Virtual Staging in Toronto

Ontario · Regulator guidance · Guidance · RECO Guidance - Use of Artificial Intelligence, 'AI in Practice: Maintain visual transparency'; cites TRESA ss. 26, 34, 35, 37 and O. Reg. 365/22 ss. 5, 8, 12

Ontario's regulator says brokerages and agents must make sure virtual staging or AI modifications accurately reflect a property's permanent features and must clearly label any digitally altered images. AI-enhanced visuals must comply with all TRESA advertising obligations.

Disclosure

Clearly label any digitally altered images; location of the label is not specified.

Original photo

Not specified

Effective

October 22, 2026

Last verified

October 23, 2026

“Maintain visual transparency: Ensure virtual staging or AI modifications accurately reflect permanent features and clearly label any digitally altered images.”

Source: RECO Guidance - Use of Artificial Intelligence

The date is the page's publication metadata (2026-10-22); the page itself shows no issue date. This is regulator guidance framed as 'must', but the label wording and placement are not prescribed.

Ontario · Decision · In force · RECO Discipline Committee, File #2020100637, Penalty and Reasons for Decision (signed April 14, 2026; posted April 17, 2026); finding decision released September 23, 2025

Two co-listing registrants edited hydro towers out of a listing photo in 2020 and circulated it without disclosing the edit. The panel found breaches of ss. 38 and 39 of the former Code of Ethics. It fined each $5,000 and ordered each to take RECO's advertising compliance course.

Disclosure

The panel faulted circulating the edited photo without any disclaimer or indication that it had been modified; no specific wording or placement is set out.

Original photo

Not specified

Penalty

$5,000 fine for each registrant plus completion of RECO's 'MCE Advertising Compliance' course

Effective

April 2026

Last verified

October 23, 2026

“permitting the photograph to be circulated without any disclaimer or indication that it had been modified.”

Source: RECO v. Angelo Christopher D'Amico and Dayana D'Amico - Penalty and Reasons for Decision

Medium confidence: see the note below.

This case removed a real feature (hydro towers); it is not about adding virtual furniture. The conduct dates from 2020 under the former REBBA 2002 Code of Ethics (ss. 38 and 39). I read the penalty decision, a scanned PDF processed with OCR, but not the September 2025 finding decision. RECO's summary is at https://www.reco.on.ca/enforcement/recent-regulatory-actions/.

Ontario · MLS rule · In force · PropTx MLS® Rules (effective December 2, 2024), Article 5 - Advertising, Rule 5.01(a)

PropTx, the MLS® system used by TRREB members, bars digitally altered images from listings, including AI-created, altered or enhanced images and digital staging, when they do not accurately depict the listed real estate. The rule does not prescribe a label, and it does not say that staging which depicts the property accurately must be disclosed.

Disclosure

Not specified

Original photo

Not specified

Penalty

Not specified in the rule; Rule 2.02 says non-compliance is handled under the Association's professional standards and disciplinary procedures.

Effective

December 2, 2024

Last verified

October 23, 2026

“Digitally altered images including the use of any artificial intelligence (“AI”) system or technology to create, alter, or enhance images or digital staging that do not accurately depict the listed real estate”

Source: PropTx MLS® Rules, effective December 2, 2024

Binds PropTx MLS® users, not the general public. Whether staging that depicts the property accurately is allowed without a label is not stated; RECO's AI guidance separately expects altered images to be labelled.

Canada · Regulator guidance · Guidance · Competition Act s. 52 and para. 74.01(1)(a); Competition Bureau 'The general impression test'

The Competition Bureau says courts judge an ad by its general impression, not just its literal words, and that a photo or illustration can make a literally true ad misleading. It also advises against using illustrations that differ from the product being sold. This is general advertising guidance and does not mention real estate or virtual staging.

Disclosure

Not specified; the Bureau warns that fine print disclaimers often fail to change the general impression of an ad.

Original photo

Not specified

Penalty

Per the Bureau's page: civil administrative monetary penalties up to $750,000 (individuals) / $10,000,000 (corporations) on first occurrence; criminal fines up to $200,000 and/or 1 year on summary conviction, or court-discretion fines and/or up to 14 years on indictment.

Effective

Not stated

Last verified

October 23, 2026

“The text of the marketing message is literally true, but the accompanying photo or illustration creates a false or misleading impression.”

Source: The general impression test - Competition Bureau Canada

General federal law on misleading advertising; no Bureau guidance specific to listing photos or virtual staging was found. Penalty figures are as stated on the Bureau's 'False or Misleading Representations and Deceptive Marketing Practices' page (modified 2026-02-19); check the Act for the current maximums.

Canada · Industry code · In force · REALTOR® Code, Article 13 interpretation and 13.2; see also Article 3.2

CREA's members' code requires all advertising and promotion of properties to accurately reflect the property, and treats every page of a REALTOR®'s website as advertising. Article 3.2 bars intentionally misleading anyone about a property. It does not mention photos, image editing or virtual staging.

Disclosure

Not specified

Original photo

Not specified

Effective

Not stated

Last verified

October 23, 2026

“All Advertising and promotion of properties shall accurately reflect property and other details and prominently display the name of the brokerage and any additional information required by provincial regulation.”

Source: REALTOR® Code (CREA)

General accuracy duty only; applies to CREA members (REALTORS®), not all licensees. PDF is marked (c) 2011-2023 and is the version linked from crea.ca.

Ontario · Law · In force · Trust in Real Estate Services Act, 2002, S.O. 2002, c. 30, Sched. C, s. 37 (registrar orders under s. 38)

Ontario registrants must not make false, misleading or deceptive statements in any advertising about trading in real estate. The section is general and does not mention photos or staging; RECO's AI guidance cites it as the basis for its labelling expectation.

Disclosure

Not specified

Original photo

Not specified

Effective

Not stated

Last verified

October 23, 2026

“No registrant shall make false, misleading or deceptive statements in any advertisement, circular, pamphlet or material published by any means relating to trading in real estate.”

Source: Trust in Real Estate Services Act, 2002 (e-Laws)

General misleading-advertising ban; it does not address photos or virtual staging. Under s. 38 the registrar may order a registrant to stop using material or to publish a correction.

Ontario · Law · In force · O. Reg. 365/22 (Code of Ethics), s. 5

Ontario registrants must make best efforts to ensure their representations are accurate and not misleading, and must not engage in misrepresentation. The section is general and does not mention photos or staging.

Disclosure

Not specified

Original photo

Not specified

Effective

December 1, 2023

Last verified

October 23, 2026

“shall make best efforts to ensure that any representations are accurate and are not misleading”

Source: O. Reg. 365/22: Code of Ethics (e-Laws)

General duty only. The date shown is the start of the current consolidation period. The Code of Ethics has no advertising section; brokerage-name advertising rules are in O. Reg. 567/05, s. 12.1.