A digitally altered listing photo is an image in which software or AI has added, removed, or changed property content, beyond routine adjustments such as exposure or color correction. AI listing photo disclosure is already required by law in California, takes effect in Wisconsin in 2027, and is under consideration in DC and New York.
On October 9, 2026, DC Councilmember Christina Henderson introduced Council Bill B26-0858, the Restricting Editing and Alterations in Listing Photos Amendment Act of 2026. It is proposed legislation and is now with the Council’s Committee on Public Works and Operations.
This article uses “altered” for all such changes, whether made with AI or conventional photo-editing software, and “AI-edited” only where AI specifically is involved.
Key Takeaways
- DC’s proposed bill, now in committee, would require an alteration label, the original image, and a written description of material differences.
- In an analysis of roughly 40,000 primary listing photos on major US portals, Coraly’s detection system flagged about 11% as digitally altered, according to NAR. More than 90% of those flagged images had no visible disclosure on or next to the photo.
- No rule discussed here prescribes a software architecture. Listing software can help support disclosure workflows, but whether a workflow meets requirements depends on each market’s rules and how the organizations involved use it.
What Would DC’s AI Listing Photo Bill Require?
B26-0858 would make certain undisclosed alterations in property advertising a prohibited trade practice. For any altered image, a listing would need to:
- State clearly that the photo has been altered
- Include a publicly accessible, unedited version of the image
- Describe in writing the material differences between the altered image and the property’s actual condition, features, and amenities
The proposal covers both rental and for-sale listings. It would apply to anyone advertising property in DC, and for real estate agents, listing agents, and property managers, a violation would also count as false advertising under their licensing law.
Where Is AI Listing Photo Disclosure Required?
As of November 3, 2026, California Assembly Bill 723 (AB 723) is the only rule compared here that is in force, and it requires online listings to give access to the unaltered image. California Assembly Bill 2025 (AB 2025), signed September 27, 2026, extends similar rules to rental ads from January 1, 2027, when 2025 Wisconsin Act 69 (Act 69) also takes effect. DC’s B26-0858 is in committee. In New York, Senate Bill S9584 and its Assembly version A11403 are in committee, as is a separate Assembly Bill A11635, and New York City has announced a disclosure initiative for rental listings.
| Rule | Status as of November 3, 2026 | What’s covered | What’s exempt | Who discloses |
| California AB 723 | In effect since January 1, 2026 | Altered images in sale ads, including leases over one year until 2027 | Routine edits that don’t change how the property looks | Brokers, salespersons, and people acting for them |
| California AB 2025 | Signed September 27, 2026; effective January 1, 2027 | Altered or fully AI-generated images in rental ads | Routine edits. No original needed for images not taken with a camera, such as fully AI-generated ones | Anyone advertising a rental; licensees also face license discipline |
| Wisconsin Act 69 | Enacted; effective January 1, 2027 | Tech or AI changes that create a misleading impression | No exemption list; disclosure applies only when a change misleads | Licensees |
| New York S9584 / A11403 | S9584: Senate Judiciary Committee. A11403: Assembly Consumer Affairs and Protection Committee | Material alterations in images, video, and virtual tours | Enhancements that don’t mislead; labeled renderings | Anyone; licensees also face license discipline |
| New York City | Announced July 16, 2026; details not yet published | AI- or digitally altered photos in rental listings | Not yet defined | Landlords (per the announcement) |
*This article is for informational purposes and does not constitute legal advice. Requirements and legislative status may change.
MLS policies can impose additional requirements on images submitted to their systems. The details vary by organization; for example:
- CRMLS: Its current guidance requires altered images to be labeled in the photo description, with the unaltered original placed immediately before or after. Its truth-in-advertising rules prohibit altering real parts of the property, such as flooring, walls, or landscaping.
- NorthstarMLS: Its guidance asks for AI-generated, AI-enhanced, and virtually staged images to be clearly identified and accompanied by an unaltered image of the property.
Separately, Article 12 of the NAR Code of Ethics requires REALTORS® who are subject to the Code to present a “true picture” in advertising. This professional obligation does not replace applicable state or local law.
