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Virtual Staging in Northern Ireland

Compliance guide for real estate professionals

Allowed with Disclosure

Estate agents and letting agents in Northern Ireland 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, such as The Property Ombudsman (TPO) or the Property Redress Scheme (PRS), and must comply with the applicable Code of Practice. Letting agents are not legally required to belong to a redress scheme, but may voluntarily join TPO or PRS.

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 the 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 Northern Ireland

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, across all property portals and marketing materials.

Tip: Property portals may crop images differently in gallery views—position watermarks where they remain visible at all display sizes.
2

Provide both staged and original photographs

Include original, unedited photographs in your marketing materials. Local Trading Standards authorities in Northern Ireland enforce the DMCC Act and expect transparency—buyers should be able to see the property's actual condition alongside any visualisation of potential.

Tip: Create a 'Current Condition' section in your gallery that buyers can refer to after viewing staged images.
3

Stage soft furnishings and décor only

The DMCC Act applies to Northern Ireland, making misleading marketing a criminal matter. Limit staging to furniture, artwork, and decorative items that wouldn't be included in the sale. Digitally altering structural features, gardens, views, or fitted items would likely constitute a misleading practice and should be avoided.

Tip: Northern Ireland has many rural properties with agricultural views—digitally altering landscapes or removing neighbouring farm buildings could constitute misleading marketing under the DMCC Act.
4

Ensure disclosure across all marketing materials

Include written disclosure in property particulars (printed and online), on your website, in social media posts, and portal listings. Consistency across all channels is essential—local Trading Standards authorities can investigate any misleading marketing touchpoint.

Tip: Create a standard disclosure statement to include in every listing: 'Some images have been virtually staged with digital furniture to illustrate potential. Original photographs are available.'
5

Comply with redress scheme requirements (for estate agents)

All residential estate agents in Northern Ireland must belong to a government-approved redress scheme. If you're a member of The Property Ombudsman (TPO) or Property Redress Scheme (PRS), you must comply with their requirements for honest and accurate property marketing. Virtual staging complaints can result in investigations and sanctions.

Tip: TPO publishes case summaries—review any relating to photography or marketing complaints to understand what triggers investigations.
6

Follow RICS and Propertymark guidance

RICS (Royal Institution of Chartered Surveyors) and Propertymark provide professional guidance applicable in Northern Ireland. Their standards often exceed minimum legal requirements—following professional body guidance demonstrates best practice.

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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
Propertymark: UK Regulation of Estate and Letting Agents
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