This section outlines the responsibilities of platforms, publishers, ad servers, and ad-tech intermediaries under EU Regulation 2024/900, with emphasis on transparency labels, notices, targeting, and record-keeping.

Who Are "Providers of Political Advertising Services"

The Regulation covers every entity that prepares, places, promotes, publishes, delivers, or distributes political advertising. This includes:

  • Online Platforms
  • Publishers
  • Ad Servers
  • DSP / SSP
  • Ad Exchanges
  • Media Agencies

Transparency Label Obligations

The label (Article 11) is the immediate visual marking that content is political advertising. The responsibility falls on the political advertising publisher - the entity that ultimately displays the ad to the user.

ROLE LABEL RESPONSIBILITY NOTES
Social Platform Responsible Full publisher responsibility
Publisher Site Responsible Full publisher responsibility
CTV Platform Responsible Full publisher responsibility
DSP Not publisher Must provide the data
Ad Server Technical implementation Supports label rendering

The label must:

  • Be clear and prominent
  • State that the content is political advertising
  • Reference the Transparency Notice
  • Appear immediately upon publication

The format is determined by Implementing Regulation 2025/1410.

Transparency Notice Obligations

The publisher must ensure the following information is available:

  • Sponsor identity
  • Ultimate controlling entity
  • Expenditure amount (ad & campaign level)
  • Source of funding
  • Electoral process
  • Dissemination period
  • Targeting information (where applicable)
  • Reporting mechanism

Accuracy of Information

  • The sponsor provides the data
  • The publisher must make reasonable efforts to verify completeness
  • If there are obvious inaccuracies → cannot claim ignorance

Targeting & Ad Delivery

If the platform or ad-tech provides microtargeting, audience segmentation, or optimisation/amplification, additional obligations apply:

  • Transparency regarding targeting criteria
  • No use of prohibited data
  • GDPR compliance
  • Recording of targeting parameters

Record-Keeping (Article 9)

Obligation for all providers of political advertising services. Records must be maintained for 7 years in machine-readable format:

ACTOR WHAT MUST BE RECORDED
All Providers Campaign served, service provided, amounts invoiced/received, origin of funds, sponsor identity, linked electoral process
Platforms Full delivery & monetisation trail, targeting parameters
Publishers Revenue per political campaign, dissemination period
Ad Tech (DSP/SSP/Exchanges) Budget allocation trail, tech/service fees, targeting configuration logs

Role-Specific Exposure

A. Online Platforms (High Exposure)

The most exposed layer. Obligations include:

  • Label, Notice, Reporting mechanism
  • Repository obligations
  • Targeting transparency
  • Cooperation with authorities

B. Publishers

  • Label implementation
  • Notice provision
  • Revenue record-keeping
  • Cooperation in audits

C. Ad Servers

Do not necessarily bear sponsor transparency responsibility, but carry technical compliance:

  • Technical support for label rendering
  • Delivery recording
  • Record-keeping for service provided

D. DSP / SSP / Exchanges

Not always a publisher, but bear significant responsibility when controlling targeting:

  • Record-keeping
  • Financial traceability
  • Targeting documentation
  • Cooperation with publisher for notice data

Risk & Liability Overview

High-risk violations include: missing labels, incomplete notices, concealed sponsors, illegal microtargeting, and non-cooperation with authorities.

Sanctions may include:

  • Administrative fines
  • Ad withdrawal
  • Dissemination suspension
  • Combined liability with GDPR
  • Public disclosure of violations

Repository Obligations (European Repository)

Applies to online political advertising publishers. They must:

  • Register political ads in a public repository
  • Provide machine-readable transparency data
  • Maintain entries for a specified period

This primarily affects social media platforms, large digital platforms, and publishers with online political inventory. DSPs/ad servers don't register directly but provide data to the publisher.

Response Obligations to Regulatory Authorities

All providers are required to:

  • Respond to information requests
  • Provide records within deadlines
  • Cooperate in cross-border investigations
  • Execute withdrawal/suspension orders

Platforms have an enhanced cooperation obligation due to their "gatekeeper" role.

Enhanced Duties Before Elections

During pre-election periods:

  • Increased oversight from authorities
  • Faster response to notices
  • Potentially shorter compliance deadlines
  • Increased scrutiny on targeting and amplification

Platforms and major publishers are expected to have dedicated compliance teams, fast-track review mechanisms, and real-time transparency updates.

Responsibility for Amplification

The Regulation covers not just "ad placement" but also algorithmic amplification, optimisation, promotion boosting, and paid visibility enhancement.

If a platform artificially boosts the visibility of political advertising or uses recommendation systems, that amplification is considered a political advertising service - subject to transparency & record-keeping. Key targeting/ad-delivery parameters must be declared. DSPs with auto-optimisation engines have increased exposure.

Risk Gradient

Platform Type Risk Level
Large Online Platforms Very High
Major Publishers High
DSP/SSP with Targeting Control High
Pure Ad Server (Technical Only) Medium
Infrastructure-Only Hosting Low

Executive Summary

The Regulation transforms the digital ad ecosystem into:

  • A transparency-first environment
  • A financially traceable system
  • A regulator-auditable infrastructure

Platforms bear the heaviest burden.

Intermediaries carry significant risk when they control targeting or budget flow.

Publishers are the final transparency executors.