California apartment owners must label every altered listing photo and show its original by Jan. 1. Gov. Gavin Newsom signed the law, AB 2025, on Sept. 276. That leaves owners 96 days from signature to enforcement.
Does that give an industry enough time? Apartment groups say the clock runs short. Consumer Reports says renters pay when a photo misleads.
What the Law Asks of Owners
Assemblymember Gail Pellerin wrote AB 20252. It covers rental ads with photos changed by editing software or generated by AI. Adding, removing or changing furniture, appliances, flooring, paint or landscaping triggers a label. The label must be reasonably conspicuous and sit on or next to the image.
Routine changes to lighting, color, cropping or exposure stay exempt when they leave the property looking the same2. A second duty follows an edit to a camera photo. The ad must carry the original, or a link, URL or QR code that leads to it.
One violation is a misdemeanor1. A licensed broker faces more, because a rental-ad violation also breaks the licensing law2.
California already polices sale listings. AB 723 took effect Jan. 1, 2026, and Wisconsin's Act 69 follows on Jan. 1, 20274. Bisnow adds a Washington, D.C. bill and proposals in New York and New Jersey1.
Why Owners Say the Clock Runs Short
Kevin Donnelly is executive director of the Real Estate Technology & Transformation Center. He backs labels and targets one clause. "What's really needed here is to make sure that we retain disclosure and false advertising protections, but also address the infeasible record production mandate that the law carries," Donnelly told Bisnow1.
The clause in question is the original-image rule. Donnelly estimates that "thousands" of California apartment communities need new photography. Estimates he has heard run as high as thousands of dollars per property.
A grace period or safe harbor after Jan. 1 is what he wants. As of Oct. 28, 65 of the 96 days remain.
"They need to make sure that they keep in mind that disclosure is certainly a laudable goal and something we can support," Donnelly said of the state's Department of Real Estate, "but the law doesn't make a historical image reappear." Owners and industry groups have asked the department for guidance on both California laws.
California Owners Get 96 Days, and 65 Remain on Oct. 28
Days between Gov. Newsom's Sept. 27, 2026 signature and AB 2025's Jan. 1, 2027 effective date
The first column is the full span from signing to enforcement; the second is the part still left on Oct. 28, 2026.
Sources: California Apartment Association [2]; Office of Gov. Gavin Newsom [6]. Chart by Ryan Elliott Dennis.
The numbers behind this chart
| Item | Value |
|---|---|
| Signing to Jan. 1 | 96 days |
| Left on Oct. 28 | 65 days |
Jonas Bordo, co-founder and CEO of the rental site Dwellsy, says owners rarely keep original photography1. Older buildings make the gap wider. Nearly half of California's apartment stock dates from before 1980, and roughly 20 percent from before 1960.
Jay Harris, a partner at the law firm Hudson Cook, advises apartment owners on compliance. He describes a typical owner. "The owner of a Class-B property, who has had the apartment for the last decade, didn't budget for a sudden reshoot in the next 60 days," Harris said.
Bordo has nicknamed the law the "Real Estate Photographer Full Employment Act." His verdict: "Fundamentally, this won't benefit anybody except the photographers." He expects lawsuits from plaintiffs who see an opportunity.
James Goody, managing partner at Oak 21 Real Estate, offers a cheaper path. Owners he works with outside California discussed asking AI to scan existing images and add a watermark that notes the alteration. Under AB 2025, a label alone covers only part of the duty, since the original must follow.
Why Consumer Reports Says Renters Need Both
Justin Brookman directs technology policy at Consumer Reports. He points to renters who move for a job and sign a lease from another city. About 8 percent of leasing still happens remotely, Bisnow reports1.
"They might sign a year-long lease, and they show up and they're on the hook for staying in a place that was not what they signed up for," Brookman told Fortune3. He also called a label the floor. "In the spirit of transparency, people should know what they're getting into," he said.
Consumer Reports backed AB 2025 in a letter that April. "AB 2025 would put in place basic guardrails to encourage the responsible use of AI tools while preventing their abuse to deceive consumers," the group wrote5.
