How does getting a mortgage in France as a non-resident compare to a mortgage in Denmark in 2026?

Danes dreaming of a second home in Provence or a chalet in the Alps are stepping into a lending system built on almost the opposite logic from home. For example, while Danish banks can finance up to 80% of a property through a realkreditlån, with just 5% required in cash, French banks typically ask non-resident buyers for 30% down, according to Finanstilsynet's own guidance on down payment requirements. To avoid confusion, this guide breaks down how much you can borrow in each country, how the two rate systems compare, and what happens to your Danish property tax bill once you own a second home in France.

 

Key Points to Remember

• Denmark lets buyers finance up to 95% of a home (80% mortgage bond plus a 15% bank loan) with only 5% down, while France generally asks non-residents for 30%.

• Denmark's realkredit system offers both fixed and variable-rate loans with unusually flexible prepayment terms, while French loans are almost always fixed for the full term.

• Danish ejendomsværdiskat can follow a fully tax-liable buyer to their French property too, separate from whatever France charges locally.

 

Why compare the French and Danish systems at all?

Denmark's mortgage market runs on a system that has no real equivalent in France. Instead of a bank lending its own money and keeping that loan on its books, a specialized mortgage institution matches each loan to a bond it sells on the stock exchange, so the money actually comes from whoever buys that bond, not from the bank itself. These institutions exist purely to issue mortgages funded by bonds sold on the capital markets. The rate you get is the market rate, not a negotiated one.

France's market runs on a completely different logic, shaped by the Banque de France and the High Council for Financial Stability (HCSF). It's built around fixed affordability limits and a strong preference for straightforward, long fixed-rate loans directly funded by the bank, no bond, no middleman. A Danish applicant walking into a French bank brings a profile that looks unfamiliar to the underwriter, income paid in kroner, no French credit history, and a home market used to bond-funded loans and higher borrowing limits than France typically allows. It is important to know the differences between systems to be able to plan according to your project and your means. 

 

How much can I borrow: France's 35% rule versus Denmark's debt factor test

Since a 2021 HCSF decision, all monthly debt payments combined, insurance included, cannot exceed 35% of net income. On a net monthly income of DKK 37,000 (roughly €5,000), that caps total repayments at around €1,750 a month, regardless of what the loan is for. 

Denmark doesn't use a single nationwide ceiling. In growth areas, specifically Copenhagen and its surrounding municipalities, plus Aarhus, Finanstilsynet requires banks to apply extra scrutiny once a household's debt factor (total debt divided by gross annual income) passes 4, combined with a loan-to-value above 60%. In that situation, the bank has to check whether the household's net wealth, all assets minus all debt, would still be positive if home prices suddenly dropped, 10% for a debt factor between 4 and 5, 25% above 5. For some households in these areas, failing that resilience test effectively creates a soft ceiling on how much they can borrow.

 

What down payment should a Danish buyer expect in each country?

At home, a typical Danish purchase splits into 80% realkreditlån, up to 15% supplementary bank loan, and 5% cash from the buyer, per Finanstilsynet's guidance on housing finance.

That bank-loan slice usually carries a noticeably higher rate than the realkredit portion itself, since it isn't backed by the same bond market. Cross into France as a non-resident, and the math changes considerably: banks generally want 30% down, sometimes more.

On a €300,000 property, that's €90,000 in cash, on top of notary costs, a real jump from the 5% a Danish buyer is used to putting down at home.

The good news is that French banks generally treat Danish applicants as lower-risk than non-EEA buyers, so EU and EEA membership does work in Denmark's favor here, with a tendency to land them a lower down payment.

 

Fixed or floating: how do interest rates actually compare in 2026?

Danish borrowers have a choice most of Europe doesn't: a long fixed-rate realkreditlån, currently forecast around 4.1% by Nykredit, or a variable-rate F-lån tied to short reference rates like CITA3 or F1, running closer to 1.7% to 2.5% depending on the lender.

French mortgage rates, by comparison, run 3.10% to 3.55% depending on the term, per Pretto's July 2026 barometer, but almost always as a single fixed rate for the entire loan. One quirk is that, since the Danish loan is funded by tradeable bonds, borrowers can often buy their bond back at the bond's market price rather than face a fixed penalty, sometimes even profiting if bond prices have fallen. A French loan works the opposite way, once signed, the rate and the schedule are locked for good, trading that possibility for total predictability.

 

What upfront costs come with the purchase itself?

Denmark splits its registration costs into two separate charges. The skøde (title deed) costs 0.6% of the purchase price plus a flat DKK 1,850 to register, while the pantebrev (mortgage deed) costs 1.25% plus DKK 1,825, a rate lowered from 1.45% as of 1 January 2026, according to Skattestyrelsen. There's no notary involved at any point, a lawyer typically reviews the contract and Tinglysningsretten records the change of ownership digitally.

France bundles most of this into notary fees (which represent taxes more than the notary's income) instead, which run 7% to 8% of the price for an existing property and drop to 2% to 3% for new builds, per Notaires de France. On a €300,000 resale, that's €21,000 to €24,000, and unlike Denmark's split system, one professional (mandatory by law for every French sale) handles both the legal verification and the registration. France also has ongoing costs such as borrower insurance, comparable to Denmark's ongoing cost of ejerudgift. 

