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Virtual Staging in New York

Compliance guide for real estate professionals

Allowed - Per-Image Labeling Required

New York Department of State has issued guidance warning that digitally altered images in real estate listings may constitute deceptive advertising. NYCRR Title 19 Part 175.25 requires honest, non-misleading advertising by licensees.

⚠️Potential Penalties in New York

License revocation or suspension possible under NYCRR Title 19. Civil penalties for deceptive advertising practices.

How to Stay Compliant

1

Label every digitally altered image individually

NYCRR Title 19, Part 175.25 requires that real estate advertising be honest and not misleading. The NY Department of State has specifically warned about AI-generated and digitally altered images in listings. Each staged image should be individually labeled with a watermark or embedded text stating 'Virtually Staged' or 'Digitally Altered.'

Tip: Batch process your staged images with a watermarking tool—this ensures consistent labeling without slowing down your workflow.
2

Use watermarks that persist across platforms

Images get reshared, screenshotted, and posted to social media. Your watermark must be embedded in the image file itself (not just added by your MLS) so disclosure travels with the image no matter where it appears.

Tip: Place watermarks within the image boundaries rather than in margins—some platforms crop edges automatically.
3

Keep comprehensive records of original photos

Under NY advertising regulations, undisclosed staging could be treated as deceptive advertising. Maintain original, unedited photographs for every staged image. If the Department of State investigates a complaint, having originals readily available demonstrates you acted in good faith.

Tip: Use cloud storage with date stamps to prove when original photos were taken and stored.
4

Be aware of NYC co-op and condo board scrutiny

NYC co-op and condo boards sometimes have their own marketing guidelines. Some boards require specific disclosures or prohibit certain types of image modification. Check with the managing agent before marketing with virtual staging.

Tip: Ask the listing's managing agent: 'Are there any building-specific photo or marketing requirements I should know about?'
5

Consider the NYC buyer demographic

New York buyers, particularly in competitive markets like Manhattan and Brooklyn, often work in finance, law, and media—industries with heightened sensitivity to disclosure and misrepresentation. Professional, thorough disclosure enhances credibility with this demographic.

Tip: In your listing, frame virtual staging positively: 'We've included virtually staged images to help you visualize the space's potential, alongside original photos showing current condition.'
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Disclosure Templates

— Copy-ready for United States

MLS Listing

"Images have been virtually staged to illustrate the property's potential. Furniture and decor 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 home features virtual staging to help you visualize its potential. The furniture shown is digitally added and not physically present. Schedule a showing to see the actual space. #VirtualStaging #RealEstate"

Property Website

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

Image Watermark

"VIRTUALLY STAGED – Furniture shown is digitally rendered"

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Sources & References

→NYCRR Title 19, Part 175.25 (Real Estate Advertising Regulations)
→NY DOS Alert: AI-Generated Images in Real Estate Listings
→NY Department of State Division of Licensing Services
→NY Real Property Law §443 (Disclosure Requirements)
Primary: NY Department of State - Real Estate Licensing · Visit →
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