Why Disclosure Is Harder Than Adding a Label
Disclosure takes more than a label, because each market defines covered alterations differently and disclosure data can drop out as a listing moves between systems.
Coraly’s analysis, as reported by NAR, also shows which alterations are most common among flagged images:
- Sky replacement: 69%
- Color enhancement: about 52%
- Virtual staging: about 10%
- Object removal: nearly 2%
The categories overlap because one image can contain several alterations.
Rules differ by market
California, Wisconsin, and DC’s proposal use different approaches to defining covered alterations and disclosures. Platforms serving several markets may need to account for the listing’s jurisdiction and the type of alteration when determining which requirements apply. Configurable rules and a review step for uncertain classifications can help manage those differences.
Disclosures can get lost in syndication
A disclosure recorded in one system may not appear on a portal if its field is omitted, remapped, or ignored downstream. SmartMLS’s Matrix guidance notes that photo captions aren’t included in feeds to IDX and third-party sites, so it requires a watermark on the image itself, while CRMLS asks for the label in the photo description. The RESO Data Dictionary includes a MediaAlteration field, but its presence in the standard does not guarantee that every connected system supports or displays it.
Source images can be hard to trace
When photographers upload large batches, matching each altered version to its source image can become manual work, especially when a listing is reviewed or corrected later.
Written descriptions add a separate workflow
Where a rule requires a written description, it has to stay matched to the right image on each channel. That calls for its own review and publishing step.
How Can Listing Software Support Photo Disclosure?
Listing software can support photo disclosure by keeping originals linked to their altered versions, applying each market’s rules, and carrying disclosure data to every channel. These are implementation options that can help support compliance workflows. Which ones a platform needs depends on the markets it serves, its role in the listing chain, and its existing systems.
| Capability | How it can help |
| Original retention | Preserves source images and links published variants to them with stable identifiers, which supports rules that require showing the original |
| Edit record | Stores the edit type for each altered image and, depending on the workflow, the editing tool, timestamp, and reviewer |
| Rule configuration | Maps the listing’s jurisdiction and edit classification to the applicable disclosure requirements. Keeping changeable rules in configuration can reduce code changes when policies are updated, although some changes may still require engineering work |
| Detection and review | Flags images that may contain covered alterations and routes uncertain cases for human review. Automated classifiers can produce false positives and false negatives, so detection supports the review process and does not determine compliance on its own |
| Publishing and audit | Maps disclosure data to each channel’s supported fields, renders disclosures in the required format, and records which version and disclosure went to each destination |
Some MLS workflows already use automated tools to flag potentially altered images during upload. NAR has described a San Diego-area MLS workflow that uses a Chrome extension to flag potentially altered images for review. Such tools can support disclosure workflows, but their results still need to be interpreted within the applicable rules.
An edit log or detection result can support a compliance workflow, but it does not establish by itself that a disclosure is accurate, legally sufficient, or visible on every destination.
Example: One Altered Photo, Three Destinations
Take a California listing with a virtually staged living room photo. Here is how a platform could handle it:
1.Upload. The photographer delivers the empty-room original and the staged version. The platform stores both and links the staged image to its source.
2.Classification. Virtual staging adds furniture, so it is tagged as a covered alteration under AB 723’s rules for a California listing.
3.Publishing. On the brokerage site, the disclosure appears next to the photo with a link to the original. The MLS feed carries the alteration flag where the feed supports it. For a portal whose feed drops captions, the workflow still has to deliver both the disclosure and access to the original, for example with a label on the image and a link or QR code to the unaltered version.
4.Record. The platform logs which version and disclosure went to each destination, so a later correction can be traced to every place the photo appeared.
Keeping Disclosures Intact Through Publishing
The challenge is preserving disclosure information as a listing passes through integrations and reaches the sites where consumers see it.
At ORIL, we provide full-cycle product design and software development for property listing and brokerage platforms, including the integrations that move listing media and metadata between systems. If you’re preparing your platform for evolving photo disclosure requirements, we can help assess your current media workflows, design the necessary improvements, and implement changes to how image versions, alteration metadata, and disclosure information move across publishing channels.
