Who: European Commission
Where: European Union (EU)
When: 10 October 2025
Law stated as at: 22 October 2025
What happened:
The EU Regulation on transparency and targeting of political advertising (EU/2024/900) became fully effective on 10 October. The regulation establishes harmonised EU-wide rules to make political advertising more transparent through the use of labelling and transparency notices and sets conditions on the targeting and ad delivery of online political advertising, alongside rules for supervision and enforcement. It applies when political ads are disseminated in the EU, regardless of where the ad’s sponsor or provider is established and of the medium.
Political advertising
The regulation defines “political advertising” broadly to cover the preparation, placement, promotion, publication, delivery or dissemination of paid-for messages by, for or on behalf of a political actor, or messages designed to influence elections, referendums, voting behaviour or other legislative or regulatory processes. It excludes official messages limited to organising and participating in elections or referendums and that are not designed to influence the outcome of a democratic function. It also excludes the presentation of candidates in specified public spaces or in the media that have been explicitly provided for by law and allocated free of charge; for example, by allocating space in public areas or a particular broadcasting time on television, where it is done in a fair, non-discriminatory manner and based on transparent and objective criteria.
Who is affected
Providers of political ads will be affected; that is, those engaged in the preparation, placement, promotion, publication, delivery or dissemination of such ads, and political advertising publishers, usually those at the end of the production chain, are in scope. This involves a broad range of actors, including online platforms, websites, forums and blogs, video sharing sites, broadcasters, influencers, newspapers, design and advertising agencies, and ad technology providers. Very large online platforms (VLOPs) and very large online search engines (VLOSEs), as defined in the Digital Services Act, face additional duties. Small and medium-sized enterprises benefit from lighter-touch obligations, including exemptions from some record-keeping, reporting and retention duties.
Sponsors on whose behalf ads are prepared or disseminated are responsible for the accuracy of declarations that the ad is a political ad and for supplying key information that must accompany each of these ads.
Transparency obligations
Publishers must clearly label each political ad as such and make sure that the ad includes the name of the sponsor (and ultimate controller), indicates any link to an election, referendum or legislative or regulatory process and whether targeting or ad-delivery techniques are being used.
Political ads must also include a transparency notice (or clear indication of its location) containing information on the:
- Sponsor (and ultimate controller identity, where applicable) and their contact details.
- Publication period.
- Aggregated amounts and benefits received by the providers of political advertising services.
- Funding source (public or private, EU or non-EU).
- Where applicable, linked elections, referendums or legislative and regulatory processes.
- Where applicable, links to the European repository for online political advertisements.
- Where applicable, targeting or ad-delivery techniques based on using personal data.
- Where applicable and technically feasible, the advert’s reach (the number of views and engagements with the advert).
Transparency notices must be accessible, user friendly, in plain language and in machine-readable format. Publishers must retain them for seven years following the last publication of the political ad concerned. In July 2025, the European Commission adopted an implementing regulation on the format, template and technical specifications of labels and transparency notices.
Online targeting restrictions
Controllers may use targeting or ad-delivery techniques involving personal data for online political advertising only if:
- the personal data was collected from the person;
- the person gave explicit, separate consent specifically for political advertising purposes under the GDPR; and
- profiling does not involve using special categories of personal data.
Anyone who is known to be at least one year under the voting age cannot be targeted.
Controllers must also comply with additional requirements when using targeting or ad-delivery techniques, including:
- Publish an internal policy and keep records on the use of such techniques.
- Provide information with each political advert that allows individuals to understand how they were targeted. This should include whether an AI system has been used to target or deliver the political advert, the specific groups of recipients targeted, and why and how people were targeted.
- Publish an internal annual risk assessment of how targeting techniques might affect people’s fundamental rights and freedoms.
- Offer an easy way (such as a web link) for people to update their personal information and withdraw their consent.
European repository for online political advertisements
The Commission is obliged to establish a public database – the European repository for online political advertisements – for all online political ads published in the EU or directed to EU citizens. Publishers must upload, within 72 hours of first publication, each online political advert and the transparency information. VLOPs and VLOSEs must make this information available in their DSA online advertising repositories and enable access to this information through the European repository from the moment the political advert is published, throughout the entire period it is displayed, and for seven years after it was last shown on their online platforms.
Commission guidelines
On 8 October, the European Commission published guidelines to support implementation of the regulation. The guidelines offer detailed explanations of the regulation’s concepts and include practical examples of how they may apply. For example, they set out indicative questions to assess whether an activity qualifies as a political advertisement and explain the regulation’s obligations.
Why this matters
Organisations involved in any aspect of political advertising – from creation to distribution – must audit their current practices and consider any changes necessary to comply with the regulation’s requirements. The broad definition of “political advertising” and the scope of actors covered by the regulation create particular risk for organisations that have not traditionally considered themselves political advertisers. Requirements in relation to record keeping, uploading advertising information to the European repository within 72 hours of publication, and obtaining separate consent for political adverting purposes might require building new internal processes and content management workflows.
