The Regulation on the transparency and targeting of political advertising (EU) 2024/900, sometimes referred to as TTPA, entered into force on 9 April 2024. Most provisions take effect on 10 October 2025, providing businesses with adequate preparation time. By standardising rules on the provision of political advertising services, this regulation addresses specific challenges such as information manipulation and foreign interference in democratic processes across the European digital advertising ecosystem.
Understanding the Political Advertising Regulation
The TTPA serves two primary objectives: contributing to the functioning of the internal market for political advertising whilst protecting fundamental rights and freedoms and supporting open and fair political debate. The regulation addresses concerns about information manipulation and foreign interference in elections and legislative processes. At its core, it aims to equip EU citizens with better tools for making informed decisions.
The regulatory scope extends beyond traditional campaign advertising. Coverage includes political advertising by, for or on behalf of political actors, plus any advertising liable and designed to influence elections, referendums, voting behaviour, or legislative processes. This applies across EU, national, regional, and local levels.
What the regulation deliberately avoids is equally important. It doesn’t affect the content of political advertisements or campaign conduct, which remain under Member State jurisdiction. Content under editorial responsibility and personal views expressed individually fall outside the scope. The drafters carefully preserved editorial independence and freedom of expression.
Transparency Requirements for Political Advertising
The transparency obligations under TTPA introduce new operational requirements for political advertising across digital and traditional media channels. These requirements reshape how political communications operate in practice.
Publishers must ensure every political advertisement carries clear labels and accessible transparency information. The obligations cover several operational areas:
- ▶ Labelling requirements: Political advertisements must identify themselves clearly, showing who funded them, which electoral process they target, and whether targeting or ad-delivery techniques are employed;
- ▶ Transparency notices: Publishers must provide detailed information about funding sources, publication periods, and links to additional resources including the European repository for political advertising;
- ▶ Record maintenance: Seven-year retention of detailed records in machine-readable formats, enabling regulatory oversight and public accountability;
- ▶ Contractual frameworks: Service providers are encouraged to establish agreements that facilitate compliance throughout the advertising supply chain;
- ▶ Notification systems: Publishers must implement accessible mechanisms for reporting non-compliant advertisements;
- ▶ Processing timelines: During the month preceding elections or referendums, publishers must process non-compliance notifications within 48 hours.
Articles 18-20 establish additional operational requirements relative to the use of targeting and ad-delivery techniques based on the processing of personal data. Unlike the requirements above, the latter are imposed on any entity within the supply chain that qualifies as data controller (or joint controller), as defined in the General Data Protection Regulation (EU) 2016/679.
Similarities between DSA and TTPA
Both regulations prioritise transparency and user protection, with TTPA building upon foundations established by the DSA. The relationship becomes apparent when comparing DSA Article 26 with TTPA Articles 11-12.
Key shared principles include:
- ▶ Real-time disclosure obligations: Both regulations require clear, immediate identification of advertising information;
- ▶ Advertiser identification: Both mandate disclosure of the entity behind the advertisement;
- ▶ Payment transparency: When the funding source differs from the advertiser, both regulations require clear disclosure;
- ▶ Targeting information: Recipients receive meaningful information about targeting parameters or techniques used in the delivery of the ad;
- ▶ Prominence standards: Both require clear, prominent markings enabling easy advertisement identification;
- ▶ User control provisions: Both provide information about modifying targeting preferences, where applicable, or withdrawing consent to data processing.
The DSA’s disclosure framework provided the template for TTPA requirements, though political advertising received additional scrutiny due to its democratic significance. The regulations demonstrate regulatory evolution, where foundational transparency principles adapt to specific sector needs.
Differences between DSA and TTPA
Despite shared principles, these regulations diverge significantly in scope and implementation. The differences highlight the specialised approach to political advertising regulation.
Comparing DSA with TTPA transparency and targeting restrictions reveals distinct characteristics:
| Aspect | DSA | TTPA |
| Application scope | All advertising on online platforms | Political advertising across online and offline channels |
| Disclosure depth | Basic advertiser and funding information, and targeting criteria | Detailed sponsor and funding information, links to additional resources and notification mechanisms, and targeting methodologies |
| Targeting restrictions | Prohibits targeting minors, and targeting based on special categories of personal data | Prohibits targeting individuals known to be under voting age, targeting based on special categories of personal data, as well as any targeting that hasn’t received specific consent |
| Repository requirements | Mandatory submission to a platform-specific repository (only for VLOPs and VLOSEs) | Mandatory submission to centralised European repository |
| Retention periods | One-year record keeping in machine-readable format (only for VLOPs and VLOSEs) | Seven-year record keeping in machine-readable format |
| Consent frameworks | General consent requirements | Explicit consent specifically for political advertising targeting techniques |
| Processing timeframes | Standard notice and action provisions (processing of notices “in a timely manner”) | Standard notice and action provisions (processing of notices “without undue delay”), reduced to 48-hour processing in the last month preceding an election or referendum |
The specialised requirements reflect heightened regulatory attention to political communications, recognising their fundamental role in democratic processes and the need for additional safeguards.
How the Digital Services Act impacts Political Advertising
The DSA establishes foundational transparency standards that enable specialised political advertising regulation through frameworks like the TTPA. This creates integrated regulatory oversight rather than isolated compliance requirements.
The enforcement relationship proves particularly significant. TTPA non-compliance can render content “illegal” under DSA frameworks. Online platforms may need to implement DSA notice and action procedures when receiving TTPA non-compliance reports, creating interconnected enforcement mechanisms.
Harmonised EU advertising rules generate legal certainty for businesses operating across multiple Member States whilst creating predictable environments for consumers. This regulatory consistency enables effective compliance planning and reduces operational complexity.
Draft guidance clarifies that intermediary services under DSA scope only face TTPA publisher obligations when political messages are provided against remuneration. Organic political content remains protected whilst paid promotion triggers additional scrutiny, with the additional caveat that content considered liable and designed to influence a political outcome will also fall under scope of the TTPA
The regulatory relationship demonstrates the EU’s systematic approach to digital governance. Rather than creating separate regulatory frameworks, foundational requirements enable sector-specific regulations to function effectively whilst maintaining coherent oversight.
This approach presents both challenges and opportunities. Compliance teams navigate multiple regulatory requirements simultaneously, but businesses mastering this complexity can offer clients regulatory certainty in an evolving environment.
Political advertising now operates within transparent, accountable digital frameworks that protect democratic processes whilst preserving fundamental expression rights. Implementation success depends on how effectively businesses adapt to these requirements when they become operative.
