A developer hands your agency twelve apartments in a building that is still a hole in the ground. The brochure has one exterior render and a set of floor plans. The first viewing request arrives on Monday, and there is nothing to view.
Selling off-plan means asking a buyer to commit to a home they can only imagine, and most people are poor at imagining a home from a floor plan. The agency closes that gap with pictures. The risk sits in the same place: every image of a home that does not exist yet is a description of what will be delivered.
Before you start
This article is practical guidance, not legal advice, written by a Belgian B2B software company rather than a law firm. The disclosure rules for AI images are covered in our articles on Article 50 of the EU AI Act and on virtual staging.
Why off-plan is a picture problem
A resale listing starts from a real room. Even an empty, badly lit flat gives the buyer walls, windows, a view and a sense of scale. An off-plan listing starts from a drawing, and a drawing answers other questions: it gives surfaces and room names, not light, volume or the feeling of standing in the living room.
Buyers fill that gap themselves. They borrow from their current home, from a show flat they visited elsewhere, or from the most flattering image on the developer’s website. Whatever the listing does not show, they invent. Good off-plan marketing replaces those guesses with images that are convincing and can be checked against the plans.
Site photos rarely help before the shell is closed. Bare concrete, scaffolding and a crane prove that the project is real, which builds trust, but they do not help anyone picture breakfast in the kitchen.
Four visuals, four jobs
Most off-plan campaigns combine the following. They do different jobs, and they carry different risks:
- The floor plan. The reference document: the most accurate thing you publish, and the least read. A clean version with dimensions, orientation and room names is worth more than a beautiful one.
- The cutaway, or dollhouse view. The same floor seen from above at an angle, walls cut at mid-height, furnished. It turns surfaces into rooms that buyers read at a glance: where the kitchen meets the living area, how far the bedrooms are from the front door.
- Interior renders. Eye-level views of one room from a defined position. They sell the feeling of the space, and they are the images buyers remember, quote at handover and compare with what they receive.
- Exterior and site images. The façade, the street, construction progress. They anchor the project in a real place and a real timeline.
The cutaway and the interior renders do the persuading. They are also where most disputes start, because they show detail that the plans do not.
A render is a promise
One rule covers nearly every case. Everything visible in an off-plan image should be something the buyer can find in the plans or the specifications. If the render shows oak parquet and the specification says laminate, the buyer will hold up the brochure at handover, and a footnote saying “non-contractual image” will not end that conversation.
These are the drifts we look for in every off-plan visual:
- Rooms that grow. A living room that looks five metres wide on a plan that says 4.2. Wide framing and generous furniture spacing make every room bigger than drawn.
- Finishes above specification. Stone worktops, full-height tiling, designer lighting, built-in wardrobes: attractive, and often options or not included at all.
- Windows and light that are not on the plan. A wider glazed opening, an extra window, sunshine pouring through a north-facing façade.
- An invented view. A park, a skyline or open fields where the site has a neighbouring building. The view is part of what is being bought.
- Furniture at the wrong scale. A double bed that only fits because it is drawn twenty centimetres short. The room will feel smaller at handover than in the brochure.
- Outdated images. The plans changed after the permit; the renders did not. The brochure now describes a flat that will never be built.
None of this is fixed by a disclaimer. It is fixed by checking every image against the plan before publication, and by saying clearly what is standard, what is an option and what is only atmosphere.
The test that matters
Picture the buyer at handover, holding your listing next to the finished room. “Same layout, with my furniture instead of yours” is the answer you want. “That window was never on the plan” is the start of a claim.
The rules in Belgium and France
Off-plan sales are among the most regulated transactions an agency handles, and the marketing has to agree with the contract that follows.
In Belgium, the Breyne Law of 9 July 1971 protects buyers of homes to be built or under construction, and its rules are mandatory. The deposit before signing cannot exceed 5% of the total price, the rest is paid as the works progress, and the contractor must provide a guarantee. The contract describes the home through its plans and specifications, which is exactly what your visuals will be compared with.
In France, the equivalent is the VEFA, the sale of a property to be completed. The reservation deposit is capped at 5% of the expected price if the sale is signed within a year, and 2% within two years. Payments then follow construction: at most 35% at foundations, 70% once the building is weathertight and 95% at completion, where an external completion guarantee is in place. The contract includes a technical description, the notice descriptive, which again defines what the buyer is entitled to.
