Four compliance claims about AI listing photos, traced to their sources
By Ferit Patefe Coremagna, Founder and CEO, Miravely. Last checked
There is no RESO Data Dictionary 1.9 and no field called AIImageModified: RESO publishes 1.4 through 1.7 and then 2.0, certified since October 2023, and the field it did approve for altered images is OriginalMediaUrl, a string added to the Media resource in February 2026 that carries a link to the unaltered original rather than a yes or no about AI. NAR amended eleven Standards of Practice in June 2025 and none of them was the one about misleading images, and the $500 to $5,000 MLS fine repeated across vendor pages is cited to no rulebook at all, while the one figure an MLS has actually published is the $250 CRMLS charges for a labelling violation left uncorrected.
AI-generatedWhy a compliance claim needs a document behind it
Four claims about AI listing photos turn up on page after page, phrased almost identically. Each one was taken to the organisation it names and read there. Three did not survive.
None of the pages making these claims links to the document it is describing. They name RESO, NAR and unnamed MLSs, and then stop, which means a reader who wants to check is not being invited to. That is not an oversight in one place; it is the shape of the whole genre, and it is why the same four sentences can be found in a dozen variations with no common ancestor anybody can point at. “What are the AI virtual staging disclosure rules real estate agents must follow in 2026?”, colossis.io
The claims travel because they are plausible. A boolean field flagging an AI edit is exactly what a standards body would build, a professional association tightening its ethics code in response to generated photographs is exactly what one would do, and a four figure fine is exactly the sort of number an MLS would set. Each of them is a reasonable guess about what the industry did, written in the grammar of a fact.
They matter because people act on them. An agent who believes a RESO field will carry the disclosure for them is waiting on something that is not coming, and an agent who believes NAR imposed a new duty in late 2025 has the year wrong on an obligation that has actually applied to them for two decades. Both errors point away from the documents that do bind them, which in California and Wisconsin are statutes with dates, and on an MLS is a rule with a number. AB 723 bill text, California Legislature
One observation from writing this, offered as an observation rather than a citation: searched in September 2026, the RESO claim comes back not merely on those vendor pages but restated as fact in the summaries search engines now write above their own results. A claim with no source, repeated often enough, acquires the voice of one.
Claim one: the RESO field that is not there
The claim, in the wording it usually appears in, is that “the RESO (Real Estate Standards Organization) Data Dictionary 1.9, adopted by most major MLS systems in early 2026, includes a new boolean field called AIImageModified” which must be set to TRUE for any image altered beyond basic colour correction.
RESO publishes which version of the Data Dictionary is current, and it is 2.0, approved on 23 October 2023, with 41 resources, 1,745 fields and 3,683 lookups. Its own page says in as many words that DD 2.0 is the current version for RESO certification. Alongside it the page lists 1.7 as legacy and 2.1 as draft. There is no 1.9 on it. RESO Data Dictionary, current and legacy versions
Nor is there one in the specifications library, which is where every version RESO has ever shipped keeps its spreadsheets and certification testing rules. That list reads 1.4, 1.5, 1.6, 1.7, then 2.0, then 2.1 in process. The numbering skips from 1.7 to 2.0 and always has. RESO specifications library
The dating is the part that cannot be repaired even by assuming the version number was a slip. A 1.9 would by definition sit before 2.0, which was approved in October 2023, so it could not be a version that arrived in early 2026 carrying a new field. The claim is not off by a digit. It describes a release that could not have happened in the order it says it happened. RESO specifications library
What RESO did do is more specific and more useful. In February 2026 it approved OriginalMediaUrl, a string, added to the Media resource for Data Dictionary 2.2: “The URL of the original, unaltered version of a media file. This field is used to provide a direct link to the source image before any digital enhancements, staging or modifications were applied.” The entry names what it was built for, which is California AB 723. RESO product updates, Data Dictionary roadmap and approved additions
The difference between the imagined field and the real one is not pedantry, because they answer different questions. A boolean answers “was this edited by AI,” which no statute in force actually asks. A URL answers “show me the original,” which is precisely what AB 723 requires a California licensee to be able to do. RESO built the field the law needed rather than the one the blogs describe, and an MLS wiring up compliance against the blogs would be building the wrong thing. AB 723 bill text, California Legislature
A flag of the kind people are describing is not imaginary as an idea; it is just not a field yet. RESO’s Research and Development workgroup has discussed AI permission fields, along the lines of an “Allow AI Learning” yes or no, and has discussed standards for disclosing when a listing has been altered by AI. Those business cases were put on hold in March 2026, and in May 2026 the workgroup voted to develop standards for hierarchical AI governance and stood up a subgroup for it. As of September 2026 none of it is an approved addition to the dictionary. RESO product updates, Data Dictionary roadmap and approved additions
The field in the blogs
AIImageModified
A boolean said to have arrived in Data Dictionary 1.9 and to have been adopted by most major MLS systems in early 2026. RESO publishes no 1.9, and 2.0 has been the certified version since October 2023.
