Guide

How to Disclose Virtually Staged Photos in California (Step by Step)

A step-by-step guide to disclosing virtually staged listing photos under California §10140.8 — the manual method and the fast method. Informational, not legal advice.

Answer first

To disclose a virtually staged photo under California §10140.8, you need four things on the image itself: a "digitally altered" statement, a QR or link to the original, image-level placement, and language pointing viewers to the original. This guide walks through exactly how to do that for each listing — the manual way, and the fast way.

The buyer can tell, from the image, that it was altered.

A virtually staged photo is properly disclosed when a buyer looking at the listing can tell, from the image, that it was altered and can immediately reach the original. That’s the bar.

A caption in the listing remarks, or a disclosure in a transaction PDF, doesn’t clear it — the disclosure has to be on or adjacent to the image everywhere the listing appears, including the MLS and any site you control. For the legal background, see the complete AB 723 guide and the four §10140.8 requirements.

Six steps per altered image.

  1. Step 1Keep the original, unaltered photo. Before staging, save the original empty / un-retouched photo of each room. You will need to host it publicly later.
  2. Step 2Add the alteration statement to the staged image. Burn a visible label onto the staged photo: "Virtually staged and digitally altered." Make sure it is legible and will not be cropped by the MLS thumbnail.
  3. Step 3Host the original and create a link or QR. Upload the original somewhere publicly accessible and generate a stable URL (and ideally a QR code) that resolves directly to that original image — not your homepage or the listing.
  4. Step 4Put the link and access language on the image. Add the QR code or short URL to the staged image, with words that tell the viewer what it is for: "View the original, unaltered image at [URL] or scan the QR code."
  5. Step 5Place the disclosure on or adjacent to the image everywhere. Ensure the disclosed image (not a clean version) is what uploads to the MLS, your website, and any portal. If your MLS wants the original adjacent, place it immediately before or after the staged image.
  6. Step 6Repeat per photo, per listing, and keep records. Do this for every altered image, and keep the original and disclosed versions on file in case the disclosure is ever questioned.

The manual method works — but it’s per-photo work that’s easy to do inconsistently across a team, and Step 3 (hosting originals with stable URLs) is where most agents give up.

Certify the photo once.

A platform built for §10140.8 collapses all six steps into one: you upload the original, it stages the room and bakes the alteration statement, the QR-to-original, and the access language onto the delivered image automatically. You download an MLS-ready, already-disclosed photo.

That’s what SEAREI does — every certified image ships with all four requirements rendered on it, and the QR resolves to the original you uploaded. No separate hosting step, no per-photo checklist, no “did everyone remember the disclosure” risk across a brokerage.

Where compliant-looking workflows break.

  • Label only. “Virtually Staged” with no link to the original fails three of four requirements.
  • Link to the wrong place. A QR that opens the listing or brokerage site instead of the specific original image.
  • Disclosure off the image. Putting it in a PDF, the remarks field, or a separate verify page instead of on / adjacent to the image.
  • Clean version uploaded by mistake. Staging the photo correctly but uploading the un-disclosed copy to the MLS.
  • Inconsistent across the team. One agent discloses correctly, another doesn’t — the brokerage’s exposure is the weakest listing.

Related questions about disclosing virtual staging.

Can I just write "virtually staged" in the listing description?

No. The disclosure has to be on or adjacent to the image, and it needs the link to the original plus access language — not just a remark in the description field.

Where do I host the original photo?

Anywhere publicly accessible with a stable URL that points directly to that image. A platform like SEAREI hosts it for you and wires the QR automatically.

Do I need a QR code, or is a URL enough?

§10140.8 accepts a publicly accessible URL or a QR code. A QR is the most practical for an on-image disclosure since buyers can scan it from a printed flyer or screen.

How fast can a photo be made compliant?

Manually, it is several steps per image. With an automated platform it is effectively instant at staging time — you download the already-disclosed photo.

Where these requirements come from.

For the full legal background, start with the complete AB 723 virtual staging guide.

By Sam Vardani, Co-founder, SEAREI · Last updated: June 5, 2026 · SEATECHONE LLC

SEAREI is built around the requirements of California Business & Professions Code §10140.8. It is not affiliated with, endorsed by, or certified by the California Department of Real Estate or any MLS. This guide is compliance guidance, not legal advice; for your specific situation, consult your brokerage counsel or designated officer.