Consumer law sits above both. The Unfair Commercial Practices Directive, transposed in Belgium in Book VI of the Code of Economic Law, prohibits misleading actions and misleading omissions. A render that shows more than the contract delivers can be either. Belgian agents also work under the IPI/BIV code of conduct, which requires a faithful presentation of the property and, since July 2026, addresses AI-edited images.
AI visuals from a floor plan
Until recently, off-plan visuals meant briefing a 3D studio, waiting a week or two and paying per image. That remains the right choice for a flagship development. For eight apartments, a terrace of houses or a single home sold off-plan, it is often too slow and too costly, so the listing goes out with plans alone.
Image models can now produce a furnished cutaway and room views from a floor plan in minutes. That changes who can afford off-plan visuals. It does not change the rules above, and two habits become essential:
- Disclose it. Since 2 August 2026, Article 50 of the EU AI Act requires artificially generated images shown to the public to be labelled clearly and visibly. “AI visualisation based on the plans, not the finished home” is clearer than any icon.
- Check it against the plan, every time. A model fills gaps with plausible detail, and plausible is exactly the problem: it adds a window that looks right, widens a room that looks cramped, upgrades a kitchen that looks plain. Approval is not optional.
The workflow that holds up is simple. Generate the cutaway from the plan, compare it with the plan and approve it. Only then generate room views from that approved reference, so every interior agrees with the same layout and the same finishes.
Six checks before you publish an off-plan visual
- Open the plan next to the image and match every wall, door and window.
- Compare room proportions with the dimensions on the plan, not with your impression.
- Check every visible finish against the specifications, and label options as options.
- Remove any view, garden or terrace that the plan and the site do not support.
- Put the label on the image itself, in the language of the listing.
- Record which plan version each image is based on, and replace it when the plans change.
Off-plan buyers commit on the strength of what you show them. The visuals that sell are the ones that still look true on the day the keys are handed over.
Off-plan visuals that stay faithful to the plans
Renovae’s new-build module, coming soon, follows the workflow above:
- It starts from your floor plan, uploaded or reused from a property already in your workspace.
- The cutaway comes first, and you approve it before any room view is generated.
- Room views come from the approved reference, from the position and direction you choose, so every image shares one layout.
- The AI label is applied to downloaded visuals, as on every Renovae image.
The self-service trial lasts 14 days and includes 20 credits, up to 20 uploaded images and three users. No payment card is needed. Trial exports carry a Renovae watermark, and nothing is charged automatically when the trial ends.
Frequently asked questions
Are the renders in an off-plan brochure contractual?
Not automatically, and a “non-contractual image” notice is common. The notice does not make a misleading image acceptable, though: consumer law looks at the overall impression of the advertisement, and buyers compare renders with what they receive. The safe practice is to show only what the plans and specifications support, and to label options and atmosphere as such.
Do AI-generated off-plan visuals need a label?
Yes. Since 2 August 2026, Article 50 of the EU AI Act requires a clear and visible disclosure on artificially generated or manipulated images shown to the public. An image of a home that does not exist yet is generated by definition, so the label belongs on the image.
Does the Breyne Law apply to every new build sold in Belgium?
It applies to the sale of a house or apartment to be built or under construction when the buyer pays before completion, and its rules are mandatory. The notary checks the contract, but the agency’s marketing should already agree with the plans and specifications that contract will contain.
When should off-plan visuals be updated?
Whenever the plans or specifications change: after the building permit, after a revision, or when an option becomes standard or is withdrawn. Keep the plan version with each image so you can see at a glance which ones are out of date.
Can I show furniture the buyer will not receive?
Yes, as long as it is clearly furniture and the image is labelled. Furniture gives scale and helps buyers picture the rooms. Fitted elements are different: kitchen units, built-in wardrobes, sanitary fittings and floor finishes are part of what is delivered, so they must match the specifications.
Sources
- Law of 9 July 1971 regulating the construction of homes and the sale of homes to be built or under construction (Breyne Law). Overview by the Belgian notaries: notaire.be
- French Construction and Housing Code, articles R261-14 (staged payments) and R261-28 to R261-31 (reservation deposit) for the VEFA. legifrance.gouv.fr
- Regulation (EU) 2024/1689 (AI Act), Article 50: transparency obligations for providers and deployers. artificialintelligenceact.eu/article/50
- Directive 2005/29/EC on unfair commercial practices: misleading actions and omissions, transposed in Belgium in Book VI of the Code of Economic Law.
- IPI/BIV: code of conduct for real-estate agents, including the 2026 provisions on AI-edited images. ipi.be