Synthetic media disclosure is the practice of labelling an AI-generated or AI-altered image, video or voice used in marketing — in Canada this is prudent professional practice, not a codified national requirement.
CREA's own AI guidance sets a transparency principle without prescribing a labelling mechanic — it says “consumers and REALTORS® should clearly understand when AI is materially influencing information, communications, or representations,” but does not mandate a specific label, watermark or caption format at the national level. What CREA is explicit about is accountability: REALTOR® Code Articles 13 and 15, governing advertising content, accuracy and claims, apply in full to AI-generated material regardless of whether a label is attached, because “the adoption of AI does not alleviate the professional responsibilities of REALTORS®.”
The Competition Act adds a separate, harder edge. Competition Act s.74.01(1)(a) makes a representation to the public that is “false or misleading in a material respect” reviewable “by any means whatever” — an unlabelled AI-staged photo presented as an unedited image of the property's current condition can create exactly that false impression, entirely apart from any CREA labelling policy. The Competition Bureau's own Artificial intelligence and competition discussion paper (a discussion paper; its public consultation ran to July 2024 and is now closed, so treat it as background, not enforcement guidance) names “‘deepfake’ (digitally altered) voices, images, or videos” as one way AI can make deceptive marketing “more convincing” — the Bureau's concern is the false impression created, not the technology used to create it.
An agent runs an interior photo through an AI “declutter and virtually stage” tool before listing. CREA does not require a national label for that image, but Article 13's accuracy standard and s.74.01(1)(a)'s false-impression test both still apply — captioning the photo “virtually staged” keeps it from being read as a photograph of the room's actual current condition, which is the real exposure a missing label creates, regardless of what any regulator has or hasn't formally mandated.
See also: Hallucination in an AI draft · Training data and what you feed a model.
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