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A Belgian royal decree gives binding force from 1 October 2026 to a new IPI code of ethics that bars real-estate agents from putting personal data into open AI systems or using AI to deceive
From 1 October 2026, when the code takes effect, the ban on entering personal data into an open AI system would carry no qualifier, and the deception rule would turn on purpose. The disclosure rule would apply only to the extent existing law already requires disclosure.
Bottom line: Signed 20 July 2026, published in the Moniteur belge on 21 September 2026, and in force from 1 October 2026 according to the official JUSTEL record. Until then the AI chapter is not yet binding.
Who this affects: Belgian real-estate agents registered with the IPI, including brokers, syndics and property managers and trainees on the list of stagiaires, the staff they answer for, and the compliance advisers and proptech vendors who serve them.
Issue date: Royal decree dated 20 July 2026. Published 21 September 2026, page 50952. Entry into force 1 October 2026, the same date Article 2 repeals the 2018 approving decree.
What changed: The new code, published but not in force until 1 October 2026, adds a Sub-title V on the real-estate agent and artificial intelligence, with a definition of an AI system and three articles on critical review, disclosure, competence, personal data and deception.
Analysis: Once the code takes effect on 1 October 2026, the ban on putting personal data into an open AI system would be unqualified, but the code does not define open. The disclosure duty would apply only to the extent it follows from legal obligations already in force.
Primary sources: Moniteur belge text, numac 2026006656 (French) · JUSTEL record with entry into force date
- Instrument (EN)
- Royal Decree of 20 July 2026 approving the code of ethics of the Professional Institute of Real-Estate Agents (IPI)
- Authority
- King of the Belgians, on the proposal of the Minister for the Middle Classes, Self-Employed and SMEs; code established by the IPI National Council on 24 June 2026
- Jurisdiction
- Belgium, federal
- Status
- Published in the Moniteur belge on 21 September 2026. Not yet in force
- Bindingness
- Article 1 gives the annexed code binding force; JUSTEL gives its entry into force as 1 October 2026. From then, it applies to persons registered with the IPI as trainees or full members
- Issue date / next deadline
- Signed 20 July 2026; published 21 September 2026; in force 1 October 2026
- Legal basis
- Framework law of 3 August 2007 on intellectual service professions, Article 8, paragraph 1; law of 11 February 2013 organising the profession of real-estate agent, Article 13
- Document
- numac 2026006656, Moniteur belge page 50952, JUSTEL dossier 2026-07-20/15
- Primary source
- https://www.ejustice.just.fgov.be/cgi/article.pl?language=fr&sum_date=2026-09-21&lg_txt=f&numac_search=2026006656
Signature, publication and entry into force
The royal decree was signed in Brussels on 20 July 2026 by King Philippe and countersigned by the minister E. Simonet. It was published in the Moniteur belge on 21 September 2026 under numac 2026006656.
The JUSTEL database gives its entry into force as 1 October 2026. Article 2 repeals the royal decree of 29 June 2018, which approved the previous code, with effect from that same date. Until 1 October the new AI chapter is published but not yet binding, and everything described below is framed on that basis: once the code takes effect, agents would be bound by it.
What the AI chapter would require
Sub-title V is headed "L'agent immobilier et l'intelligence artificielle". Once it takes effect on 1 October 2026, Article 43 would provide that an agent's use of an AI system, or use by a person the agent is responsible for, cannot undermine the agent's ethical and legal obligations.
Article 44 would add three things. First, when using AI systems in professional work, the agent "procède à une évaluation minutieuse et critique des informations ainsi générées", in our translation carries out a careful and critical assessment of the information generated. Second, a transparency duty toward third parties, covered in the next section. Third, the agent would need sufficient competence to control these systems, at a level matched to the system's complexity and the context of use.
From 1 October 2026, the second paragraph of Article 44 would set a flat rule: "L'agent immobilier ne peut introduire des données à caractère personnel dans un système d'intelligence artificielle ouvert." Our translation: the real-estate agent may not enter personal data into an open artificial intelligence system. Article 45 would bar using an AI system "dans le but de tromper des personnes", with the aim of deceiving people.
The disclosure duty carries a qualifier
Once in force on 1 October 2026, Article 44 would say the agent is transparent toward third parties and informs them of the use, even partial, of an AI system and how it is used. The same sentence then limits that duty: "dans la mesure où cela découle des obligations légales en vigueur", to the extent that this follows from legal obligations in force.
