On 10 October, the EU’s Transparency and Targeting of Political Advertising Regulation (TTPA) entered into force. The Regulation aims to make political advertising more transparent and to prevent interference by external actors in elections.

This blog explains how the Regulation defines political advertising, who it applies to, how it changes advertising practices, and what obligations different actors have under it.

HOW IS POLITICAL ADVERTISING DEFINED?

The Regulation defines advertising as political if it is provided, prepared, or disseminated by, for or on behalf of a political actor, in return for payment or equivalent consideration, as well as advertising which purpose or effect is to influence the outcome of an election or referendum, or a legislative or regulatory process.

“Political advertising” refers to the preparation, placement, promotion, publication, delivery or dissemination—by any means—of a message, typically for remuneration or as part of one’s own campaign. It covers political communication in all forms, including online activity such as coordinated posts or messages shared through bots, if they meet the definition of political advertising.

Political advertising does not include communication of official information by public authorities in a neutral manner, or editorial content subject to journalistic responsibility—such as information on how to vote. The Regulation also does not govern the content or opinions expressed in political advertisements; it concerns only the transparency and targeting requirements applicable to them.

The European Commission has published guidelines to support the implementation of the Regulation. On page 26, you can find a table of guiding questions to help assess whether an advertisement qualifies as political.

WHO DOES THE REGULATION APPLY TO?

The Regulation applies to sponsors of political advertising and to providers of political advertising services.

  • A sponsor is defined as “the natural or legal person at whose request or on whose behalf a political advertisement is prepared, placed, promoted, published, delivered or disseminated.”
  • Providers of political advertising services are actors who offer political advertising services in return for payment or other consideration. These include, for example, advertisement producers (such as advertising agencies), publishers (such as newspapers, influencers, blogs, and billboards), as well as distributors and technology platforms (such as advertising platforms).

The Regulation does not apply to ancillary services that merely transmit or support the transmission of political advertisements without receiving payment specifically for the publication of that advertisement, and without influencing its content. For instance, internet access providers or printing houses that only deliver messages on behalf of others are not covered by the Regulation. Similarly, social media platforms are not covered if they have not received payment for the dissemination of the advertisement.

It is also important to note that the classification as political advertising depends on the content, not on who funds it. If an advertisement meets the definition of political advertising, it falls within the scope of the Regulation regardless of the nature of the organisation. Thus, for example, a charitable organisation may qualify as a provider of political advertising services if it engages in activities relating to political influence.

Violations of the Regulation may result in sanctions for the publisher of the advertisement. These may amount to up to 6% of the publisher’s annual turnover. Violations are monitored by national competent authorities that are designated by the member states.

HOW DOES THE REGULATION AFFECT ADVERTISING?

From now on, all political advertisements must be clearly labelled and must indicate who paid for themto which election or referendum they relate, and whether the advertisement was targeted at a specific group of individuals.

Each advertisement must also include, or provide easy access to, a transparency notice. The transparency notice must contain additional information, such as details of the sponsorship, financing and its origin.

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An example of how to label a political advertisement. This is not a real advertisement. 

Political advertisements and their accompanying transparency notices must also be transmitted to the European Union repository, which is to be established for this purpose by 10 April 2026.

Political advertising online may only be targeted at adults who have given their consent to receive political advertising. Profiling based on special categories of personal data—such as data revealing ethnic origin, health status or political opinions—is strictly prohibited.

In addition, during the three months preceding an election or referendum, political advertising services may only be provided to sponsors established or residing within the European Union. They cannot be provided to third-country sponsors, regardless of the advertisement’s content.

HOW HAVE TECH GIANTS AND MEDIA COMPANIES RESPONDED TO THE REGULATION?

In response to the Regulation, Google, Meta, and Microsoft have banned political advertising entirely on their platforms within the European Union. Citing the Regulation, these platforms also restrict a wide range of social issue advertising.

For example, Meta has extended its ban to include advertisements concerning “social issues” within the EU. Meta defines social issues as content relating to:

  • civil and social rights
  • crime
  • the economy
  • environmental policy
  • health
  • immigration
  • political values and governance
  • security and foreign policy

Civil rights organisations, such as The Civil Liberties Union for Europe, have criticised the Regulation’s broad and ambiguous definition of political advertising, arguing that it could be interpreted as covering communication by civil society organisations — such as advocacy campaigns or public debate — and therefore risk limiting their role in democratic discourse.

The European Commission’s guidance, published on 8 October 2024, clarifies that not all advertising related to social or societal issues qualifies as political advertising. Commercial campaigns that address themes such as equality or sustainability, without the intention to influence elections, voting behaviour or legislative processes, primarily reflect the brand’s values and do not fall within the definition of political advertising.

The decisions of the major technology platforms also affect media companies that rely on their networks for display advertising, such as Sanoma, one of Finland’s largest media groups and publisher of the national daily Helsingin Sanomat.

Sanoma has described the platforms’ bans as problematic for freedom of expression, arguing that they go “against the fundamental principles of Western societies.” As a result of Microsoft’s decision, Sanoma has had to restrict certain types of social issue advertising across its digital channels.

Another major Finnish media group, Keskisuomalainen, sees both challenges and opportunities in the EU Regulation. While the new rules increase administrative work and technical requirements for publishers, they may also redirect advertising revenue from Meta and Google’s platforms to domestic media outlets.

