When does Wisconsin's altered-photo disclosure law take effect?
January 1, 2027. Section 9 of 2025 Wisconsin Act 69 sets the effective date. The act was enacted December 9, 2025.
Wisconsin
Wisconsin — 2025 Act 69 (Wis. Stat. § 452.136(1m))
Wisconsin's 2025 Act 69 (§452.136(1m)), effective Jan 1 2027: disclose in ALL advertising when tech or AI alters a property in a misleading way. No wording is prescribed.
Answer first
Starting January 1, 2027, Wisconsin licensees must disclose — in ALL advertising, not just the MLS — when a listing ad has been altered using technology, including AI, to add, remove, or change elements of the property in a way that creates a false or misleading impression. That's the whole statutory duty: Wisconsin's 2025 Act 69 prescribes no watermark wording, no placement, no listing-description sentence, and no original-photo access requirement. The disclosure format is currently left to the licensee.
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Wisconsin
What Wisconsin — 2025 Act 69 (Wis. Stat. § 452.136(1m)) requires
| Disclosure required | Yes |
|---|---|
| Required label wording | NONE mandated. § 452.136(1m) requires the licensee to "disclose" in all advertising but prescribes NO specific wording, watermark, label format, or placement. Exact verbatim duty: "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." Format is left to the licensee pending any DSPS/REB guidance. |
| Label placement | Not specified. The duty attaches to "all advertising" — broader than MLS. No on-photo vs. description placement is prescribed. |
| Listing description must disclose | No |
| Original photo required | No |
Alterations this rule covers:
- any advertising altered or modified using technology, including artificial intelligence, to ADD, REMOVE, or CHANGE elements of the property — WHEN it creates a false or misleading impression of the property (the duty is conditioned on the false/misleading impression, unlike CA AB 723's broader trigger)
- applies to ALL advertising by a licensee — not only MLS listings (social media, flyers, portals included)
- NOT addressed by the statute: watermark wording, placement, listing-description text, or original-photo access
Rules documented
That’s the Wisconsin — 2025 Act 69 (Wis. Stat. § 452.136(1m)) rule. We’ve researched and cite this board’s rule, but we don’t yet claim our delivery meets it — ask us for a board check first.
What we can always do for any board: host your original, unaltered photo at a public URL and issue a timestamped verification record. What we don’t claim here is a board-compliant on-image delivery.
What this does — and what you still do
- SEAREI produces the disclosure artifacts: a disclosure-labeled export, your unaltered original hosted at a public URL, a public verification page, and a certificate with integrity hashes.
- SEAREI does not guarantee that any MLS, board, or regulator will accept your listing, and is not affiliated with or endorsed by any of them. Board rules change — each board page shows the date we last verified it.
- You complete the MLS-side steps your board requires (field or public-remarks entry, uploading the original, image ordering) and confirm the current rule with your MLS or broker before publishing.
- Nothing here is legal advice.
See the full Terms of Service.
What the agent must do
To meet the Wisconsin — 2025 Act 69 (Wis. Stat. § 452.136(1m)) rule, an agent completes these MLS-side steps (from the cited source):
- In all advertising, disclose when technology/AI has added, removed, or changed property elements in a way creating a false or misleading impression (effective Jan 1, 2027).
- No specific wording, placement, watermark, or original-photo format is prescribed by the statute.
The rule
2025 Wisconsin Act 69, Section 4, creating Wis. Stat. § 452.136(1m) — "Advertising enhanced by technology" (enacted December 9, 2025; published December 10, 2025)
Effective 2027-01-01.
Published by Wisconsin Legislature, State of Wisconsin — serving Wisconsin (statewide).
Penalty
Not specified in § 452.136(1m). Violations fall under general Wisconsin real-estate licensee discipline (Wis. Stat. ch. 452, DSPS Real Estate Examining Board). Do NOT publish a dollar figure — none exists in the statute.
FAQ
Does Wisconsin require a watermark on virtually staged photos?
No. Wis. Stat. § 452.136(1m) requires disclosure "in all advertising" but prescribes no watermark, wording, or placement. The trigger is technology-altered advertising that creates a false or misleading impression of the property.
Is Wisconsin's rule the same as California's AB 723?
No. California requires a disclosure plus access to the original unaltered photo, with enumerated alteration categories. Wisconsin's duty is narrower in trigger (alterations creating a false or misleading impression) but broader in reach — it covers ALL advertising by a licensee, not only MLS listings, and requires no original-photo access.
Sources
- 2025 Wisconsin Act 69 — full act text (official Wisconsin Legislature site; read in full)
- Wisconsin DSPS Real Estate Examining Board — January 2026 WRA memo & materials (PDF; secondary, not yet read in full)
- HousingWire — 'Could Wisconsin's new law set a national standard for real estate transparency?' (context/press)
Last verified 2026-08-17.
Related markets
The rule differs board by board. A few related markets to compare — the full list is on the compliance overview:
This page summarizes publicly available rules for general information and is not legal advice. Confirm current requirements with the cited source or your broker or legal counsel before relying on it.