 

Does buying property in France change what I owe on Danish property tax?

Ejendomsværdiskat, Denmark's annual property tax, isn't limited to homes located in Denmark. A person who remains fully tax liable in Denmark owes ejendomsværdiskat on a foreign home too, calculated the same way as for a Danish property, according to Skattestyrelsen. The standard rate is 5.1 per mille (0.51%) of the property's value, rising to 1.4% on the portion above DKK 9,007,000 in 2026. The catch for a French property is that there's no official Danish valuation to fall back on, so the owner has to establish the market value themselves, typically starting from the purchase price.

France runs its own wealth tax on real estate (IFI) independently of what Denmark charges. For a non-resident, IFI only applies once French property exceeds €1.3 million, starting at a 0.5% rate, with nothing owed below that threshold. The two taxes don't offset each other, and a Danish buyer under the IFI threshold could still owe ejendomsværdiskat on the same property back home, so it's worth checking both sides with an advisor rather than assuming one tax cancels out the other.

 

Heads up! This article is aimed at non tax residents. If you're a French tax resident and looking to buy in France, go here: How do mortgages work in France in 2026? The complete guide

 

What happens if a Danish buyer eventually moves to France for good? 

Denmark's system is more straightforward here than some of its neighbors. Ejendomsværdiskat on a foreign home is tied to being fully tax liable in Denmark, so once that liability ends, typically when someone gives up their Danish residence and center of life moves abroad, the ongoing Danish tax on the French property ends with it.

There's no multi-year tail obligation the way some Nordic wealth taxes work, though the exact timing depends on individual residence and income ties, which is worth confirming with a tax advisor.

On the French side, becoming a French tax resident brings the French property under ordinary French tax rules and can eventually expose worldwide assets to the IFI. A transitional rule softens the landing: someone who lived outside France for the five years before the move is taxed only on French property for up to five years afterward, according to impots.gouv.fr.

Put together, a Dane relocating permanently generally sees Danish property tax wind down as residence there ends, while French tax obligations phase in gradually rather than all at once.

 

Is there a system of bidding for real estate in France?

Not in the way Denmark can work. If more than one buyer is interested in a Danish property, it's entirely up to the seller whether to run a closed bidding round at all, there's no legal requirement to do so, and the seller can simply choose whoever they prefer at whatever price they set.

What Danish law does guarantee is a safety net after signing: every buyer has a statutory six-business-day right of withdrawal, though using it costs 1% of the purchase price in compensation to the seller. Most buyers instead rely on an advokatforbehold, a lawyer's review clause that lets them walk away for free within a set window, usually three to six business days, according to Skøde Centret.

France skips the bidding question entirely and works through a single negotiated offer instead. A seller lists an asking price, and a buyer submits a written offre d'achat, often below that number, valid for a period the buyer sets themselves. There's no legal deadline forcing the seller to answer: if too much time passes without a reply, the offer simply lapses and the buyer walks away with nothing owed, according to the Chambre des Notaires de Paris. For a Danish buyer used to a seller holding all the cards on price, the French system actually shifts some of that leverage back to the buyer.

 

How does the purchase process differ in its timeline?

A French purchase moves through a fairly fixed sequence: a preliminary sales agreement, a financing window of 45 to 60 days to secure a loan offer, a mandatory 10-day cooling-off period on that offer once issued, and a final signature before a notary, whose involvement is required by law for every sale. None of it requires a Danish buyer to set foot in France, since the whole process can run through a power of attorney (procuration), a topic covered in more detail in our guide to how a mortgage works in France.

Denmark's version compresses those protections into the days right after signing rather than spreading them across two months. The six-business-day withdrawal right and the advokatforbehold both typically run in the first week, and once those pass, Tinglysningsretten can register the transfer digitally within days rather than weeks. Set side by side, Denmark front-loads its buyer protections early and moves fast afterward, while France spreads similar protections out across a longer, more sequential process.

 

How do you finance a French property with a Danish financial profile?

Neither system is better, they're simply built around different assumptions about leverage, bond markets, and paperwork. What actually matters for a Danish buyer is translating a kroner income, a realkredit-shaped credit history, and Danish tax residency into terms a French bank recognizes, which is exactly where a broker earns their fee.

Opeongo Finance works with Danish and other Scandinavian buyers as non-residents and expatriates, matching applications to banks that lend to international clients and explaining precisely where the French rules diverge from what's familiar at home.

Whether you're still comparing options or already have a property in mind, let's talk it through, no obligation attached.

Updated on July 15, 2026, by Paul Desjardins, mortgage broker specializing in international clients (ORIAS No. 25 010 121).

Paul Desjardins assists expatriate buyers, non-residents, and international investors with their real estate financing projects in France. More than 60% of his clients live abroad: he advises them in French and English, from the initial review of their application through to the signing at the notary’s office. He writes practical guides for Opeongo Finance aimed at international clients who want to understand the rules of French mortgage lending and secure financing from abroad.