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AB 2025 and AI Rental Photos: What Bay Area Property Owners Should Know

AB 2025 and AI Rental Photos: What Bay Area Property Owners Should Know

AB 2025 and AI Rental Photos: What Bay Area Property Owners Should Know

An empty bedroom can be furnished digitally. A kitchen can be shown with different appliances. Landscaping, wall colors, and even the view through a window can be changed without anything at the property changing.

These tools create possibilities for rental marketing. They also raise an important question for owners: can prospective tenants tell which parts of the image reflect the actual rental?

California’s AB 2025 would establish disclosure requirements for digitally altered images used to advertise rental properties.

As of September 23, 2026, the Legislature has passed AB 2025, and the bill is with the Governor. It has not yet become law. Follow the official bill status here.

For owners in Fairfield and across the Bay Area, here is what the enrolled proposal would mean.

What would AB 2025 require?

The proposal has two central requirements.

First, a rental advertisement using a covered digitally altered image would need to disclose that the image has been altered. That disclosure would need to be reasonably conspicuous and appear on or adjacent to the image.

Second, the advertisement would generally need to include the original, unaltered photograph or provide access through a link, URL, or QR code to a publicly accessible website that clearly identifies it.

If the original is accessed through one of those methods, the disclosure would also need to tell viewers that the original is available there.

These requirements would apply statewide. They would not create separate rules for Fairfield, Sacramento, or other California rental markets.

Which images would be covered?

The enrolled bill includes images fully generated through artificial intelligence, as well as existing images edited to add, remove, or change elements.

The listed elements include:

  • Furniture, appliances, and fixtures.

  • Flooring, walls, and paint colors.

  • Landscaping, hardscape, and building facades.

  • Floor plans.

  • Views, neighboring properties, utility poles, and other exterior elements.

Virtual staging falls within the proposal’s scope because furniture is expressly included.

Consider an empty Fairfield rental bedroom. Adding a digital bed and desk could help someone picture a possible layout. Under the proposed requirements, that altered image would need a disclosure and access to the original photograph.

Digitally replacing worn flooring or removing a neighboring structure from view would also involve changes specifically contemplated by the bill.

Would ordinary photo editing require a disclosure?

Not every adjustment would qualify.

The bill excludes routine edits such as lighting adjustments, sharpening, white balance, color correction, straightening, cropping, and exposure changes when they do not change the representation of the property.

That condition matters. An adjustment described as “color correction” should not be assumed exempt if it changes how the property itself is represented.

A useful review question is: does the edit make the photograph clearer, or does it make the rental look different from what is actually there?

What if there is no original photograph?

The bill includes an exception to the original-image requirement for an image, architectural rendering, or artistic rendering that was not originally created using a capture device.

That exception addresses the requirement to provide an original image. It does not eliminate the disclosure requirement for a covered AI-generated image.

Owners should distinguish between a photograph that has been edited and an image created without an underlying photograph.

Would AB 2025 ban virtual staging?

The proposal would not prohibit virtual staging. It would require transparency about covered images.

However, labeling an image would not make every use appropriate. The bill expressly states that it does not alter or limit laws concerning false or misleading advertising.

A virtually furnished living room can illustrate a possible use of space. A photograph showing appliances that are not included can create a different—and potentially misleading—expectation.

The full enrolled bill is available from the California Legislature.

What should rental owners do now?

While the proposal awaits action, review how your listing photographs are produced:

  • Find out whether your vendors use virtual staging or AI editing.

  • Preserve original photographs alongside edited versions.

  • Ask what was added, removed, or changed.

  • Establish who approves images and disclosures before publication.

  • Check the bill’s status before updating your compliance procedures.

Owners with properties in multiple markets can use a consistent review process across their portfolio.

Photography also works alongside pricing, advertising, and showing coordination. Learn more about how Legacy approaches these responsibilities through our rental property marketing services.

A clear listing starts a better leasing conversation

Rental photographs help applicants decide whether a home fits their needs. Accurate presentation gives them better information before they invest time in an inquiry or showing.

For Fairfield and Bay Area owners, the opportunity is to use technology thoughtfully while keeping the actual property at the center of the advertisement.

Legacy’s Bay Area property management services support owners with marketing, tenant placement, maintenance, and ongoing rental operations.

Looking for help with your rental property? Contact our Bay Area team to discuss your property and management goals.

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