How common are altered photos? A June study by the platform Coraly checked roughly 40,000 primary listing photos from Zillow, Redfin, Realtor.com and Homes.com. Nearly 11 percent showed signs of digital alteration4.
Coraly Finds Nearly 11 Percent of Listing Photos Show Alteration
Share of about 40,000 primary listing photos from four portals, January to March 2026
Coraly reports nearly 11 percent, so 11 rounds the figure up.
Source: Real Estate News [4]. Chart by Ryan Elliott Dennis.
The numbers behind this chart
| Item | Value |
|---|---|
| Photos with signs of alteration | 11% |
| Whole | 100% |
New York City's mayor wants a similar rule. Zohran Mamdani proposed on July 16 that landlords, brokers and listing platforms disclose AI-altered photos and videos3. "You shouldn't have to worry whether or not the apartment you're viewing online is real," Mamdani said at Manhattan's Tenement Museum.
Zillow told Fortune it supports disclosure and wants renters to see the original beside the edit. "We support clear disclosure when AI is used to materially alter a listing image, and believe consumers should be able to view the original content alongside the altered version wherever possible," a Zillow spokesperson said.
Assistant Commissioner Christina Jimenez of the Department of Real Estate gave Bisnow a general line: "DRE takes all violations seriously and remains committed to putting consumer protection first"1.
Bisnow practiced the label itself. Its story illustrations carry the credit "Bisnow/created with ChatGPT" on the page.
What the Two Sides Need
Brookman's case holds if renters see the label and the original before they sign a lease. Donnelly's case holds if the cost of reshoots outweighs what misled renters lose.
Both agree on the label. They split on the original image and on the date.
What to do
If you manage California apartments, ask your photographers and marketing vendors for original image files this week. Then check each listing against the AB 2025 list2. Edits to furniture, appliances, flooring, paint and landscaping all need a label and an original.
Pick one label wording and one QR or link format, and apply it across every listing before Jan. 1.
If you rent, ask the listing agent for the original image and compare it with the edit. Tour the unit in person when you can, since 8 percent of leases close remotely1.
By the numbers
- 96 days: the span between Newsom's Sept. 27 signature and the Jan. 1, 2027 effective date12.
- Nearly 11 percent: the share of roughly 40,000 listing photos that showed alteration in Coraly's study4.
- Leases that close remotely run about 8 percent, per Bisnow1.
- California apartment stock built before 1960 makes up roughly 20 percent1.
- Over 2,400 renters gave testimony behind New York City's 23 tenant initiatives3.
What to watch
Watch for guidance from California's Department of Real Estate, and for any grace period it grants after Jan. 1. The first lawsuits will show whether Bordo's forecast holds. Wisconsin's Act 69 takes effect the same day4. Bills in the District of Columbia, New Jersey and New York City could add the next rules13.
Sources
- Patrick Sisson, "The New Challenge For Apartment Managers: Proving Listing Photos Are Real," Bisnow, Oct. 27, 2026, https://www.bisnow.com/news/national/multifamily/the-new-challenge-for-apartment-managers-proving-listing-photos-are-real
- California Apartment Association, "New law will require disclosures for digitally altered rental ads," Sept. 29, 2026, https://caanet.org/new-law-will-require-disclosures-for-digitally-altered-rental-ads/
- Tatiana Sataua, "'Housefishing': NYC proposes AI disclosure rules for rental listing photos," Fortune, July 22, 2026, https://www.fortune.com/2026/07/22/mamdani-ai-altered-rental-listing-disclosures/
- Real Estate News, "AI-modified listing photos blur line between enhancement and deception," Sept. 8, 2026, https://realestatenews.com/2026/09/08/ai-modified-listing-photos-blur-line-between-enhancement-deception
- Consumer Reports Advocacy, "Consumer Reports supports California bill to combat deceptive AI in real estate listings," Apr. 10, 2026, https://advocacy.consumerreports.org/research/consumer-reports-supports-california-bill-to-combat-deceptive-ai-in-real-estate-listings/
- Office of Gov. Gavin Newsom, "Governor Newsom issues legislative update 9.27.2026," Sept. 27, 2026, https://www.gov.ca.gov/2026/09/27/governor-newsom-issues-legislative-update-9-27-2026/