cyprus, the seller pays

The seller typically pays in Cyprus, around 3–5% plus VAT, similar to Spain and Portugal. Buyers dealing with the listing agent generally don't pay a separate commission.

UAE / Dubai, the buyer pays

Dubai flips the script: the buyer pays the agent, with the RERA-standard commission at 2% of the purchase price plus 5% VAT on the fee. This is on top of the 4% Dubai Land Department transfer fee. So in Dubai, the agent commission is squarely a buyer's cost, budget for it from the start.

United Kingdom, the seller pays

In the UK the seller pays the estate agent, typically 1–3% plus VAT. Buyers pay nothing to the listing agent. Buyers who want representation hire a separate buying agent, paid by the buyer, common at the higher end of the London market.

Germany, split since the 2020 reform

Germany reformed its rules in December 2020. For sales of owner-occupied homes, the Maklerprovision is now split between buyer and seller, commonly around 3.57% each (VAT included). Previously buyers often shouldered the whole fee, so this is a meaningful, relatively recent change.

The Netherlands, each side hires its own

The Dutch market is built around representation: the seller hires a verkoopmakelaar, the buyer hires an aankoopmakelaar, and each side pays its own agent, typically 1–2% plus VAT. Buying without your own agent is possible but unusual, because the seller's agent does not work for you.

What this means for your real budget

The headline price is never the price. Once you factor commission in, two properties listed at the same number can cost you very different amounts:

• In Spain or Portugal, the listed price is closer to your real cost (the seller absorbs the agent fee).
• In Italy, Greece or Turkey, add the buyer-side commission to your budget.
• In Dubai, add 2% + VAT to the buyer, on top of transfer fees.
• In France, check whether the price is commission-inclusive before comparing.

A buyer comparing a €400,000 home in Spain with a €400,000 home in Italy is not comparing like with like, the Italian purchase carries a buyer-side fee the Spanish one does not.

Frequently asked questions

Is estate agent commission negotiable?
Almost always, especially on higher-value properties and where the seller pays. It is one of the most negotiable numbers in the transaction.

Why do some countries charge the buyer and others the seller?
It is custom and regulation, not logic. Where the buyer pays (Dubai, Italy's buyer-side share), the agent is partly working for you; where the seller pays (Spain, UK), the listing agent works for the seller.

Should I hire my own buyer's agent?
In markets where the listing agent represents the seller, a dedicated buyer's agent can pay for itself through better negotiation and protection, particularly for remote, cross-border buyers.

Does VAT really get added on top?
Often, yes. In Spain (21%), Portugal (23%), Italy (22%) and Greece (24%), VAT on the commission is a real cost. Factor it in.

Why cross-border buyers need one transparent view

Every market has its own custom, and listing portals built for a single country rarely explain it, they assume you already know the local rules. International buyers don't, and that is precisely where mistakes happen.

JanusHermes is built to surface these mechanics up front: who pays the agent, what the buyer-side cost is, and how the commission interacts with transfer taxes and notary fees in each country, so the price you compare is the price you'll actually pay. Where you want representation rather than a salesperson, we connect you with agents whose incentives are transparent from the first conversation. Explore listings and country intelligence on JanusHermes.

Figures are typical 2026 market ranges and are negotiable and variable by agency and property type. Always confirm the exact commission and who pays it in writing before committing. This is general information, not financial or legal advice.

A note on the numbers: where no source is named, the market figures in this article (prices, yields, costs) are indicative estimates compiled from publicly available market data and industry reporting at the time of writing. Markets move and rules change, so treat them as a starting point and verify current figures with official sources before acting on them.