# Wisconsin Agents: Act 69 Takes Effect January 1, 2027 — Start Preparing Now

Wisconsin 2025 Act 69 adds an advertising disclosure rule for technology- and AI-altered listing images, similar in purpose to California's AB 723. It takes effect January 1, 2027.

- State: Wisconsin (WI)
- Risk level: high
- Last verified: 2026-10-11
- Confidence tier: verified_public_rulebook — verified against the board or statute’s own public rulebook
- Canonical page: https://relto.app/mls-compliance/wisconsin

## Summary

Wisconsin 2025 Act 69 (2025 Assembly Bill 456, enacted December 9, 2025), codified at Wis. Stat. §452.136(1m), takes effect January 1, 2027 and requires a licensee to disclose in all advertising if the advertising has been altered or modified using technology — including AI — to add, remove, or change elements of the property that create a false or misleading impression. The statutory text does not prescribe a disclosure format or placement. Act 69 is mainly a brokerage-practice reform act; the advertising disclosure is one section of it.

## Virtual staging laws in Wisconsin

### Wisconsin 2025 Act 69 (2025 Assembly Bill 456) — Wis. Stat. §452.136(1m)

Requires a licensee to disclose in all advertising if the advertising has been altered or modified using technology, including artificial intelligence, to add, remove, or change elements of the property that create a false or misleading impression. The statutory text is broad and silent on disclosure format and placement; it likely reaches virtual staging as well as adjacent edits (sky replacement, grass enhancement, object removal) when they create a false or misleading impression.

Effective: January 1, 2027.

### Wisconsin Deceptive Trade Practices Act (Wis. Stat. § 100.18)

Broad consumer-protection statute prohibiting fraudulent representations in advertising. Under Wis. Stat. §100.18(11)(b)2, a private action allows recovery of pecuniary loss and costs, but attorney fees may not be recovered from a person licensed under chapter 452 while engaged in real estate practice.

## What Wisconsin MLS boards require for virtual staging

### Metro MLS (Greater Milwaukee)

- Disclosure rule: Metro MLS requires an original, unaltered main photo first, then each digitally altered photo (including virtual staging) placed immediately after its original and carrying the Flexmls watermark, with the phrase "Photos are Digitally Altered" in Public Remarks (Metro MLS, post dated April 21, 2026; sanctions apply from September 1, 2026). Separately, Metro MLS guidance dated February 10, 2026 says virtual staging must be clearly disclosed. This rests on Metro MLS blog posts, not its rulebook. Act 69 adds a statutory advertising disclosure rule starting January 1, 2027.
- Permitted: Virtual staging with furniture, décor, rugs, and artwork, with disclosure, per the Metro MLS article.
- Prohibited: Adding people or pets, lifestyle scenes, or signage, per the Metro MLS article.
- Penalty: Metro MLS states a $10 sanction for digitally altered photos lacking the required watermark and $10 per day for a digitally altered primary photo until replaced. Metro MLS's full rulebook schedule was not read. Act 69 adds no penalty of its own; see Penalties.

## What happens if you skip disclosure in Wisconsin

- Act 69 Enforcement (regulatory): Act 69 has no penalty clause of its own. A violation is a ground for Real Estate Examining Board discipline under Wis. Stat. §452.14(3)(L), and under §452.14(4m)(a), which is already in force, the board may assess a forfeiture of up to $5,000 per violation. The new disclosure duty itself, §452.136(1m), applies from January 1, 2027.
- License Discipline (regulatory): The Real Estate Examining Board (through DSPS) can discipline licenses for misrepresentation
- DTPA (civil): Wisconsin DTPA (Wis. Stat. §100.18) allows recovery of pecuniary loss and costs for fraudulent representations; attorney fees are not recoverable from a chapter 452 licensee engaged in real estate practice (§100.18(11)(b)2).

