The new code of ethics of the IPI, Belgium’s professional institute of real estate agents, was approved by Royal Decree of 20 July 2026 and replaces the 2018 code, repealed as of 1 October 2026. For a property management agency, three blocks matter day to day: the use of artificial intelligence, statements to owners and client money accounts.

What changes on 1 October 2026?

The Royal Decree of 20 July 2026 approving the code of ethics of the Institut professionnel des agents immobiliers (IPI, BIV in Dutch) was published in the Belgian Official Gazette on 21 September 2026. Its Article 1 makes the annexed code binding. Its Article 2 repeals the Royal Decree of 29 June 2018 as of 1 October 2026. The text sets no other date for the new code; DroitBelge reports that it enters into force on 1 October 2026.

The code was adopted by the IPI National Council on 24 June 2026. It keeps the 2018 structure: common obligations, obligations of the intermediary agent, obligations of the property administrator. Three blocks directly concern the property manager, meaning the agent who manages property on behalf of others. A whole sub-title is devoted to artificial intelligence (Articles 43 to 45). Statements to owners remain due at least once a year (Article 73). Finally, the ethics directive on client money accounts is built into the code (Articles 92 to 94) and, according to the preamble, repealed as a separate text. The code is published in French and Dutch; the wording below is our translation.

What does the code say about artificial intelligence?

Sub-title V, “The real estate agent and artificial intelligence”, has three articles. Article 43 sets the principle: using an AI system, by the agent or by a person for whom the agent is responsible, may not undermine the agent’s ethical and legal obligations. Article 44 requires a careful and critical assessment of the information generated this way. It also requires transparency towards third parties about the use of an AI system, to the extent that this follows from the legal obligations in force. The agent must also have sufficient skills to master these systems. Its second paragraph is the most concrete: the agent may not enter personal data into an open artificial intelligence system. Article 45 prohibits using AI with the aim of deceiving people. For an agency, the consequence is direct. A reminder letter, a listing or a reply drafted by an assistant binds the agent as if the agent had written it personally.

These rules complement the EU regulation on AI, which imposes its own transparency obligations on providers and professional users of certain systems. The IPI code does not cite it, but its definition of an AI system, in Article 5, is very close to it. What the regulation already requires of agencies is detailed in our article on the AI Act and real estate agencies.

What is an “open” AI system?

The code does not define it. Its Article 5 only defines an “artificial intelligence system”. Until the IPI clarifies the notion, the agency must decide for itself, tool by tool. The cautious reading is to treat as open any tool where the agency does not contractually control the reuse of the data entered. That is the case of consumer assistants used with a personal account. A tenant’s name, an address, an IBAN, a payslip or an application file do not belong there. This reading is ours, not the IPI’s: it is a precaution, nothing more.

What must a statement to the owner contain?

Article 73 targets the real estate agent acting as property administrator. Article 5 includes both the syndic and the property manager under that term: rental management is therefore covered. The text requires accounts, statements and asset reports that are clear and broken down by category and type of costs, expenses and income. Their frequency is the one set by the agreement, and at least once a year. No rule requires a monthly statement: the mandate sets the pace, with an annual minimum. Article 75 adds a duty to inform: the manager informs the client in good time of the legal requirements relating to the property and of the risks of not complying with them. These two articles take over Articles 69 and 71 of the 2018 code. They extend the civil obligation to account for one’s management, set out in Article 1993 of the former Civil Code. For the agency, a summary annual statement meets the minimum, but not the requirement of a breakdown by category.

What about Book 7 of the Civil Code?

The Act of 22 July 2026 inserting Book 7, “Special contracts”, into the Civil Code was published in the Belgian Official Gazette on 23 September 2026. It enters into force on the first day of the twelfth month following its publication, that is 1 September 2027. It then repeals Article 1993. The mandate becomes a service contract. Article 7.4.27 provides that the service provider accounts for the amounts managed and returns the balance to the client. Mandates concluded before that date remain subject to the previous rules, unless the parties agree otherwise.

What changes for client money accounts?