The field RESO approved
OriginalMediaUrl
A string on the Media resource, approved February 2026 for Data Dictionary 2.2: the URL of the original, unaltered version of a media file. Built for California AB 723.
RESO product updates, Data Dictionary roadmap and approved additions
The flag still in committee
Not a field yet
AI permission fields and a way to disclose that a listing was altered by AI have both been discussed by RESO’s R&D workgroup. On hold in March 2026, back as a governance workstream in May, and still not in the dictionary.
RESO product updates, Data Dictionary roadmap and approved additions
AI-generatedClaim two: the NAR rule that was already there
The second claim is that “the National Association of REALTORS® updated its Code of Ethics guidance in late 2025 to require members to disclose any digital alteration that changes the perceived layout, size, or features of a listed property.”
NAR publishes a summary of what it changed each year. The 2025 changes took effect on 5 June 2025 and are listed there: Article 4 and Standards of Practice 4-1, a new 4-2, Standard of Practice 11-2, and an amendment to the Pathways to Professionalism. Eleven further Standards of Practice were amended, namely 1-12, 1-13, 1-16, 3-1, 3-2, 3-9, 9-2, 10-1, 10-5, 16-11 and 16-16. Nothing in the list concerns artificial intelligence, digital alteration or photographs, and the one Standard that is about misleading images is not in it. NAR, 2025 Summary of Key Professional Standards Changes
That Standard is 12-10, and its date line reads adopted 1/07, amended 1/18. Its fifth limb prohibits “otherwise misleading consumers, including use of misleading images.” It sits under Article 12, which requires that REALTORS “be honest and truthful in their real estate communications and shall present a true picture in their advertising, marketing, and other representations.” Neither says artificial intelligence, because both were written before anyone needed them to. NAR 2026 Code of Ethics and Standards of Practice
So the correction runs in an uncomfortable direction for the agent hearing it. There was no new rule in late 2025, which means nobody got a transition period, a guidance note or a grace year. The duty not to mislead with an image has been enforceable against every member since 2007, and a photograph generated last week is judged by it exactly as a photograph retouched in 2010 was. NAR 2026 Code of Ethics and Standards of Practice
What the Code does not give is anything an agent could follow. It names no wording, no placement, no file to keep and no test for when an edit becomes misleading. It is a standard applied after the fact by a hearing panel, and it is the reason the rules that do specify those things, a state statute and an MLS rulebook, are the ones worth reading first. NAR’s own writing on generated listing photographs treats them the same way: as an existing legal risk rather than a new rule. NAR, "Using AI to Enhance Listing Photos Can Be Legally Risky"
The rule said to have arrived
Late 2025
A Code of Ethics update requiring disclosure of any digital alteration that changes the perceived layout, size or features of a property. NAR’s own summary of the 2025 changes does not contain it.
The rule that applies
Adopted 1/07, amended 1/18
Standard of Practice 12-10, fifth limb: misleading consumers, “including use of misleading images.” It predates the technology, names no photograph and prescribes no label.
AI-generatedClaim three: the fine nobody publishes
The third claim is a number: that failing to disclose virtual staging draws an MLS fine of $500 to $5,000. It appears on page after page in that exact range. Below, every page repeating it next to every document found that actually sets a figure.
| Where the figure comes from | What that page or document says |
|---|---|
| Roomstage AI | “Failure to disclose virtual staging can result in MLS fines ranging from $500 to $5,000.” The page names more than a dozen regional MLS systems and links to the rulebook of none of them. No author, no date, and a footer note that rules vary by region. “MLS Virtual Staging Rules & Disclosure Requirements (2026)”, Roomstage AI |
| RealVision AI | The same $500 to $5,000 range, plus a $10,000 Florida case and a claim that 38 states now require disclosure, up from 22 in 2023. This one carries a byline and a date, and still links to no statute, no MLS handbook and no case. “MLS Virtual Staging Rules Guidelines”, RealVision AI |
| CRMLS | The largest MLS in the country, in its own knowledgebase, for the rule in force since 1 January 2026: label the image in the photo description field, put the unaltered original immediately before or after it, and “Violating this rule will result in a warning at first and then, if not corrected in a timely manner, a $250 fine.” CRMLS Rule 11.5.2 FAQ |
| Bay East | The same duties from the same date, worded differently: submit the original, display it immediately after the altered image, and mark the altered image “altered,” “digitally altered” or “AI altered.” It names no dollar figure at all, only enforcement under its rules and regulations. Bay East, “Digitally Altered MLS Photo Rule” |
| California AB 723 | The statute both MLS rules were written to implement sets no dollar penalty of its own. The $250 that circulates as an AB 723 fine is not in the bill; it is CRMLS charging for an uncorrected violation on its own system, and an agent who lists elsewhere would never meet it. AB 723 bill text, California Legislature |
AI-generatedClaim four: the states that have not passed anything
The fourth claim comes in two sizes. One page says 38 states now require virtual staging disclosure, up from 22 in 2023. Another says California, New York, Texas, Florida and Illinois have all introduced or passed disclosure bills between 2024 and 2026.