## What you need to know

- Wisconsin 2025 Act 69 (2025 Assembly Bill 456) adds an advertising disclosure rule for technology- and AI-altered listing images, similar in purpose to California AB 723
- Codified at Wis. Stat. §452.136(1m); effective January 1, 2027
- The text covers advertising altered to "add, remove, or change elements of the property" in a way that creates a false or misleading impression, so it likely reaches virtual staging and adjacent edits like sky replacement, grass enhancement, and object removal
- The statute does not prescribe a disclosure format or placement
- Wis. Stat. §452.136(1) already bars false, deceptive or misleading advertising today
- Act 69 has no penalty clause; discipline runs through Wis. Stat. §452.14, including forfeitures up to $5,000 per violation under §452.14(4m)(a), already in force

## How to disclose properly

- Disclosure of AI or technology tools used to modify property appearance in photos
- The statute's trigger is alteration that adds, removes or changes elements of the property and creates a false or misleading impression; whether a given edit (staging, sky replacement, grass enhancement, object removal) meets it is not settled by the statute text, so confirm with your brokerage or counsel
- NAR Articles 2 and 12 / SOP 12-10 compliance

## Broker warning

Act 69 takes effect January 1, 2027. Don't wait — start building disclosure into your workflow now. The statute is broadly worded and likely reaches more than furniture staging (for example sky replacement, grass enhancement, and object removal), but we found no board or WRA guidance interpreting it, so confirm with counsel.

## Questions Wisconsin agents ask about virtual staging

### What is Wisconsin AB 456 / 2025 Act 69?

Wisconsin 2025 Act 69, codified at Wis. Stat. §452.136(1m), is a state law, similar in purpose to California AB 723, requiring a licensee to disclose in all advertising if the advertising has been altered or modified using technology — including AI — to add, remove, or change elements of the property that create a false or misleading impression. It takes effect January 1, 2027. The statute is broad and format-agnostic; it does not prescribe how or where the disclosure must appear.

### How is Wisconsin 2025 Act 69 different from California AB 723?

Both laws require disclosure of digitally altered listing images. California AB 723 (effective Jan 1, 2026) makes willful violation a misdemeanor and also mandates a specific format — a reasonably conspicuous on-or-adjacent statement plus a link/URL/QR code to the unaltered original. Wisconsin Act 69 (effective Jan 1, 2027) has a broader "false or misleading impression" trigger but is silent on format and placement, leaving firms discretion in implementation.

### How does RELTO help Wisconsin agents prepare?

RELTO automatically applies disclosure language and pairs original images with staged versions, so workflows that already satisfy stricter frameworks (such as California AB 723) also meet the Wisconsin Act 69 disclosure trigger when it takes effect. Brokerages can start documenting compliant workflows now.

## Sources

- Primary source: https://docs.legis.wisconsin.gov/statutes/statutes/452/136
- Wisconsin 2025 Act 69 — Governor Evers press release: https://content.govdelivery.com/accounts/WIGOV/bulletins/3fedde4
- Wis. Stat. §452.136 — Wisconsin statutes: https://docs.legis.wisconsin.gov/statutes/statutes/452/136
- Wis. Stat. §452.14 — Discipline; forfeitures (Wisconsin statutes): https://docs.legis.wisconsin.gov/statutes/statutes/452/14
- Wis. Stat. §100.18 — Fraudulent representations (Wisconsin statutes): https://docs.legis.wisconsin.gov/statutes/statutes/100/18
- Metro MLS — New photo upload requirements in Flexmls (April 21, 2026): https://metromls.com/new-photo-upload-requirements-in-flexmls-original-altered-watermark/
- Metro MLS — Virtual staging best practices (February 10, 2026): https://metromls.com/virtual-staging-best-practices-whats-allowed-in-mls-listing-photos/

## Not legal advice

This page is for general information only and is not legal advice. RELTO is a virtual-staging technology provider, not a law firm. Statutes, MLS rules, and enforcement practices change.

This entry is verified against the board or statute’s own public rulebook. Before you act, confirm the current rule with the statute or MLS rulebook itself, your broker of record, and a licensed Wisconsin real-estate attorney.