Read literally, once the code applies from 1 October 2026, that clause would tie disclosure to whatever other law already demands rather than creating a free-standing duty to label every AI-assisted listing or email. That is our reading. The code does not say which legal obligations it has in mind, and the IPI's disciplinary bodies may read it more broadly.
Terms the code defines, and one it does not
From 1 October 2026, the definitions article would add a definition of an AI system: an automated system designed to operate with varying levels of autonomy that may adapt after deployment and that infers from its inputs how to generate outputs such as predictions, content, recommendations or decisions that can influence physical or virtual environments.
The code does not define an open AI system. Whether a paid enterprise tier of a general chatbot, a tool with training on user inputs switched off, or a vendor's hosted model counts as open is left unanswered by the text.
Under the code's definitions, which apply from 1 October 2026, an agent would be a person registered either on the list of trainees or on the roll of full members, and the obligations in this title would be common to intermediaries, syndics and property managers.
A numbering discrepancy in the official text
The decree's own recital says a new sub-title V "comprenant les articles 40 à 42 concernant l'utilisation de l'intelligence artificielle est ajouté". In the online Moniteur belge text the same provisions are displayed as Articles 43, 44 and 45, and the whole annex appears to run on from the decree's own Articles 1 to 3.
We cite Articles 43 to 45 because that is the numbering in the text we read, and note that the code's internal numbering is probably 40 to 42. Cross-references inside the annex, such as Article 43's reference to article 3 for the persons an agent answers for, are consistent with that three-article offset. Check the printed page of the Moniteur belge before citing an article number in correspondence.
What we did not verify
What we opened: the full French text of the royal decree and its annexed code on the Moniteur belge site, read end to end, and the JUSTEL record for numac 2026006656, which gives the publication date, page 50952, dossier 2026-07-20/15 and the 1 October 2026 entry into force. The site blocks automated downloads with a bot check, so both pages were captured through a rendering service and saved to our evidence file; every French passage quoted here was matched against that capture. A sentence the sweep had drawn from a secondary site, the ban on entering personal data into an open AI system, is in the official text as the second paragraph of Article 44 and is quoted from there.
What we did not open: the printed PDF page of the Moniteur belge, so the article numbering discrepancy is unresolved; the Dutch text; the IPI National Council decision of 24 June 2026; any IPI commentary or guidance; and the disciplinary provisions of the framework law. We therefore say nothing about sanctions for breach and do not define an open AI system.
What we refuse to claim: that the code requires agents to label all AI-generated content, because Article 44 limits disclosure to obligations already in force; that the code implements or mirrors the EU AI Act, because it does not say so; and that the new rules bind anyone before 1 October 2026. This piece covers the AI provisions only; the new code also rewrites third-party account rules and other duties that we do not summarise.
Informational analysis for working professionals, not legal advice. Confirm how any rule applies to your situation with qualified counsel.
From 1 October 2026 the data rule translates directly into a staff control: no pasting a client's name, address or financial details into a public chatbot to draft a listing or a letter. The code does not define open; on our reading a consumer chatbot is the case most likely to be treated as open, but that is untested. The data rule has no qualifier. Before then, decide which tools your agency treats as open, write that down for staff you answer for under Article 43, and check whether any disclosure you already owe under other law now needs to mention AI.
Source File
Open the Moniteur belge text and confirm four things: the signature date of 20 July 2026, Article 2 repealing the 2018 decree from 1 October 2026, the heading of Sub-title V, and the second paragraph of Article 44 on personal data in an open AI system. Then open the JUSTEL record for the entry into force field.
L'agent immobilier ne peut introduire des données à caractère personnel dans un système d'intelligence artificielle ouvert. · Code de déontologie de l'Institut professionnel des agents immobiliers, Sub-title V, Article 44 second paragraph (Moniteur belge online numbering), published 21 September 2026, in force 1 October 2026 per JUSTEL
FAQ
When do the AI rules take effect?
On 1 October 2026, according to the JUSTEL record. The decree was signed on 20 July 2026 and published in the Moniteur belge on 21 September 2026.
Does the code require agents to disclose every use of AI?
Not on its face. From 1 October 2026, Article 44 would require transparency about AI use toward third parties only to the extent that this follows from legal obligations in force.
Can an agent use a chatbot with client data?
Not an open one, once the code takes effect. The second paragraph of Article 44 bars entering personal data into an open AI system, but the code does not define what open means.
Is the agent responsible for staff who use AI?
When the code applies from 1 October 2026, Article 43 would cover AI use by the agent or by a person the agent is responsible for, and would provide that such use cannot undermine the agent's ethical and legal obligations.
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