CGI in property adverts: UK rules from the CAP Code and ASA, and how they apply to AI video
CGI in property adverts in the UK: what the CAP Code and ASA guidance say about computer-generated images, "CGI for illustration" labels and AI video.
In this article
A UK developer wants to launch an off-plan scheme with a vertical film made from the architect's CGIs: sunlit balconies, a finished courtyard, a kitchen with the upgraded worktops. Nothing in UK advertising rules bans CGI, but every frame is a claim about what a buyer will get, and the Advertising Standards Authority judges the overall impression, not the small print. This guide covers the CAP Code rules that apply, what the ASA's guidance says about images and qualifying text, where property CGIs most often mislead, how to label them, and how the same rules apply when an AI video tool animates the renderings.
Key takeaways
- The CAP Code has no rule banning CGI; rule 3.1 says marketing "must not materially mislead or be likely to do so," and that is the test every CGI and every AI-generated scene has to pass.
- A "CGI for illustration purposes only" line tells viewers the image isn't a photograph, but under rules 3.9 and 3.10 a qualification may clarify, never contradict, and the ASA says small print is "generally unlikely to prevent an ad from misleading."
- The ASA's new-build guidance requires "image includes optional upgrades at additional cost" next to any image showing upgrades, "equally prominent to the price claim," with the price prefixed "from."
- The riskiest details in property CGIs are the ones a buyer can't check yet: views, neighboring buildings, sunlight, mature planting, finishes and room size.
- AI motion adds a new layer of invention, since a video model extends the image past its edges, so review each scene against the approved CGI before the film runs as an ad.
Are CGIs allowed in UK property adverts?
Yes. UK property adverts can use CGIs, artist's impressions and AI-generated video, provided the overall impression doesn't materially mislead consumers about the property they would actually buy, under rule 3.1 of the CAP Code. A label such as "CGI for illustration purposes only" should be clear and placed where viewers see it, but it can't rescue an image that misrepresents the specification, views or surroundings. If the CGI shows optional upgrades, the ASA expects "image includes optional upgrades at additional cost" next to the image, as prominent as the price.
The rest of this guide is the detail behind that answer. It is general information, not legal advice; a developer running a national campaign should also take advice on consumer law, which sits behind the Code.
The CAP Code rules that apply
The UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (the CAP Code) covers non-broadcast ads, online ones included. Section 3, on misleading advertising, does most of the work for property imagery. The wording below is from the CAP Code section 3, as of October 2026.
| Rule | What it says | What it means for a CGI or AI film |
|---|---|---|
| 3.1 | "Marketing communications must not materially mislead or be likely to do so." | The overall picture of the home, building and setting has to be fair |
| 3.3 | Must not omit material information, including by presenting it "in a way that is unclear or untimely, or in a way that the consumer is unlikely to see or hear it" | A label shown for one second at the end of a Reel may not count |
| 3.7 | Marketers "must hold documentary evidence" for objective claims | Keep the plans, specification and approved CGI set that each scene relies on |
| 3.9 | Qualifications "may clarify but must not mislead by contradicting the claims that they qualify" | "For illustration only" can't undo a view the flat won't have |
| 3.10 | "Qualifications must not mislead by not being presented clearly." | Legible on a phone, on screen long enough to read |
| 3.11 | Must not mislead "by exaggerating the capability or performance of a product" | Stretched rooms, impossible light or invented amenities |
| 3.17 | Price statements "must relate to the product featured" | A "from" price over an upgraded penthouse CGI needs qualifying text |
Rule 3.2 allows "obvious exaggerations ('puffery')" that consumers are unlikely to take literally, which covers a moody sky or a stylized golden hour. It doesn't cover a balcony, a park or a station that a buyer would take at face value.
What the ASA says about images and qualifying text
The ASA's most specific property guidance is its advice page on new build and off plan homes, as of October 2026. It notes that "developers often use photographs of show homes finished to a high specification," and says an upgraded image is acceptable for off-plan property if "the price is clearly prefixed with 'from' and qualifying text is placed next to the image," giving the example "from £90,000, home shown £95,000." The qualifying text "must be equally prominent to the price claim and positioned adjacent to the image," and the wording it gives is "image includes optional upgrades at additional cost."
The ASA's September 11, 2025 article on avoiding misleading imagery in ads sets out the general principle that "images of products must not mislead about the product(s) that customers will actually receive," and that pre- or post-production techniques should not alter images "in a way which exaggerates what the product can do." Its warning about disclaimers comes from video game ads but transfers directly: "a qualification or small print such as 'Not representative of actual gameplay' is generally unlikely to prevent an ad from misleading consumers." Read "CGI for illustration purposes only" in the same light.
The ASA used to publish an advice page on property descriptions and CGIs, but it could not be fetched as of October 2026, and no ASA ruling specifically about property CGIs was located for this article. The principles above are the ones the ASA states in its current pages.
