Reference

The Universal Virtual Staging Disclosure Phrase (Copy + Paste)

One disclosure block — copy-and-paste — that satisfies California AB 723, CRMLS Rule 11.5.2, HAR watermark wording, REBNY watermark wording, Canopy MLS §1.18.1, NWMLS Rule 105(d), Wisconsin Act 69 (forward-compatible), and NAR Article 12 / SoP 12-10 simultaneously.

SC

Reviewed by SofaBrain Compliance Desk

Compliance review · Last reviewed 2026-05-19

Editorial flat-lay showing a real-estate listing brochure with a printed disclaimer at the bottom and a magnifying glass hovering over the fine print

The phrase

This image has been digitally altered with generative AI virtual staging. The original, unaltered photograph is available at [URL/QR code]. Furniture and décor are not included in the sale. No structural elements, finishes, fixtures, or landscaping of the actual property have been modified in this image.

What this single block discharges

  • AB 723(a) — disclosure that the image is altered.
  • AB 723(b) — adjacency requirement (it sits on the image).
  • AB 723(c) — link/QR to original (when paired with the QR code).
  • NAR Article 12 — "true picture" obligation.
  • NAR SoP 12-10 — anti-manipulation of listing content.
  • CRMLS Rule 11.5.2 — labeling plus parallel original.
  • HAR watermark wording — "image does not represent actual property as is" equivalent.
  • REBNY watermark wording — "Furniture Not Included" equivalent.
  • Canopy MLS §1.18.1 — on-image disclosure (not just caption).
  • NWMLS Rule 105(d) — "virtually staged" label.
  • Wisconsin Act 69 (effective Jan 1, 2027) — forward-compatible "tech-altered" disclosure.
  • NY DOS Trend Alert / RPL §441-c — non-deceptive advertising.
  • E&O defense posture — eliminates the "concealment" pleading that triggers AI exclusions.

Placement requirements

For maximum legal posture, burn the disclosure into the bottom 8% of the rendered image. Use a minimum font size equivalent to 14px on a 1920×1080 frame (this remains legible at the typical MLS thumbnail size). Semi-transparent background or contrasting font color is fine, but legibility wins over aesthetics.

Pair the on-image disclosure with a C2PA Content Credential signed at export. This gives the realtor a cryptographic provenance defense and satisfies the parallel-original requirement when published on a Sofabrain-controlled landing page.

Why the wording matters

Every phrase in the disclosure is doing legal work. "Generative AI virtual staging" answers AB 723's definition of digitally altered image. "Furniture and décor are not included in the sale" answers REBNY's watermark requirement. "No structural elements, finishes, fixtures, or landscaping … have been modified" pre-empts the CRMLS categorical prohibitions and the worst plaintiff theories. Do not paraphrase casually.

Frequently asked questions

Can I shorten the phrase if I am running out of space?+

You can shorten the "No structural elements …" sentence if your render genuinely does not modify structure, finishes, fixtures, or landscaping (Sofabrain's default). You cannot shorten the disclosure-of-alteration sentence or the link-to-original sentence — those are statutorily required.

Does the phrase need to be in the agent's own voice?+

No. The disclosure is a statement of fact about the image, not an endorsement. Realtors can and should use the standardised phrase — it has been drafted to maximise compliance across jurisdictions.

What if my MLS uses a different required wording?+

If your MLS prescribes specific watermark text (HAR, REBNY), use their text in addition to the universal phrase — not instead of. The universal phrase satisfies the substantive disclosure obligation; the prescribed text satisfies the form requirement.

Related compliance reading

Stay compliant — automatically

SofaBrain burns the required disclosure into every render, packages the original unaltered image, and emits state-specific compliance metadata. You upload the file to your MLS, the disclosure rides along.

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Sources and citations

Disclaimer. This page summarises laws, MLS rules, ethics guidance, and insurance practices as of 2026-05-19. It is not legal advice and does not create an attorney-client relationship. For specific compliance questions, consult an attorney licensed in your state or your E&O carrier. SofaBrain Inc. is not a law firm.