Article 92 requires the intermediary agent to hold one or more client money accounts for third-party funds. The property manager has the same obligation, with a single exception, now narrower. The manager is exempt only if acting exclusively as property manager and if all clients have opened a personal account for this purpose. The agreement with the bank must provide that a client money account never shows a debit balance, and that it supports neither credit nor security. No set-off with the agent’s other accounts is allowed. The agent also notifies the IPI of the numbers of its client money accounts and of any change. Article 93 requires funds to be handed over without delay, after settlement, to those entitled, when the parties or a court require it. Article 94 requires transparent operations. For an agency that collects rent, the practical consequence is twofold. The property manager exemption must be checked mandate by mandate, and the accounts must be declared to the IPI.

The code sets no figure for deadlines. Deadlines come from Article 21/2 of the Act of 11 February 2013 organising the profession, in force since 1 August 2018. The agent transfers the funds to the person entitled as quickly as possible. If this cannot be done within four months of receipt, the agent pays them into a dedicated account, unless the total does not exceed EUR 2,500. For the property manager, a contrary agreement may set aside the quick transfer. Published disciplinary decisions on client accounts are detailed in our article on what the Executive Chamber sanctions.

Are these breaches actually sanctioned?

The IPI 2025 annual report lists 2,008 disciplinary files opened and 402 decisions, including 48 strike-offs and 228 suspensions. The report does not break these sanctions down by ground. It is therefore not possible to say what share concerns client money accounts. In 2019, the IPI wrote that its Executive Chamber had recently imposed a major sanction, suspension or strike-off, on several agents for not having a client money account or mismanaging it.

What should be settled before 1 October?

Here are the points to settle, in the order in which they are easiest to check:

  1. Inventory the AI tools used on files: who uses them, for what, with which data, and what the provider’s contract says about reuse of the data entered.
  2. Write an instruction for the team: no personal data in a tool the agency does not contractually control.
  3. Review every AI output before sending: the careful and critical assessment required by Article 44 implies a human review.
  4. Check the skills of the people who use these tools, and document their training.
  5. Review management mandates: frequency of statements, categories of expenses and income, pace of payouts.
  6. Declare client money accounts to the IPI, then check the property manager exemption mandate by mandate.
  7. Check old balances: funds held for more than four months above EUR 2,500 must go to a dedicated account.

The new code also widens the question of evidence. A written instruction, a review trail and a detailed statement are the documents an inspection by the Executive Chamber could request. On obligations specific to professionals, see also our article on the “professional” landlord under the Code of Economic Law.

Where does Seido stand on these rules?

Managing several properties? Seido builds each owner’s management report from rent, charges, fees shown separately and maintenance jobs. The pace is set per owner, monthly or quarterly, and nothing is sent before your approval. On the AI side, Seido sorts incoming requests and suggests a category, a priority and a contractor: you decide. Your obligations under Article 44 remain yours, and it is up to the agency to classify each tool in its inventory. See Seido’s owner reporting.

The particularly sensitive question of applicant data is covered in our article on tenant selection. On digital evidence, see also the digital inventory.

Frequently asked questions

Does the new code apply to property managers or only to syndics?

To both, and to intermediary agents. The AI rules (Articles 43 to 45) sit among the obligations common to all real estate agents. Article 73 on statements targets all property administrators, defined in Article 5 as the syndic and the property manager. Articles 92 to 94 on client money accounts target the intermediary agent and the property manager. The syndic falls outside them, but is subject to its own Article 81, which requires separate accounts for each association of co-owners.

Must tenants be told that a text was drafted with AI?

Article 44 requires informing third parties about the use of an AI system to the extent that this follows from the legal obligations in force. The code therefore does not create a general obligation to label every letter. It refers to texts that already require information, such as the EU AI regulation for certain systems. In practice, the agency must identify these cases and document them in its internal instruction.

Is an annual statement enough?

It meets the minimum of Article 73, provided it is clear and broken down by category and type of costs, expenses and income. But the frequency is first the one set in the mandate: if the mandate promises a quarterly statement, that pace applies. The civil obligation to account for one’s management (Article 1993 of the former Civil Code) comes on top of this ethical rule. Many agencies choose a shorter pace to limit owners’ questions.

What is a dedicated account?

It is an individual account opened for a specific file or client, under Article 21/2 of the Act of 11 February 2013. The client money account, by contrast, is a pooled account. An agent who cannot transfer funds to the person entitled within four months of receipt must pay them into a dedicated account. The obligation does not apply when the total per person, per transaction or per file does not exceed EUR 2,500.

Sources and references

Last updated: September 2026. This article is provided for information purposes only and does not constitute legal advice. For any specific situation, consult a real estate law professional or the IPI.