Italy: serving expat and cross-border buyers

Italian agencies meet more and more buyers who do not fit the standard picture: one citizenship, a second country of residence and savings held in a third. This briefing sets out what an agent should establish about such a buyer before taking instructions, and what the rules say about checks. It is written for agencies and developers.

Step one: which rules apply to your buyer

A 2026 law-firm guide to buying in Italy states that most foreign buyers can purchase Italian real estate under the principle of reciprocity: a non-EU citizen can buy if Italians can buy on comparable terms in that person's country (see the Mondaq guide for foreign buyers). Other summaries add that the notary has to verify this at the deed, and that a non-EU citizen without reciprocity can still buy with a valid Italian residence permit. The guide we read gives no detail on how the check is made or which countries qualify, so we do not list any.

For your file the practical point is simple: ask for citizenship, not only the country of residence, at the first call, and tell a non-EU buyer early that the notary will look at it. A buyer who learns this on the day of the deed loses weeks. Ask the notary or your lawyer to confirm the position for the specific passport before the buyer pays a reservation.

The Italian tax code comes first

Every party to a property transaction needs the Italian tax code, the codice fiscale. It is also needed to open a bank account, sign contracts and pay taxes. One consultancy page says it takes one to two weeks in person and up to four weeks through a consulate, and that it is free (see this 2026 non-resident guide). Treat those times as indicative and start the application on day one, not when a date for the deed is fixed.

What to collect before you take instructions

Treat the file as something a regulator might read later. For each buyer, collect:

• a valid passport or national ID, and the residence permit if the buyer lives outside the country of citizenship
• proof of address no older than a few months, such as a utility bill or bank statement
• the Italian tax code, and the tax number in the country of residence
• marital status, because the notary will record it and it affects who appears on the deed; ask the notary what is needed
• for a company buyer: the certificate of incorporation, the register of directors and shareholders, and the identity of the individuals who ultimately own or control it

A notary does not act for the buyer. A 2026 guide describes the Italian notary as a neutral public official who does not protect the buyer. Tell buyers early that they need their own lawyer for due diligence on title, planning and mortgages.

Source of funds: what a useful file looks like

A bank statement showing a balance is not enough. The file should show where the money came from. Typical evidence:

• salary or business income: payslips, tax returns or company accounts, plus the bank statements where the income arrived
• proceeds of selling another property: the sale contract and the statement showing the receipt
• inheritance or gift: the will, probate or gift document
• a loan: the loan agreement
• savings built over years: statements covering a long period, not a single month

Check that the account holder is the buyer. If someone else will pay, ask why and document the relationship. Treat large cash, sudden transfers from unrelated parties and reluctance to explain as red flags. We explain below why cash is a poor idea in Italy in any case.

What the rules ask of agents

Italian agents are within the anti-money-laundering decree, Legislative Decree 231/2007. An agents' magazine summarises the duties as identifying and verifying the client and any beneficial owner with valid documents, rating the client's risk, keeping records for ten years and reporting suspicious transactions to the national financial intelligence unit, the UIF (see this summary for estate agents). A legal explainer adds that notaries must also verify the identity of both parties and the beneficial owner, do client due diligence and report suspicious activity. We did not verify registration or supervision details for agencies; ask your trade body or lawyer.

At EU level, the anti-money-laundering regulation, Regulation (EU) 2024/1624, is reported to apply from 10 July 2027 and to treat real estate agents as obliged entities, with customer checks for occasional transactions of at least EUR 10,000. Plan your onboarding for that standard now.

Sanctions screening, done by the book

Screen the buyer, any beneficial owner and any third-party payer against the EU consolidated sanctions list and the other lists your bank or lawyer requires. Under EU guidance, an entity owned or controlled more than 50 percent by a listed person is treated as listed too. Keep a dated record of every check. If a red flag appears, stop, take legal advice and report as the national rules require. Never advise a client on how to avoid a check or how to restructure to get around one.

Russian-speaking buyers are one example. Their nationality is not a reason to refuse the file, and it is not a reason to skip checks. What matters is the person: whether they or their business are listed, who owns the buying entity, and where the money came from. Under Article 5b of Regulation 833/2014, banks may not accept deposits above EUR 100,000 per institution from Russian nationals or residents, but the Commission's FAQ says the rule does not apply to nationals of EU or EEA states or to holders of a temporary or permanent residence permit in a Member State (see the Commission FAQ on deposits). Do not apply it yourself; just know that banks may still ask detailed questions.

A short checklist for your team

• ask for citizenship and residence status at the first call, and write them down
• start the tax code application at once
• collect identity, address, tax numbers and status documents before any reservation
• build the source-of-funds file before money moves
• screen every party and payer and keep the record
• tell non-EU buyers early that the notary will check reciprocity or the residence permit
• put translations and apostilles on a timetable, because they take longer than buyers expect
• keep one person responsible for compliance, even in a small agency

Working with D.H. Realting

D.H. Realting is a trilingual (Russian, English, Polish) overseas-property platform. We introduce buyers, including expats and cross-border buyers, and support the process. Agencies that handle the deal locally and want to be introduced to such buyers can contact us through our partners page.

This briefing is informational only and is not legal, tax or investment advice. Facts were checked on 12 October 2026 from the sources named in the text; rules change, so confirm with a local lawyer before relying on any point.