However, Keskisuomalainen also notes a concern that advertisers might perceive compliance as too complex, which could discourage political and social advertising altogether. Therefore, it stresses the importance of making the ad-buying process as straightforward as possible for advertisers.

RESPONSIBILITIES OF SPONSORS, SERVICE PROVIDERS AND PUBLISHERS OF POLITICAL ADVERTISING

Actor

Responsibilities

Sponsors

  • The sponsor must indicate whether the service they request constitutes political advertising.
  • The sponsor must declare if they are under the control of another entity.
  • During the three months preceding an election or referendum, the sponsor must demonstrate that they are established or residing within the EU and therefore entitled to request political advertising services.
  • The sponsor must provide the political advertising service provider with all information required under the Regulation concerning the advertisement.
  • The information provided must be accurate and up to date, and sponsors must promptly correct or update it if any changes occur.
  • The sponsor must respond without undue delay to requests from the service provider to rectify incomplete or inaccurate information.

Service Providers

  • Providers must not discriminate against sponsors established or residing within the EU on the grounds of their place of residence or establishment, unless such differential treatment is objectively justified.
  • During the three months preceding an election or referendum, political advertising services may only be provided to sponsors established or residing within the European Union; they cannot be provided to third-country sponsors.
  • Providers must ensure that contracts for political advertising services clearly define the respective responsibilities and information flows so that the Regulation’s requirements are fulfilled and information is properly transmitted throughout the entire advertising chain.
  • Providers must ensure that their clients declare whether the requested service constitutes political advertising and that they meet the conditions set out in the Regulation. Providers must retain these declarations.
  • Providers must include the requirements of the Regulation in their contractual terms and conditions.
  • Providers must offer clear and user-friendly means for sponsors to submit the required information.
  • Providers must request sponsors to correct manifestly erroneous or incomplete information, where necessary. However, they are not required to verify the accuracy of the information or declarations provided, unless they appear manifestly incorrect without the need for further verification.
  • Providers must retain information related to each political advertisement for seven years in a machine-readable format.
  • Providers must transmit all relevant information concerning political advertising accurately, completely and in a timely manner to publishers, competent authorities and other authorised entities, in accordance with the Regulation.
  • Providers must designate a contact point for interactions with competent authorities, and this contact information must be easily accessible, for example, on their website.
  • Providers established outside the EU who offer political advertising services within the Union must designate, in writing, a legal representative in one of the Member States and register this representative with the competent authorities. The representative is responsible for ensuring compliance with the Regulation and may be held liable for infringements.

Publishers

  • Publishers must ensure that each political advertisement is accompanied by a label and a transparency notice containing complete and up-to-date information as required by the Regulation.
  • Publishers must retain the transparency notices for seven years.
  • If a publisher becomes aware that the information is incomplete or inaccurate, it must make best efforts to complete or correct the information without undue delay.
  • Publishers must suspend the dissemination of the advertisement if the incorrect information cannot be corrected promptly.
  • Publishers of online political advertising must ensure that political advertisements and their associated transparency notices are transmitted to the European Commission’s political advertising repository once it becomes operational.
  • Large publishers must include in their annual financial report information on revenues received from political advertising and on any targeting or ad-delivery techniques used, and must provide this information to the national competent authorities upon request.
  • Publishers must provide an accessible and free-of-charge reporting mechanism through which any person can report political advertisements that may infringe the Regulation.
  • Such reports must be handled without undue delay, and particularly within 48 hours during election periods.
  • Where necessary, the publisher must suspend or correct the publication in cooperation with the sponsor or service provider.

Providers of Advertising Technology

  • Providers of advertising technology must ensure that political advertisements include the required label and transparency notice as set out in the Regulation.
  • Providers must agree with publishing platforms on the allocation of responsibilities in a way that avoids duplication of information or labelling obligations.
  • Providers must transmit to publishing platforms the information received from sponsors, where those platforms do not obtain it directly.
  • Providers must correct or complete any missing or inaccurate information without undue delay, in cooperation with the publishing platforms.

Content Producers/Influencers

  • Content producers must determine whether the requested service constitutes political advertising and ensure that the sponsor is entitled to request such advertising.
  • Content producers must collect and retain the required information, and ensure that political advertisements are properly labelled and accompanied by a transparency notice.
  • Content producers must provide users with a mechanism to report advertisements that may infringe the Regulation.
  • Content producers must transmit the advertisements and the related information to the European repository for political advertising once it becomes operational.
  • Content producers are subject to the same obligations as publishers, unless the exemptions for micro, small and medium-sized enterprises apply.

Small and Medium-Sized Enterprises (SMEs)

  • Microenterprises whose political advertising services are only an ancillary activity are exempt from the obligation to retain information and from the seven-year data storage requirement.
  • SMEs are not required to include annual reporting on revenues from political advertising in their financial statements.
  • Microenterprises must make best efforts to provide feedback to any individual who has submitted a report concerning a potentially non-compliant political advertisement, indicating what actions have been taken as a result.
  • SMEs are not subject to the 48-hour deadline for handling reports during election periods, but they must still act without undue delay.
  • When responding to requests for information from competent authorities, SMEs may use an extended deadline of 12 working days. Before elections, information should be provided as soon as possible before polling day.
  • SMEs may designate an external contact point to handle communications with ministries or competent authorities.