What does AB-723 require for listing photos?

AB-723 requires clear disclosure on or adjacent to materially altered listing images and a publicly accessible way to view originals (URL/QR). The failure mode is operational: teams cannot reliably pair altered images to originals later, across every place the listing appears. The defensible standard is repeatable: originals retrievable fast, alteration map maintained, proof link durable, broker review recorded.

AB-723: Listing Photos Need Proof, Not Polish

What the law requires in plain English

California Assembly Bill 723 (AB-723) took effect January 1, 2025. It amends Business and Professions Code Section 10140.6 to require real estate licensees who use digitally altered listing images to:

Disclose clearly that the image has been materially altered
Provide a way for consumers to view the original, unaltered image

"Material alteration" covers changes that affect how a reasonable buyer would perceive the property-think virtual staging, sky replacement, object removal, or AI-enhanced landscaping. It does not cover routine adjustments like color correction, cropping, or exposure fixes.

The law says the disclosure must be "clear and conspicuous" and appear "on or adjacent to" the altered image. It also says consumers must be able to access the original via a "URL, QR code, or other easily accessible method."

What this means operationally

The words "easily accessible method" and "on or adjacent to" sound simple-until you think about where listing images actually appear:

MLS feeds
Portal syndication (Zillow, Realtor.com, Redfin, etc.)
Agent websites
Social media posts
Print brochures and flyers
Email marketing
Open house materials

Each of these surfaces has different technical constraints. Some strip metadata. Some compress images. Some do not allow embedded links. The law does not exempt any of them.

Where teams get tripped up

The hardest part of AB-723 is not understanding the rule-it is maintaining an auditable link between every altered image and its original, across every distribution channel, for as long as the listing is active (and possibly longer, if disputes arise).

Here are the four most common failure modes we see:

1. Originals are missing or unfindable

The photographer delivered enhanced images, but the RAW or unedited versions were never requested, stored, or organized. When a disclosure is challenged, there is no original to point to.

2. No mapping between altered and original

Even if originals exist, teams cannot reliably identify which original corresponds to which altered image-especially when there are 30+ photos per listing and multiple rounds of edits.

3. Proof link is not durable

The URL or QR code pointed to a staging environment, a cloud folder that was reorganized, or a page that was taken down after the listing closed. When someone checks the link, it is dead.

4. Broker review not recorded

The listing agent made a good-faith disclosure, but there is no record that the broker reviewed and approved the enhanced media and the disclosure language-leaving the brokerage exposed.

A workflow standard that holds up

Based on the failure modes above, here is a simple, defensible workflow standard any team can adopt:

Step 1: Originals retrievable fast

Before any image is enhanced, the original (unedited or minimally edited) version must be stored in a durable location with a stable file naming convention. This is not about archiving-it is about retrieval. If you cannot find the original in under 60 seconds, the system does not work.

Step 2: Alteration map maintained

Every enhanced image should have a clear link to its corresponding original. This can be a spreadsheet, a folder structure, or a purpose-built tool-but it must be explicit and maintained throughout the listing lifecycle.

Step 3: Proof link durable

The URL or QR code you provide to consumers must resolve to the original image (or a gallery of originals) for as long as the disclosure obligation persists. This means:

No links to internal staging environments
No links to cloud folders that might be reorganized
No links to pages that will be deleted when the listing closes

A durable proof link should be:

Publicly accessible
Stable across listing lifecycle
Auditable (you can prove the link worked on a given date)

Step 4: Broker review recorded

Before the listing goes live, the broker (or designated reviewer) should confirm:

That the enhanced images are appropriately disclosed
That the proof link is functional
That the disclosure language meets MLS and legal requirements

This review should be timestamped and stored-not just a verbal sign-off.

Quick gut-check checklist

Use this before any listing with enhanced images goes live:

[ ] Do I have the original (unaltered) version of every enhanced image?
[ ] Can I match each enhanced image to its original in under 60 seconds?
[ ] Is the proof link publicly accessible and tested?
[ ] Will the proof link still work after the listing closes?
[ ] Has the broker (or designated reviewer) confirmed the disclosure and proof link?
[ ] Is there a timestamped record of that review?

If you answer "no" or "I'm not sure" to any of these, stop and fix it before publishing.

If you are outside California

AB-723 is a California law-but the underlying trend is not limited to one state.

NAR's MLS Technology and Emerging Issues Advisory Board has discussed AI and image manipulation disclosure as a 2025 priority.
Several regional MLSs are already implementing their own enhanced media disclosure fields and workflows.
Consumer advocacy groups are watching how California enforces AB-723 as a model for other states.

If you operate outside California, you have a window to build these workflows before your state or MLS catches up. If you operate in California, the window is already closed-you need these workflows now.

What MLSs can do to help

MLSs are in a unique position to reduce compliance friction for their members. Here are three simple steps any MLS can take:

1. Publish a workflow standard

Give members a clear, simple standard for how to disclose enhanced images and link to originals. This does not have to be proprietary-it just needs to be explicit and consistent.

2. Enable proof link fields

Add a field in the listing entry workflow where agents can paste a proof link (URL or QR code location). This makes the disclosure auditable and reduces the risk of links being lost in remarks fields.

3. Provide sample disclosure language

Give members templated language for the "clear and conspicuous" disclosure. This reduces ambiguity and ensures consistency across listings.

References

California Legislative Information. Assembly Bill No. 723. (2024). [https://leginfo.legislature.ca.gov/](https://leginfo.legislature.ca.gov/)

California Business and Professions Code Section 10140.6.

National Association of REALTORS. MLS Technology and Emerging Issues Advisory Board. (2024–2025).

California Department of Real Estate. Guidance on Digital Marketing and Advertising. (2024).

Various MLS rules and compliance bulletins regarding enhanced media disclosure.

AB-723 Is Live in California: Listing Photos Now Need Proof, Not Just Polish