Lost in translation: The real estate words that aren't what they seem

Many real estate professionals work with international clients at some point: They may receive a referral from abroad, work on a relocation, or work with a buyer or seller from a different legal system.

In those situations, the most underestimated risk is not the contract, the financing or the inspection. It’s the language. A familiar-sounding term can create a false sense of security, even with the most sophisticated translation tools, and a simple misunderstanding can have serious legal or financial consequences.

When you hit a term you’ve never heard​ before, you would likely stop, ask, use Google or AI ​and clarify. That’s not the problem. ​Where people get hurt is when a term sounds close enough that you assume it works the same way it does at home, so you move forward without questioning it because you are confident that you understand it.

​After many years working in real estate in both Italy and the United States, I’ve seen situations that were frustrating at first and almost comical later — all because a familiar-sounding word meant something completely different on the other side of the ocean.  

Real estate terms abroad: 4 that don’t quite translate

Here are four examples (and four ways to get burned). 

Notary

​​Take the word “notary”: easy to translate, easy to recognize and also very easy to misunderstand. To an American agent, a notary verifies identity, witnesses signatures and performs a few official acts. In Italy, the notaio​ (notary) is something else entirely — and the gap between the two is not a nuance; it’s a canyon.

The notaio is a highly trained legal professional and public official who prepares or authenticates the deed and verifies the legality of the transaction. Think less notary at the local UPS store and more a legal authority operating out of an elegant office in a centuries-old palazzo, in a custom-tailored suit.

Functionally, an American buyer would recognize more of the notaio’s role in a title company than in the notary they know back home. Same word, translated correctly, wrong picture in your head. And it’s not just Italy — France, Spain and several other civil-law countries operate with similar notarial systems.

Broker

The word “broker” can be confusing in a different way. In Italy, the English word “broker” is also commonly used for a mediatore immobiliare, which makes the confusion even easier.

In the U.S., your broker works for you — buyer’s side or seller’s side — with duties dictated by that relationship. In Italy, the mediatore immobiliare doesn’t work that way. Their job is to bring both parties to the table, not to advocate for either one.

Instead of acting for one side, the Italian agent is required to stay in the middle, so when an American buyer assumes the friendly agent showing them apartments is “their” agent fighting for their price behind the scenes, they’re not just making a small assumption.

They have completely misunderstood the agent’s role, and that can shape the entire deal. I’ve had this conversation at least a dozen times. 

Preliminary contract

Then there’s the “preliminary contract,” which might be the most misleading of all, because the word itself does the damage. “Preliminary” suggests something early, soft, reversible — a step you can still walk back from. The contratto preliminare in Italy is the opposite: Once both parties sign, they are legally bound to complete the sale on the agreed terms.

Changing your mind is no longer really an option, and neither side gets to walk away just because the closing feels far off. If either party fails to hold up their end of the agreement, there can be real legal and financial consequences, as the next example shows.

Earnest money

​”Earnest money.” American buyers picture a deposit sitting safely in escrow, held by a neutral third party until closing — a gesture of good faith, nothing more. In Italy, the caparra confirmatoria​ (earnest money) usually goes straight to the seller, and it has actual teeth: default as the buyer and you can lose it entirely. Default as the seller, and the buyer may be owed double it back.

It looks like a deposit. Legally, it carries much more weight than the earnest money most American buyers are used to.

The list doesn’t stop at four. Closing, deed, title, land registry, appraisal, escrow, listing agent, survey: Each can carry a different meaning, a different responsibility or a different legal consequence depending on which side of the border you’re standing. And this is not just an Italy issue: Work in France or Spain, and you’ll find a different vocabulary carrying the exact same traps.

Nobody — not me, not anyone — can hold every legal system in their head. That’s not really the point. The point is knowing which words deserve a second look before you trust them.

Google or AI can hand you a fast, technically correct translation in two seconds. What it can’t hand you is the legal and cultural weight sitting behind that word in a system you didn’t grow up in. That gap — between translation and meaning — is where the expensive mistakes happen.

More than once, I’ve had an American client use a familiar term with complete confidence, and a few minutes later, we realized we were talking about two different things. So, practically: if you work with international clients, referrals or relocations, get more suspicious of the “obvious” words, not less.

Before you explain a term to a client, check what it actually does in that country’s legal and practical systems. Don’t just translate it and hope the meaning made the trip, too. Because words cross borders easily. Meaning doesn’t always follow.