AB 723 listing photo disclosure, before the photos hit the MLS.
Since January 1, 2026, California's AB 723 requires every digitally altered listing photo to carry a disclosure on or next to it, plus a link or QR code to the original, unaltered image. CRMLS Rule 11.5.2 also puts the original immediately before or after the altered photo in the MLS. RetouchLint records what changed in each photo and writes the disclosure for you.
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What the law requires
AB 723 needs two things on every altered listing photo — and CRMLS adds a third.
Business and Professions Code § 10140.8 applies to brokers, salespersons, and anyone acting on their behalf — including the photographer who edits the shoot. An image is "digitally altered" when editing software or AI adds, removes, or changes elements such as furniture, appliances, flooring, paint, landscape, the facade, or views through windows. Lighting, white balance, color correction, straightening, cropping, and exposure alone are exempt.
On or adjacent to the altered image, reasonably conspicuous, saying the image has been altered and that the unaltered images can be accessed at the linked website, URL, or QR code.
A link, URL, or QR code to a publicly accessible page that includes, and clearly identifies, the original, unaltered image.
CRMLS Rule 11.5.2 requires the unaltered photo immediately before or after the altered one in the listing, with the altered photo labeled in its photo description.
How RetouchLint delivers it
Pair each original with its final and tag what changed, using the statute's line between altered elements and exempt adjustments like exposure or color correction.
Copy-paste disclosure language for the MLS photo description, remarks, and marketing.
The photographer or editor signs a statement of the work performed, so the agent's disclosure rests on a record rather than memory.
Each original shown beside its published final with the edit list. Packets are stored in your browser, so publish the originals where the public can open them and add that URL to the packet — it goes straight into the disclosure.
Free AB 723 disclosure generator · real estate photo disclosure guide · California photo disclosure under AB 723 · giving buyers access to the original image · MLS edited-photo compliance
The problem
Edited listing photos quietly create disclosure risk.
Sky replacements, virtual staging, removed furniture, and "just a little" lawn enhancement are routine in listing photos. Often nobody keeps a record of what was changed, by whom, or whether buyers were told.
When a complaint, audit, or lawsuit shows up, the agent and the photographer are left reconstructing the edit history from memory — sometimes years later.
RetouchLint creates the paper trail at the moment of editing, not after the dispute.
The workflow
Four steps from raw files to a broker-ready disclosure packet.
Drag in the source photos and the edited versions you plan to publish.
Match each final to its original, then check off what changed — sky, staging, lawn, defects.
The photographer or editor signs a short attestation describing the work performed.
RetouchLint tells you whether AB 723 disclosure applies and writes the copy-paste disclosure language.
What's in the packet
A record of what changed in every listing photo, and who changed it.
Each published final is paired with the source photo it came from, so what changed is visible side by side.
Tag each edit against AB 723's line between digital alterations and exempt adjustments like exposure or color correction.
The photographer or editor signs a statement of the work performed, stamped with the date and time of signing.
Copy-paste wording that says the photos were altered and where the originals can be seen, with your link to the originals filled in.
A page showing each original beside its final and the edit list. Packets are stored in your browser, so host the originals publicly for the AB 723 link.
Save the disclosure text as a file to send along with the photo delivery.
Pricing
Simple, per-listing or per-seat.
Best for one-off transactions or testing the workflow.
- 1 disclosure packet
- Public original-photo page
- PDF audit packet
- 30-day archive
Active agents and independent photographers.
- Unlimited packets
- Brokerage branding
- 1-year archive
- Email support
Teams that need shared compliance records.
- Unlimited seats & packets
- Centralized broker dashboard
- Permanent archive
- Priority support
AB 723 FAQ
Questions agents and photographers ask about AB 723
Who does AB 723 apply to?
A real estate broker or salesperson, or a person acting on their behalf, who includes a digitally altered image in an advertisement or other promotional material for the sale of real property. A photographer or editor producing listing images at an agent's direction is working on the agent's behalf, so the agent's disclosure depends on the photographer's record of what changed.
Which edits make a listing photo "digitally altered" under § 10140.8?
Adding, removing, or changing elements in the image with photo-editing software or AI — the statute lists fixtures, furniture, appliances, flooring, walls, paint color, hardscape, landscape, facade, floor plans, and elements outside or visible from the property such as streetlights, utility poles, views through windows, and neighboring properties. The list is "including, but not limited to", so it is not exhaustive.
Do color correction and exposure edits need a disclosure?
No. The statute excludes images where only lighting, sharpening, white balance, color correction, angle, straightening, cropping, exposure, or other common adjustments were made that do not change the representation of the property.
What does the disclosure itself have to say?
It must state that the image has been altered, be reasonably conspicuous and located on or adjacent to the image, and include language saying the unaltered images can be accessed at the linked website, URL, or QR code. The link must lead to a publicly accessible page that includes and clearly identifies the original, unaltered image.
What does CRMLS Rule 11.5.2 add on top of AB 723?
CRMLS requires the original, unaltered photo to appear in the MLS listing immediately before or after the digitally altered one, and the altered photo to be labeled in the photo description field. Other MLSs have their own versions — Bay East's rule, also numbered 11.5.2, requires the original immediately after the altered image — so check your board's rules.
When did AB 723 take effect?
January 1, 2026. AB 723 was signed on October 10, 2025 and added Section 10140.8 to the California Business and Professions Code.
More in the full photo disclosure FAQ. RetouchLint does not provide legal advice.
Stop reconstructing edit history after the fact.
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