By Dennis R. Riccio, President, Central Arizona Association of REALTORS®

This update highlights critical ADRE rule changes effective December 13, 2025, including shorter reporting deadlines, expanded disclosure duties, and increased broker accountability. All CAAR members should review the sections applicable to their license type and consult their broker or legal counsel as needed

Arizona Department of Real Estate Rule Changes Now in Effect

The Arizona Department of Real Estate has implemented sweeping revisions to the Arizona Administrative Code governing real estate licensees. These changes were approved by the Governor’s Regulatory Review Council and became effective December 13, 2025.

Because these revisions significantly impact both real estate agents and designated brokers, the Arizona Association of REALTORS® published a two-part legal analysis authored by AAR General Counsel Aaron Greene. This article highlights the most consequential changes and identifies areas where immediate compliance attention is required. Links to AAR’s full legal breakdown are included below.

Why These Changes Matter

The revised rules affect nearly every aspect of real estate practice, including disclosure obligations, advertising standards, supervision requirements, transaction file retention, reporting deadlines, and team and DBA structures. In many cases, the rules impose stricter timelines and expand duties that previously applied more narrowly.

Key Changes Affecting Real Estate Agents

Agents must be aware of several changes that directly affect day-to-day practice:

• Shorter reporting deadlines. Agents now have only 10 calendar days, not business days, to report changes in licensing or contact information to ADRE.
  • Expanded disclosure duties. Disclosure obligations now extend beyond clients and may apply to non-clients, including when an agent is acting as a principal in the transaction.
  • Performance and availability requirements. Agents must perform license duties expeditiously and promptly notify their designated broker if they are unable to perform, even on a temporary basis.
  • Advertising rule expansion. All advertising, including online, electronic, and AI-assisted marketing, is now explicitly regulated and must clearly identify the employing broker’s legal name or registered DBA without requiring scrolling.

👉 Because these rule changes involve interpretive and enforcement issues, members are strongly encouraged to review AAR General Counsel Aaron Green’s detailed legal analysis here: 

https://www.aaronline.com/2025/12/04/adre-rule-revisions-effective-december-13-2025-part-2/

Key Changes Affecting Designated Brokers and Branch Managers

The revised rules materially increase broker accountability and oversight obligations:

• Heightened responsibility for advertising. Designated brokers may now be held responsible for all advertising produced by the brokerage.
  • Mandatory progressive discipline. Brokers must establish and enforce progressive disciplinary policies addressing licensee violations of law or brokerage policy.
  • Expanded transaction file retention. Brokers must retain all disclosures and all documents signed by the parties, not just escrow and settlement documents.
  • Multiple DBA ownership requirements. Employing brokers may register multiple DBAs only if the broker entity owns at least ten percent of each.
  • Potential fingerprint requirements for renewals and new team registration rules, subject to further ADRE guidance.

👉 Because these rule changes involve interpretive and enforcement issues, brokers and branch managers are strongly encouraged to review AAR General Counsel Aaron Green’s detailed legal analysis here:

https://www.aaronline.com/2025/11/26/adre-rule-revisions-effective-december-13-2025/

What CAAR Members Should Do Now

CAAR strongly encourages all members to review the full AAR legal analyses, update internal policies and advertising practices, and ensure agents and staff understand the new timelines and disclosure requirements. Additional guidance from ADRE and AAR is expected, and CAAR will continue to provide updates as clarification becomes available.

This article is provided for informational purposes only and is not intended as legal advice. Members should consult their designated broker or independent legal counsel regarding compliance obligations.

AGENT QUICK REFERENCE GUIDE
What Every Agent Needs to Know

Reporting Deadlines
• You now have 10 calendar days to report changes to your licensing or contact information to ADRE.

Disclosures
• Disclosure duties may apply to non-clients, including when you are acting as a principal.
• Material adverse facts must be disclosed even if they are not technical property defects.

Performance Obligations
• You must perform license duties expeditiously.
• If you are unable to perform your duties, you must promptly notify your designated broker.

Advertising Rules
• Owner permission is required before placing signs or advertising property.
• All advertising must clearly identify the employing broker’s legal name or DBA without scrolling.
• Online, electronic, and AI-assisted advertising is regulated.
• Special disclosures apply when advertising another licensee’s listings or transaction history.

Bottom Line
When in doubt, consult your designated broker before advertising, disclosing, or delaying performance.

BROKER COMPLIANCE CHECKLIST
Effective December 13, 2025

Supervision and Policy Updates
☐ Review and update brokerage policy and procedures manuals
☐ Implement a written progressive discipline policy
☐ Actively enforce brokerage policies and statutory compliance
☐ Confirm branch manager letters of authority clearly define delegated duties

Advertising Oversight
☐ Review all brokerage advertising for compliance
☐ Ensure employing broker legal name or registered DBA appears clearly and without scrolling
☐ Confirm owner permission is obtained for all signs and advertising
☐ Monitor agent and team online, social media, and AI-generated advertising

Transaction File Retention
☐ Retain all disclosures made during the transaction
☐ Retain all documents signed by the parties
☐ Confirm file retention systems capture required records

Licensing and Reporting
☐ Calendar the new 10 calendar day reporting deadline for ADRE notifications
☐ Review ownership documentation for all registered DBAs
☐ Monitor guidance regarding fingerprint renewal requirements

Teams
☐ Track team names and membership
☐ Prepare for potential ADRE team registration requirements