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Virtual Staging in England

Compliance guide for real estate professionals

Allowed with Disclosure

Estate agents and letting agents in England must comply with the Estate Agents Act 1979 (estate agents only), the Digital Markets, Competition and Consumers Act 2024 (DMCC Act), and the Committee of Advertising Practice (CAP) Code. Additionally, all residential estate agents must belong to a redress scheme under the Consumers, Estate Agents and Redress Act 2007, and letting agents must belong to a redress scheme under the Redress Schemes for Lettings Agency Work and Property Management Work. Both estate agents and letting agents may join The Property Ombudsman (TPO) or the Property Redress Scheme (PRS), and must comply with the applicable Code of Practice.

The Competition and Markets Authority (CMA) and local Trading Standards authorities enforce the DMCC Act, which makes misleading commercial practices, including property marketing, a criminal offence, punishable by a fine and/or up to two years imprisonment.

The National Trading Standards Estate and Letting Agency Team (NTSELAT) enforces the Estate Agents Act 1979, which provides the general regulatory framework for estate agents. While the Act does not specifically address virtual staging, convictions for breaches of the DMCC Act can serve as a "trigger offence" under the Estate Agents Act 1979, allowing NTSELAT to issue warning orders or prohibition orders banning estate agents from practice.

The Advertising Standards Authority (ASA) enforces the CAP Code, which requires all marketing materials to be legal, decent, honest and truthful. While the ASA cannot impose criminal penalties, they can refer non-compliant advertisers to Trading Standards for prosecution under the DMCC Act.

The Property Ombudsman Code of Practice for Residential Estate Agents and Code of Practice for Residential Letting Agents require all statements about a property, including oral, pictorial, and written, are accurate and not misleading. These codes currently reference the Consumer Protection from Unfair Trading Regulations 2008 (CPRs), which were replaced by the DMCC Act on April 6, 2025.

The PRS does not have a formal published Code of Practice like TPO, but members must still comply with all relevant consumer protection legislation, including the DMCC Act.

⚠️Potential Penalties in England

Misleading property marketing materials can result in criminal prosecution under the DMCC Act, including a fine and/or up to 2 years imprisonment. Convictions can lead to NTSELAT prohibiting estate agents from practising.

How to Stay Compliant

1

Apply visible labelling to all digitally enhanced images

The DMCC Act and CAP Code require that marketing materials not mislead consumers. Add clear labels such as 'Virtually Staged' or 'Digitally Enhanced Image' to each modified photograph. The label should be visible at all sizes the image might be displayed.

Tip: Use a watermark positioned in the lower portion of the image where it won't be cropped by portal thumbnail generators.
2

Include original photographs in your property particulars

Transparency in property marketing is essential under the DMCC Act and redress scheme codes. Provide original, unedited photographs alongside any staged versions.

Tip: Lead your gallery with one or two hero staged shots, then immediately follow with original photos—this shows the property's potential while maintaining transparency.
3

Stage only moveable furniture and soft furnishings

The DMCC Act prohibits creating a misleading impression about a property. Digitally altering structural elements such as walls, flooring, fixtures, windows, or gardens would likely constitute a misleading practice and should be avoided. Staging should be limited to items a viewer would understand are not part of the property sale: furniture, artwork, rugs, and decorative items.

Tip: Ask yourself: 'Would a buyer expect this to be included in the sale?' If no, you can stage it. If yes (fitted kitchens, flooring, light fixtures), don't alter it.
4

Add written disclosure to property particulars

Beyond image labelling, include a written statement in your property particulars: 'Some photographs in this marketing material have been virtually staged with digital furniture. Original photographs are available upon request.'

Tip: Property particulars should already have a disclaimer section—add staging disclosure there for consistency.
5

Comply with your redress scheme requirements

If you're a member of The Property Ombudsman (TPO) or Property Redress Scheme (PRS), you must comply with their requirements for honest marketing. Virtual staging complaints can result in investigations and sanctions. Review your scheme's guidance on digital imagery and ensure your practice aligns with their expectations.

Tip: TPO publishes case summaries—review any relating to photography complaints to understand what triggers investigations.
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Disclosure Templates

— Copy-ready for United Kingdom

Property Listing

"Images have been virtually staged to illustrate the property's potential. Furniture and décor shown are digitally rendered and are not included with the property. Please refer to the original photographs for an accurate representation of the property's current condition."

Social Media

"This property features virtual staging to help you visualise its potential. The furniture shown is digitally added and not physically present. Book a viewing to see the actual space. #VirtualStaging #PropertyMarketing"

Property Website

"This listing includes virtually staged photographs. Digital furniture and décor have been added to help you visualise the space. These items are not present in the physical property. Unstaged photographs are available upon request."

Image Watermark

"VIRTUALLY STAGED – Furniture shown is digitally rendered"

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Sources & References

Digital Markets, Competition and Consumers Act 2024
UK Government Press Release (April 7, 2025)
UK Parliament Research Briefing (July 8, 2025)
Chartered Trading Standards Institute: Property Descriptions
ASA: Ensuring your marketing complies with the CAP Code (Sept 2023)
The CAP Code, Edition 12
TPO Code of Practice for Residential Estate Agents
TPO Code of Practice for Residential Letting Agents
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