Neither page links to a single one of the statutes it is counting. That is the tell, and with a count in the dozens it is a decisive one: a list of 38 states that exists would be published as a list, because a list is the useful form of that claim and the easiest thing in the world to link. “MLS Virtual Staging Rules Guidelines”, RealVision AI
Texas is the one worth checking, because it is named specifically and because a summary in circulation says the Texas Real Estate Commission updated its advertising rules in 2025 to cover digitally altered visual representations. The rule usually cited, 22 Texas Administrative Code section 531.18, is titled Consumer Information and is about giving consumers the commission’s Consumer Protection Notice. It says nothing about images. 22 Tex. Admin. Code 531.18 (consumer information)
What Texas does have is older and broader. Under the Texas Real Estate License Act the commission may discipline a licensee who publishes an advertisement that misrepresents a property or is likely to deceive the public. That reaches a generated photograph comfortably. It is also not new, not AI specific, and not a disclosure requirement: it tells a licensee what they may not do, not what they must say. Tex. Occ. Code ch. 1101, the Texas Real Estate License Act
New York is the instructive case, because the state genuinely did act and what it did was still not a rule. On 13 November 2025 the Department of State issued a trend alert warning homebuyers about generated listing images, quoting the Secretary of State that such tools “may produce misleading or exaggerated representation of properties.” The alert imposes nothing new. It points at 19 NYCRR 175.25(c)(9), which requires an honest and accurate depiction, at Real Property Law 441-c for discipline, and at the General Business Law provisions on deceptive acts. New York Department of State trend alert on AI generated listings, 13 November 2025
A bill that would go further, S9584, is before the New York Senate and has not passed. Counting New York as a state that requires AI photo disclosure turns a consumer alert and a pending bill into law, which is the same move that turned a workgroup discussion into a RESO field. New York Senate Bill S9584
The honest count as of September 2026 is two. California AB 723 has been in force since 1 January 2026, and 2025 Wisconsin Act 69 creates section 452.136 (1m) from 1 January 2027. Everywhere else, a misleading listing photograph is reached by advertising and licensing law that was already there, which is real and enforceable and simply does not tell anyone what to write under a picture. Wis. Stat. 452.136 (1m) (advertising enhanced by technology)
The claim
38 states
Up from 22 in 2023, on a page that links to no statute for any of them and publishes no list of which states they are.
Statutes written for this
Two
California AB 723, in force since 1 January 2026, and 2025 Wisconsin Act 69, creating section 452.136 (1m) from 1 January 2027.
Everywhere else
Law that predates it
Texas reaches it through the licensing act’s bar on advertisements that misrepresent a property. New York through honest advertising rules and, since November 2025, a consumer alert. Both real, neither new.
What is actually true in September 2026
The surviving list is shorter than the invented one, and more demanding, because everything on it names a document, a date and a consequence.
