Wisconsin Virtual Staging Rules: Act 69 and Wisconsin MLS Rules

Wisconsin (all real estate licensees) · Wis. Stat. §452.136(1m), created by 2025 Wisconsin Act 69

From January 1, 2027, Wisconsin licensees must disclose in all advertising when it has been altered with technology, including AI, to add, remove or change elements of the property in a way that creates a false or misleading impression.

Where to disclose

Disclosure in the advertising; the law does not specify wording or placement.

Original photo

Not specified

Effective

January 1, 2027

Last verified

October 22, 2026

“A licensee shall in all advertising disclose if the advertising has been altered or modified using technology, including artificial intelligence, to add, remove, or change elements of the property that creates a false or misleading impression of the property.”

Source: 2025 Wisconsin Act 69 (2025 Assembly Bill 456), Wisconsin Legislature

Enacted December 9, 2025. Your MLS’s own rules still apply on top of the law.

North-central Wisconsin · Policies & Procedures Section III, items E and F

Virtually staged photos must be clearly watermarked on the face of the photo, with furniture in accurate proportion. Material changes such as adding fixtures or removing power lines are not allowed unless actually made before sale, and public remarks must disclose digitally edited photos.

Where to disclose

Watermark on the face of the photo, and a public remarks disclosure for digitally edited photos.

Original photo

Not specified

Penalty

Warning, then $50, $100, $250 and $500 per firm within 12 months; up to $2,500 per offence by the Board

Effective

Not stated

Last verified

October 22, 2026

“Photos included in the MLS that have been virtually staged (i.e. adding furniture, etc.) must be clearly watermarked on the face of the photo disclosing it was virtually staged.”

Source: GNMLS Policies & Procedures (August 2026)

Southeast Wisconsin (Milwaukee) · MLS Procedures, “Listing Photo Requirements”; Rules & Regulations Section 1.2

The main photo must be an original, unaltered photo. Any digitally altered photo, including virtual staging, must carry a watermark added with the Flexmls watermark feature and follow its unaltered original, and the public remarks must say photos are digitally altered.

Where to disclose

A watermark added with the Flexmls watermark feature, plus “Photos are Digitally Altered” in public remarks.

Required wording

Photos are Digitally Altered (public remarks)

Original photo

Required, immediately before the altered photo; the main photo must be unaltered

Penalty

$10 for a missing watermark; $10 a day for an altered main photo

Effective

Not stated

Last verified

October 22, 2026

“If an altered version of a photo is included, upload the original, unaltered photo immediately before the watermarked altered version. You must only use the Flexmls watermark feature to add a watermark”

Source: Metro MLS Procedures (final, August 5, 2026)

Only the Flexmls watermark may be used, so images must be uploaded without another label.

Minnesota and western Wisconsin · “Virtual Staging and AI-Enhanced Images” best-practice guidance, Sections 1.1–3.3

NorthstarMLS guidance says staged or AI-enhanced photos should be disclosed in the caption or filename shown in the listing viewer, or on the photo, with at least one unaltered “before” image per room. Staging may only add or remove personal property.

Where to disclose

Photo caption or filename visible in the listing viewer, or on the photo itself.

Original photo

Recommended: at least one unaltered “before” photo per staged room

Effective

Not stated

Last verified

October 22, 2026

“The disclosure must appear: Directly in the photo caption or filename visible in the listing viewer; OR On the altered photo.”

Source: Virtual Staging Best Practice (NorthstarMLS Resources)

Published as best-practice guidance (described as proposed in July 2026); the binding July 2026 rules have no staging section.

Northwestern Wisconsin (Eau Claire area) · Rules & Regulations Section 1.2(N)(4); Policies & Definitions, “Virtual Staging”

Virtual staging may only add or replace furnishings and may not alter fixtures, repair damage or change structure. Each staged photo must be next to an unstaged version, and a disclaimer must appear on the photo, in its description and in the public remarks.

Where to disclose

Disclaimer on the photo, in each staged photo’s description, and in public remarks.

Original photo

Required, immediately before or after the staged photo

Effective

April 2025

Last verified

October 22, 2026

“The public remarks, and description for each virtually staged photo, and the photo itself must include a disclaimer”

Source: NWWMLS Rules & Regulations and Policies & Definitions (April 2025 manual, archived copy)

Read from an archived copy; the live file was unavailable and may have been replaced.

Northeast Wisconsin (Green Bay, Fox Valley, Oshkosh, Wausau) · Rules & Regulations Section 4.12(3) “Required Photos”

If photos show virtually staged rooms, the public remarks must say so. Staged photos may only be additional photos, not the main photo, and each must be accompanied by a photo of the room as it actually appears.

Where to disclose

Notice in public remarks.

Original photo

Required: a photo of the room as it actually appears

Effective

October 6, 2026

Last verified

October 22, 2026

“a notice of this is to be included in public remarks in MLS. Virtually staged photos are approved for additional photo use only and must be accompanied by a photo of the room as it actually appears.”

Source: RANW MLS Rules and Regulations (October 2026)