France vs. U.S. mortgages: What American buyers need to know in 2026?

The French mortgage system works very differently from the American one: there is no credit score comparable to the FICO score, French banks generally require a significantly larger down payment from non-residents, and the debt-to-income ratio is governed by specific rules. 

An American homebuyer accustomed to having their interest rate determined by their FICO score and to the fact that an FHA loan requires only a 3.5% down payment will be in for two surprises when they begin researching the terms of a French mortgage: there is no credit score to check, and the down payment is nowhere near 3.5%. French banks generally require non-resident buyers, including Americans, to make a 30% down payment, in addition to a legal debt-to-income ratio cap set at 35% by the High Council for Financial Stability (HCSF). U.S. mortgage rates averaged 6.65% for a 30-year fixed-rate loan in August 2026, according to Freddie Mac’s “Primary Mortgage Market Survey,” while French rates over the same period ranged from 3.43% to 3.61%, according to Pretto’s barometer. The two systems are based on almost opposite principles, and a U.S. homebuyer must set aside certain preconceptions before being able to understand either one.

 

Key Points to Remember

• France legally caps every borrower's monthly loan payments at 35% of net income; the US replaced its old 43% debt-to-income threshold with a price-based test in 2021, so there's no single fixed ratio waiting for you there anymore.

• US lending runs on a three-digit FICO score while France has no credit score at all, and leans on savings, cash reserves, and a monthly leftover-income calculation instead.

• An American buyer can still get on the property ladder at home with as little as 3.5% down through an FHA loan, but a French bank will typically ask a US non-resident for 30% down.

 

Why compare the French and US systems at all?

The US mortgage market was built around a data infrastructure France simply doesn't have: three national credit bureaus, a standardized three-digit score, and federal programs like FHA loans designed to get first-time buyers in the door with a small down payment.

French banks have never had access to a US-style credit score, and they don't build a domestic equivalent the way, say, a French bank might size up a French resident's history.

What replaces it is a closer look at what a bank can verify directly: savings, income stability, and how much cash a buyer is putting down.

An American researching French financing is learning a system built around fundamentally different inputs.

 

Borrowing capacity: France's 35% rule versus the US's price-based test

In France, the math is fixed by regulation: total monthly loan payments, insurance included, cannot exceed 35% of net income, a rule confirmed by the HCSF and applied to every borrower, resident or not.

The US used to have something similar. Until 2021, a Qualified Mortgage generally required a debt-to-income ratio at or below 43%. The Consumer Financial Protection Bureau (CFPB) replaced that hard threshold with a price-based test: a loan generally qualifies if its annual percentage rate doesn't exceed the average prime offer rate by more than 1.5 percentage points, regardless of the borrower's exact DTI. Lenders still look closely at debt-to-income as part of underwriting, but there's no single legal ceiling the way there is in France.

An American used to shopping around for a lender with more flexible ratios will find that flexibility doesn't exist once they're applying to a French bank.

 

Credit scores versus savings: the real philosophical gap

This is where the two systems diverge the most. In the US, a FICO score, built from payment history, amounts owed, length of credit history, and a couple of smaller factors, sits at the center of almost every lending decision, and most lenders still expect a score somewhere in the mid-600s even after Fannie Mae removed its hard 620 floor from automated underwriting in November 2025.

France has nothing resembling this. There's no data-sharing arrangement between US credit bureaus and French banks, so a FICO score simply never reaches a French underwriter's desk. France's own closest equivalent, the FICP registry maintained by the Banque de France, only logs payment defaults, not a positive score, so a spotless US credit history doesn't translate into anything a French bank can check either. Some French banks do ask American applicants for their actual US credit report, mainly to see existing debts rather than to import a score, which is exactly the kind of detail that makes working with a broker who tracks lender-by-lender practice worth it.

What replaces the score entirely is savings: French banks lean on the down payment size, months of clean bank statements, and the reste à vivre, the amount left over each month after the loan payment, as their real substitute for a credit check.