California AB 723 has applied since 1 January 2026. A licensee using a digitally altered image in advertising has to disclose it and make the unaltered original available, and the duty sits inside the Real Estate Law, so a wilful failure is an offence rather than a fee. It sets no dollar penalty. AB 723 bill text, California Legislature
Wisconsin follows on 1 January 2027 with a shorter rule and a condition attached: section 452.136 (1m) requires a licensee to disclose in all advertising that it was altered using technology, including artificial intelligence, to add, remove or change elements of the property in a way that creates a false or misleading impression of it. No wording is prescribed, no placement, and no original. Wis. Stat. 452.136 (1m) (advertising enhanced by technology)
The MLS rules are what most agents will meet first, and they arrived before either statute could bite. CRMLS and Bay East both started on 1 January 2026, both require the unaltered original beside the altered image, and both specify the label in their own words. They do not match each other, which is the operative fact: a photo compliant on one system can be short an element on the next. CRMLS Rule 11.5.2 FAQ
In the data layer, the mechanism that carries all of this is OriginalMediaUrl on the Media resource, approved by RESO in February 2026 for Data Dictionary 2.2. It is how the original photograph travels with the altered one through a feed, which is what AB 723 needs and what no boolean could have provided. RESO product updates, Data Dictionary roadmap and approved additions
Behind all of them sits NAR’s Article 12 and Standard of Practice 12-10, unchanged, applying to every member in every state, and New York’s Department of State alert, which changes no rule but tells its licensees the department is looking. Two statutes, a set of MLS rulebooks that disagree with each other, one new field and an ethics standard from 2007. That is the whole of it. New York Department of State trend alert on AI generated listings, 13 November 2025
How to check a claim like these in five minutes
- Ask which document. A real rule has a name and a number: a bill, a section of an administrative code, a numbered MLS rule. A claim that names only an organisation has not been checked by whoever wrote it either. CRMLS Rule 11.5.2 FAQ
- Go to the organisation’s own site rather than a summary of it. RESO publishes its current version, its version history and every approved addition, and all three are one click from its front page. RESO Data Dictionary, current and legacy versions
- Check the version and the date against each other. A version number lower than the current one cannot be the version that introduced something this year, which is what settled the AIImageModified claim without needing to search for the field at all. RESO specifications library
- When a claim says a body changed a rule, read that body’s own list of what it changed. NAR publishes one every year, and the Standard everybody was told had been amended is simply not on it. NAR, 2025 Summary of Key Professional Standards Changes
- Treat a dollar figure as belonging to one rulebook until proven otherwise. Fines are set by the organisation that collects them, so a range quoted for MLSs in general almost certainly came from nowhere in particular. Bay East, “Digitally Altered MLS Photo Rule”
- Keep statute, guidance and MLS rule in separate mental columns. New York’s alert is real and is not law; CRMLS’s $250 is real and is not a state penalty; AB 723 is law and sets no fine. Collapsing the three is how most of these claims were born. New York Department of State trend alert on AI generated listings, 13 November 2025
- If nothing links to the source, that is the finding rather than an inconvenience. Every claim in this post that failed was on a page that named an authority and linked to none, and every claim that held up was one sentence away from the document itself. “What are the AI virtual staging disclosure rules real estate agents must follow in 2026?”, colossis.io
Read next
The rest of the series
California AB 723: what virtual staging disclosure actually requires
The statute behind the MLS rules and the RESO field, read section by section, including where the $250 that circulates as a state fine actually comes from.
Wisconsin Act 69: what the AI advertising disclosure actually requires
The second statute, from 1 January 2027, and the three things already being got wrong about it by the same kind of page that produced the claims above.
What UK agents must disclose when a listing photo is digitally altered
The same question outside the United States, where there is no photo statute at all and a general prohibition on unfair commercial practices has to do the work.
Why AI-staged listing photos look fake, and what buyers actually notice
What a buyer notices before any of this applies, which is the thing every one of these rules is ultimately written about.
Questions
Common questions
Is AIImageModified a real RESO Data Dictionary field?
No. It does not appear in the RESO Data Dictionary, and the version it is attributed to, 1.9, is not a version RESO has published. The current certified version is 2.0, approved on 23 October 2023.
RESO Data Dictionary, current and legacy versionsIs there a RESO Data Dictionary 1.9?
No. RESO’s published versions run 1.4, 1.5, 1.6, 1.7 and then 2.0, with 2.1 in draft and 2.2 taking approved additions. A 1.9 would also have to predate 2.0, so it could not be a 2026 release.
RESO specifications libraryWhat field did RESO actually add for altered listing images?
OriginalMediaUrl, a string on the Media resource, approved in February 2026 for Data Dictionary 2.2. It holds the URL of the original, unaltered version of a media file, and it was added for California AB 723 rather than as an AI flag.
RESO product updates, Data Dictionary roadmap and approved additionsDid NAR add an AI disclosure rule to the Code of Ethics in 2025?
No. The 2025 changes took effect on 5 June 2025 and amended Article 4, three Standards of Practice plus a new 4-2, and eleven further Standards. None concerns artificial intelligence or altered images, and Standard of Practice 12-10, the one about misleading images, was not among them.
NAR, 2025 Summary of Key Professional Standards ChangesIs there a $500 to $5,000 MLS fine for undisclosed virtual staging?
Not one that any MLS has published. The range is repeated across vendor pages with no rulebook cited. CRMLS, which does publish its schedule, issues a warning first and then a $250 fine if the violation is not corrected; Bay East sets out the same duties and no dollar figure.
CRMLS Rule 11.5.2 FAQHow many US states require disclosure of AI-altered listing photos?
Two have passed a statute about it: California, in force since 1 January 2026, and Wisconsin, from 1 January 2027. Claims of 38 states, or of bills passed in Texas, Florida and Illinois, are not supported by the rules those states publish.
22 Tex. Admin. Code 531.18 (consumer information)Every claim on this blog is read against the document it came from before it is printed, and the ones that do not clear that bar are printed here with the pages that made them, so a reader can repeat the check rather than take it on trust.