This section provides a structured overview of the responsibilities for platforms, publishers, ad servers, and ad-tech intermediaries under the DSA and EU Regulation 2024/900 on Political Advertising Transparency.

1. Transparency Label Obligations

Who is affected: Online platforms, publishers (when hosting political ads), ad servers & ad-tech intermediaries (when involved in delivery/targeting).

Every political ad must:

  • Be clearly labelled as "political advertising"
  • Name the sponsor / payer
  • State on whose behalf it is placed
  • Explain the key targeting criteria
  • Provide a link to further information (transparency notice)

Ad-tech intermediaries must ensure that labelling signals (metadata flags) are correctly transmitted throughout the entire delivery chain.

2. Record-Keeping Requirements

Documentation must be maintained for:

  • Advertiser identity
  • Expenditure amounts
  • Display period
  • Targeting criteria
  • Creative deliverables
  • Impression count / reach

Records must:

  • Be maintained for a specified retention period
  • Be available to national regulatory authorities upon request

Ad-tech intermediaries must maintain logs for ad delivery & targeting.

3. Repository Obligations

Applies primarily to Very Large Online Platforms (VLOPs) and major digital platforms. They must maintain:

  • A public, accessible ad repository
  • Information on: sponsor, expenditure (where required), targeting parameters, display period, reach metrics

Publishers do not always have a public repository obligation, but may be required to provide data upon request.

4. Response Obligations to Regulatory Authorities

All involved parties must:

  • Cooperate with national authorities
  • Provide data within deadlines
  • Disclose targeting and delivery data
  • Provide technical documentation

In case of violation: administrative fines and potentially high sanctions (especially for VLOPs).

5. Enhanced Duties Before Elections

During pre-election periods:

  • Enhanced review of advertising content
  • Faster response to reports
  • Strengthened monitoring of political campaigns
  • Special risk mitigation procedures
VLOPs Ad-Tech Intermediaries
Obligation for risk assessment regarding systemic risks (electoral manipulation, misinformation). Must have an escalation process and the ability to freeze campaigns immediately.

6. Responsibility for Amplification

Responsibility exists when:

  • The platform amplifies content through algorithms
  • Promotes political advertising via paid boosting

Obligations include:

  • Transparency in the promotion mechanism
  • Explanation of targeting logic
  • Risk mitigation for manipulation
  • Special attention to microtargeting

Prohibited: Targeting based on sensitive personal data (religion, ethnicity, etc.) and targeting of minors.

Responsibility Matrix

ACTOR LABEL RECORDS REPOSITORY AUTH. RESPONSE PRE-ELECTION
Platforms ✓ ✓ VLOPs ✓ ✓✓
Publishers ✓ ✓ Limited ✓ ✓
Ad Servers Pass-through Logs X ✓ ✓
Ad Tech Metadata ✓ X ✓ ✓

Risk & Penalties Overview

  • Fines up to 6% of global turnover (DSA)
  • National sanctions for political advertising violations
  • Reputation risk
  • Potential ban from providing services