Reference

The Universal Virtual Staging Disclosure Phrase (Copy + Paste)

One copy-and-paste disclosure block written to cover what California AB 723, the major MLS rules we track (CRMLS, HAR, REBNY, Canopy, NWMLS), Wisconsin Act 69 and NAR Article 12 / SoP 12-10 ask for. Always check your own MLS for prescribed wording.

Last updated Sources linked belowInformation, not legal advice

Reviewed by SofaBrain Compliance Desk, Compliance reviewCorrected against primary sources October 8, 2026

On this page
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

Short answer

  • Single disclosure block synthesises requirements across the major US MLS regimes + statutory laws + NAR ethics.
  • Burn into the bottom 8% of every render at minimum 14px equivalent on a 1920×1080 frame.
  • Pair with a QR code or URL linking to the unaltered original photograph.
  • Eliminates the "concealment" pleading that triggers Berkley/Hamilton/Philadelphia E&O exclusions.

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 each part of the block addresses

  • AB 723, §10140.8(a)(1): a statement that the image has been altered.
  • AB 723, §10140.8(a)(1): the statement must be reasonably conspicuous and on or adjacent to the image (it sits on the image).
  • AB 723, §10140.8(a)(1)–(2): a link, URL or QR code to the original, unaltered image (when you fill in the link).
  • 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): disclosure when an ad was altered with technology in a way that could mislead.
  • 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.

Keep the original, unaltered photo published or linked next to the altered one. In California that link is required; elsewhere it is the clearest way to show buyers what changed.

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 drop the "No structural elements …" sentence, but only if the image really does not change structure, finishes, fixtures or landscaping (true of plain furniture staging, not of paint, floor or landscaping edits). Keep the sentence saying the image was altered and, in California, the link to the original: AB 723 requires both.

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, so a standard phrase works. Adjust it if your MLS prescribes its own wording.

What if my MLS uses a different required wording?

If your MLS prescribes specific watermark text (HAR, REBNY), use their text, adding the universal phrase if there is room. The prescribed wording is what that MLS checks for.

Sources

Information, not legal advice. This page summarizes laws, MLS rules, ethics guidance and insurance practices as of October 8, 2026. It does not create an attorney-client relationship, and SofaBrain Inc. is not a law firm. For specific questions, consult an attorney licensed in your state or your E&O carrier.