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 them, to 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.
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 |
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Sponsors |
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Service Providers |
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Publishers |
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Providers of Advertising Technology |
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Content Producers/Influencers |
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Small and Medium-Sized Enterprises (SMEs) |
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