VOW compliance requirements
The BrokerFold Team — Product + Engineering
Last reviewed
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Reviewed against primary sources (TRREB/PropTx VOW data agreement and MLS rules (operator experience) / Competition Tribunal VOW framework, Commissioner v. TREB, accessed 2026-07-26 / HouseSigma published VOW terms and FAQ (reference implementation), accessed 2026-07-26) — last reviewed July 26, 2026. This page is general information, not legal advice.
VOW compliance is the set of operating conditions attached to the VOW data feed: register consumers before they see gated data, capture terms-of-use acceptance, expire passwords on schedule, enforce the gate on the server, keep auditable records, and respect display limits. The board holds the operator to these conditions, and your website vendor is the party that actually implements most of them. This page turns the conditions into a checklist you can hand to any vendor, with how BrokerFold satisfies each line. General information, not legal advice.
The checklist, requirement by requirement
| # | Requirement | What to ask a vendor | How BrokerFold implements it |
|---|---|---|---|
| 1 | Registration before access | Can any sold record reach an anonymous visitor? | Sold and off-market data exists only in signed-in responses |
| 2 | Terms-of-use click-wrap | Is acceptance an explicit step, recorded with a timestamp? | Signup requires an affirmative terms step, stamped server-side |
| 3 | Password expiry (90 days on TRREB) | Who tracks expiry, and what happens at the boundary? | Automatic lifecycle: warnings at 7 and 1 days, expiry re-locks sold data, code-verified renewal |
| 4 | Server-side enforcement | Where are gated values removed from the response? | At the data layer, before rendering; never CSS hiding |
| 5 | Imagery discipline | What image does a locked listing show? | A pre-generated 160-pixel blurred derivative, never a real photo |
| 6 | Query limits | Are result sizes capped for VOW consumers? | Listing queries clamp to the per-inquiry cap of 100 |
| 7 | Record-keeping | What exists if the board audits? | Acceptance timestamps plus an append-only sold-data access log |
| 8 | Attribution and disclaimers | Do credits survive the lock state? | Brokerage attribution renders on locked cards; board disclaimer sitewide |
| 9 | Internal-only fields | Can private feed fields ever render? | Private remarks and similar fields are ingest-only by design |
| 10 | Registered URLs | Is the VOW running only on URLs the agreement names? | Site URLs are registered through the data agreement flow |
The rest of this page expands the lines that most often separate a real implementation from a brochure claim.
Registration, terms and the password clock
The wall is a three-part contract with the consumer. They register, they affirmatively accept terms of use that establish a broker-consumer relationship and bind them to personal, non-commercial use, and they hold a password whose validity is capped at 90 days under TRREB’s terms, renewable thereafter. Operationally the details are unforgiving: the acceptance has to be recorded, the expiry has to be derived per request rather than trusted to a cron job, and a renewal must restore access without silently manufacturing a terms acceptance that never happened. These are the mechanics BrokerFold runs in production for every tenant site, described from the visitor’s side on what is a VOW.
Server-side gating is the load-bearing requirement
Every other line on the checklist can be satisfied on paper while the site still leaks. The test is simple: open a sold listing as an anonymous visitor and inspect the page source. If the address, price or photo URLs are present but visually obscured, the site is publishing gated data and decorating it. A compliant implementation redacts on the server, so the anonymous response never contains the gated values, and shows purpose-built blurred preview images generated in the image pipeline. This is how BrokerFold is built, and it is the single most revealing question to put to any vendor on this list.
Records: what you want to exist when someone asks
The agreement makes the operator accountable for who accessed gated data. Two artifacts cover that accountability: a per-visitor record of terms acceptance with its timestamp, and a log of sold-data access by registered visitors that cannot be edited after the fact. BrokerFold writes both automatically, which means the audit answer is a query, not an archaeology project. Vendors who cannot say what they log have answered the question.
Boundaries that persist even for signed-in visitors
Compliance does not end at the login. Per-inquiry result caps apply to VOW consumers. Fields licensed for brokerage-internal use, private remarks being the obvious example, stay out of every consumer surface regardless of session state. And the sold-data permission is a display permission on your registered VOW, not a general publication right; marketing a specific transaction remains a separate, consent-based activity under RECO’s advertising rules.
Using this list
If you are evaluating platforms, send the table above and ask for a demonstration of lines 1, 4 and 5 on a live site, since those are the ones that cannot be faked in a sales deck. If you are already running a VOW, the TRREB VOW website page shows what a current implementation looks like, and the VOW website pillar covers the platform end to end.
Keep reading
- VOW website A VOW website shows registered visitors the sold prices and off-market history anonymous sites can't display. How VOWs work, and how BrokerFold runs one.
- What is a VOW A VOW (Virtual Office Website) is a password-protected real estate site that can show sold prices and off-market MLS data to registered consumers.
- TRREB VOW website A TRREB VOW website shows GTA sold prices and off-market history to registered visitors. What the TRREB VOW feed contains and how BrokerFold serves it.