If you want more information on how credit scores, credit reports, and savings work in France, check out our dedicated article.

 

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

At home, an American buyer can still qualify for an FHA loan with as little as 3.5% down if their credit score is 580 or above, or 10% down below that, according to FHA.com's lender guidance.

In practice, most buyers put down more: the median down payment for first-time homebuyers was 10% in 2025, matching the highest level recorded since 1989, while repeat buyers put down a median of 23%, per the National Association of Realtors' “2025 Profile of Home Buyers and Sellers.”

In France, non-resident buyers, including Americans, are generally required to make a 30% down payment. For a property worth $300,000, this amounts to $90,000 in cash, excluding notary fees—which is significantly more than what most American buyers set aside for a purchase in the United States.

 

Loan terms and rates: what's actually on offer in 2026

According to Freddie Mac, the average rates for 30-year fixed-rate mortgages stood at 6.65% and those for 15-year fixed-rate mortgages at 5.95% in August 2026. In France, average rates ranged from 3.43% for 15-year loans to 3.61% for 25-year loans in September 2026 for residents; for non-residents, an additional 0.4 percentage points must be added, according to Pretto. It is in terms of loan duration that the comparison becomes most interesting: a 30-year fixed-rate loan is the norm in the United States, which offers American buyers a longer repayment period to spread out their payments. French banks generally do not grant the same flexibility to non-residents, limiting the loan terms for expatriate and non-resident buyers to approximately 15 to 20 years, compared to up to 25 years for a French resident.

Term length is where the comparison gets more interesting: a 30-year fixed loan is the default in the US, giving American buyers a longer runway to spread out payments. French banks generally won't extend that same runway to a non-resident, capping loan terms for expatriate and non-resident buyers around 15 to 20 years, against up to 25 for a French resident. Both countries fix the rate for the life of the loan once signed, so the real difference an American buyer needs to plan around isn't rate structure, it's a shorter term pushing up the monthly payment on an already larger loan.

 

What upfront costs come with the purchase itself?

In France, notary fees (mostly taxes and registration duties, not the notary's own income) run approximately 7 to 8% of the price for an existing property, and 2 to 3% for new construction, according to the official website of French notaries. On a $300,000 resale property, that's roughly $21,000 to $24,000 on top of the down payment.

In the US, closing costs are far lighter by comparison: the national average purchase-mortgage closing cost was $4,528 in 2025, or about 1.04% of the average sale price, according to LodeStar Software Solutions' 2026 report.

An American budgeting for a French purchase the way they would at home will underestimate this line item by a wide margin.

 

How does the purchase process differ day to day?

A US purchase runs through a title company or escrow agent, with a home inspection, an appraisal, and a closing that typically takes 30 to 45 days from accepted offer to keys. A growing number of states now allow remote online notarization, letting a buyer sign closing documents without appearing in person.

A French purchase runs through a preliminary sales agreement (the compromis de vente), a financing window that typically runs 45 to 60 days in practice, and a final signature before a notary, whose involvement is mandatory in every French property sale. The whole process, from compromis to keys, generally takes two to three months.

An American buyer doesn't need to fly over for any of it: the signing can be handled remotely through a power of attorney, something we cover in more detail in our guide on how a mortgage works in France.

The bigger adjustment isn't remote versus in-person, it's that a French notary plays a state-certifying role no single party in a US closing holds.

 

Financing your project between two systems

A comparison between France and the United States clearly highlights one point: an American income, a FICO-built credit history, and a down payment sized for a US market all need to be translated into terms a French bank actually recognizes.

At Opeongo Finance, we help American buyers, as non-residents or expatriates, structure their application for French banks that actually lend to non-EU applicants, and explain how the French rules interact with what you already know from home.

Whether you're just starting to research your options or already have a property in mind, let's talk about your project, with no obligation.

Updated on September 4, 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.