Where property CGIs most often mislead
Most CGIs are fair; trouble starts with the details a buyer can't verify until completion. A practical review list:
| Risk | Typical example | Fix |
|---|---|---|
| Views | Unobstructed river view from a unit that will face the next block | Render views per unit type, or show the view only on units that have it |
| Surroundings | Neighboring buildings, roads or a railway removed from the context | Keep the real context in the model; crop rather than erase |
| Light | Every room in afternoon sun regardless of orientation | Use plausible light for the actual orientation |
| Planting | Mature trees on day one where the plan shows saplings | Show planting at a stated age, or say "landscaping shown at maturity" |
| Specification | Upgraded kitchen with the standard price | "Image includes optional upgrades at additional cost," adjacent and equally prominent |
| Scale | Wide lens making a 3 m room read as 5 m | Keep camera focal length close to human view; give room dimensions elsewhere |
| Amenities | A gym, pool or concierge desk that isn't in the scheme | Show only what is consented and committed |
The same test applies to finished buildings: a photograph retouched to remove a substation or brighten a north-facing flat raises the same rule 3.1 question as a CGI.
How to label CGIs in an advert and a video
A label does two jobs: it tells people the image is not a photograph, and it carries any material qualification. Plain, specific wording beats a generic disclaimer.
- For a CGI of an unbuilt scheme: "Computer-generated image of the proposed development. Final appearance may vary."
- For a CGI showing upgrades: "Image includes optional upgrades at additional cost," next to the image and as prominent as the price.
- For landscaping or context shown in a future state: "Landscaping shown at maturity" or "Surrounding development shown as approved."
- For an AI-generated film: "AI-generated visualization of the proposed development from computer-generated images."
In a 30-second vertical film, rule 3.3's "unclear or untimely" wording matters. Put the CGI or AI line on screen from the first scene, not only at the end, in a corner the app's caption and buttons don't cover (Instagram Reels specs shows the safe area), and repeat it in the caption. If a specific scene shows upgrades, put the upgrades line on that scene. Wording for built-versus-concept captions in general is in AI rendering disclosure for architects.
Applying the rules to AI video made from CGIs
An image-to-video model has no plans behind the picture. It infers depth and extends what it sees, so a slow pan can reveal a side elevation nobody designed, a pull-back can add a street, and lighting can shift between scenes. For CAP Code purposes, each of those inventions is part of the ad, so the review that applies to a CGI applies to every second of the film.
- Start from the approved CGI set. Use the images the developer has signed off for marketing, not design-stage options.
- Check each scene against its source image: window count, balcony lines, materials, planting, the neighbors. The AI video quality checklist has the full list.
- Treat people as illustrative. AI tools often add figures; they shouldn't imply amenities, services or a resident profile the scheme doesn't offer.
- Keep the evidence. Rule 3.7 asks for documentary evidence, so archive the plans, specification, CGIs and final film together.
Arch2Video works this way: you upload exactly six images from one project (CGIs, drawings or photos), its AI director plans six connected five-second scenes, and you get a 1080 × 1920 MP4 of about 30 seconds. Every film includes a small cast of original, fictional adults in at least one scene, and AI motion is an interpretation of the images, so review the film before it runs and present unbuilt schemes as concept work. There is no text-overlay step, so add the CGI and upgrades lines in an editor before publishing.
If the same film will run in other markets, other rules stack on top: Dubai's Trakheesi permit for videos and India's RERA advertisement rules both require registration details on the frame, and the EU adds its own AI labeling duty, covered in EU AI Act Article 50 for design studios.
Who is responsible, and what a complaint leads to
The advertiser, normally the developer or the agent placing the ad, is the one the ASA holds to account. A visualization or architecture studio that only supplies CGIs is rarely the advertiser, but a studio posting the developer's sales film from its own account is publishing an ad.
When the ASA upholds a complaint, it publishes the ruling and the ad can't run again in its original form. A June 10, 2026 ruling against an estate agency's leaflet and Facebook comparison ads is a recent property-sector example: the ASA found breaches of rules 3.1 and 3.7, among others, and told the agency to make future comparisons verifiable (ASA ruling on RE/MAX Property Specialists, as of October 2026). It concerned claims, not images, but shows how quickly a Facebook post becomes a published ruling. Behind the Code sits consumer law: the Competition and Markets Authority published its guidance on unfair commercial practices under the Digital Markets, Competition and Consumers Act 2024 on April 4, 2025.
Frequently asked questions
Is "CGI for illustration purposes only" enough to make a property advert compliant?
No. It tells viewers the image isn't a photograph, which helps, but CAP Code rule 3.9 says qualifications "must not mislead by contradicting the claims that they qualify," and the ASA says small print is "generally unlikely to prevent an ad from misleading consumers." If the CGI shows a view, finish or amenity the buyer won't get, fix the image. Use the label alongside an accurate CGI, not instead of one.
Do I have to say a property video was made with AI in the UK?
The CAP Code has no AI-specific labeling rule; the test is still whether the ad materially misleads. An AI film of an unbuilt scheme can mislead if viewers take it for footage of a finished building, so a short "AI-generated visualization" line is a sensible way to avoid that. Platform rules may require a disclosure anyway, and if the film reaches EU audiences, the EU AI Act's own transparency rules can apply.
Can I show upgraded finishes in a CGI with a "from" price?
Yes, if you qualify it. The ASA's new-build guidance allows an upgraded image when the price is prefixed "from" and qualifying text such as "image includes optional upgrades at additional cost" sits next to the image, "equally prominent to the price claim." In a video, put that line on the scene that shows the upgrades, not only in the caption.
Who gets in trouble if the CGIs in an ad are misleading, the developer or the architect?
Usually the advertiser, meaning the developer or agent who placed the ad. A studio that only supplied CGIs is rarely the advertiser, but keep the approved image set and any instructions you were given, and don't post sales ads from your own account. Portfolio posts are safer with an accurate "computer-generated image" label and no prices.