Virtual staging disclosure under CRMLS Rule 11.5.2
CRMLS splits altered photos in two. Furniture and appliance edits you disclose and pair with the original. Changing the building, or anything visible beyond it, is not allowed on the listing at all.
What the rule says
Rule 11.5.2 was created for the January 2026 edition of the CRMLS rules, implementing California's AB 723. Its defined term is narrow. A digitally altered image is one edited to add, remove or change elements related to furniture or appliances, and common adjustments such as lighting, white balance, cropping and exposure fall outside it.
A Subscriber who submits to the MLS any Digitally Altered Image must also (i) submit the original, unaltered version of the digitally altered image, (ii) ensure that the original, unaltered version is displayed in the listing immediately before or after the digitally altered image, and (iii) ensure that the digitally altered image is labeled as "Photo Modified", "Virtually Staged", "Digitally Altered," or "AI Altered," or some accurate substantially similar term in the text field section for the altered photo in the add/edit module.
CRMLS Rules and Policies, Rule 11.5.2, effective Jan 5, 2026. Read the CRMLS Rules and Policies
The rule then goes past disclosure. Subscribers may not add to a listing any image altered to add, remove or modify real property elements, and it names flooring, walls, windows, structural elements, cabinetry, paint color, hardscape, landscape, facade, fixtures and floor plans. The same bar covers elements outside or visible from the property, such as streetlights, utility poles, views through windows and neighboring properties. One exception exists, where the property will be improved to match the altered photo by closing as part of the listed price.
What it means in practice
Several things follow from that split, and the second one catches people out.
- Adding or removing furniture is allowed. Label the photo, publish the original next to it, and you are inside the rule.
- Altering the building is not a disclosure question. Repainting a wall, swapping flooring or erasing a utility pole is barred from the listing outright, whatever label you attach to it.
- The label goes in the photo description text field in the add and edit module, using Photo Modified, Virtually Staged, Digitally Altered, AI Altered, or an accurate equivalent.
- No watermark is required. The CRMLS FAQ says so directly, which contradicts the vendor pages claiming you need a metadata or filename tag.
- Virtually clearing a room of furniture that will not be there at closing counts as altered too, per the CRMLS knowledge base.
Sky replacement appears nowhere in the rule, the FAQ or the knowledge base, and it reads arguably either as a common adjustment or as an element visible from the property. Decluttering items that are not furniture sits in the same gap, since the definition reaches furniture and appliances while the prohibition reaches real property elements. Both are unresolved in the text. Ask CRMLS rather than reasoning your way to an answer.
Disclosure wording you can adapt
CRMLS names the acceptable labels in the rule itself, so use one of those in the photo description field rather than inventing your own. These are starts for the places that field does not cover.
- Photo description field
- Virtually Staged. Original unaltered photo shown immediately after.
- Agent remarks
- Staged images in this listing are labeled and each is paired with the unaltered original, per CRMLS Rule 11.5.2.
- Advertising outside the MLS
- This image is digitally altered. Furniture was added digitally and the structure of the room is unchanged. The original, unaltered image is at the link below.
AB 723 is broader than the MLS rule. It reaches all advertising and promotional material and asks for a statement plus a link, URL or QR code identifying the original image, so meeting Rule 11.5.2 inside the MLS does not by itself meet the statute.
How EstateInventor helps
EstateInventor staging is geometry-locked. Walls, windows, doors, ceilings, floors, built-ins and proportions stay exactly as shot, and output dimensions match the file you uploaded. Only furniture and decor are added or removed, which is the category CRMLS lets you disclose rather than the one it prohibits.
That distinction decides everything under Rule 11.5.2. A tool that repaints a wall or opens up a floor plan produces an image you may not post at all, however you label it. And because the edit starts from your photo and returns it at the same dimensions, the unaltered original the rule asks you to publish is the file you uploaded.
You still disclose. Added furniture sits squarely inside the definition, so label the photo and publish the original. One tool needs care. Our exterior work adjusts sky, lawn and facade, and landscape and facade are named in the prohibition, so do not put it on a CRMLS listing photo without checking first.
Common questions
Does CRMLS require me to disclose virtual staging?
Yes. Adding or removing furniture makes the photo a digitally altered image under Rule 11.5.2. Label it in the photo description field, submit the original, and display that original immediately before or after the staged version.
Do I need a watermark on the image?
No. The CRMLS digitally altered images FAQ says a watermark is not needed. The label belongs in the photo description text field instead.
Can I digitally remove a power line or repaint a wall?
Not on a CRMLS listing. Those are real property elements, or elements visible from the property, and the rule bars posting such images rather than letting you disclose them. The one exception is where the property will actually be improved to match by closing, at the listed price.
What is the penalty?
CRMLS has been inconsistent about this. Its 2025 citation schedule carries no line for 11.5.2, its 2026 FAQ documents said there was no fine yet, and its knowledge base, updated in July 2026, describes a warning followed by $250. A misleading image is separately citable under Rule 11.5(c) at $100.
Does following Rule 11.5.2 mean I comply with California law?
Not on its own. AB 723 added section 10140.8 to the Business and Professions Code and reaches all advertising, asking for a disclosure statement plus a link, URL or QR code to the original image. The MLS rule handles the listing record only.
Sources
Before you rely on this
This page is informational, not legal advice. We wrote it from the documents the MLS itself publishes and we link every one of them, but rules get amended and local interpretation varies. Confirm the current text with your MLS or your broker before you publish a listing, and treat the linked source as authoritative wherever it differs from this page.