The European Commission is preparing guidance for advertising repositories that very large platforms and search engines are already required to provide under the DSA. The consultation covers searching for advertisements, information about the target audience and access to content. The draft guidance will be consulted on in Q2 2027, with the final version planned for Q2 2028.
The European Commission is seeking contributions by 2 December to improve public repositories of online advertisements: how easily ads can be found, what can be learned about their target audience and how their content can be accessed. The initiative, launched on 4 November, is preparing technical guidance for very large platforms and search engines. The obligation to provide these repositories already exists under the Digital Services Act, DSA; this is neither a new law nor the launch of a single European archive.
In brief
Authorities, researchers, journalists, civic organisations, providers, the advertising industry and the general public can contribute by 2 December 2026.
The future guidance will address efficient searches for advertisements, information about their targeting and distribution, and access to advertising content.
The DSA already requires public repositories to identify the person on whose behalf an advertisement appears and, if different, the person who paid for it. The repositories must allow searches using multiple criteria and provide access through an API.
Information must be retained for the duration of the advertisement’s display and for another year after its last presentation, with special rules for ads that have been removed. The personal data of users to whom the advertisement was or could have been shown may not be included.
The Commission plans to consult on draft guidance in Q2 2027 and publish the final version in Q2 2028. Existing obligations continue to apply, and the initiative is separate from the European pilot repository for political advertising.
Through its call for contributions, the Commission aims to ensure that advertising repositories can be effectively used to examine campaigns, rather than merely exist as databases. The institution identifies three areas for the future guidance: easily searchable advertisements, useful information about how users are targeted and reached, and access to advertising content. Contributions can be submitted through the initiative’s page on “Have Your Say”.
Participants are asked to provide examples of good practices and difficulties encountered, information missing from repositories, and features that would make search tools and APIs more useful. The Commission is also seeking comments on the relationship between the DSA and other sector-specific advertising rules, supported, where possible, by documents or research.
According to the Commission’s announcement, these tools can help researchers, journalists, civil society and national authorities identify risks such as online fraud, disinformation, deceptive commercial practices and the promotion of illegal products or services. The consultation seeks experiences and recommendations on how repositories work; it does not announce a new finding that a particular platform has breached the rules.
The obligation is laid down in Article 39 of the DSA. It applies to online platforms and search engines designated as very large that display advertisements on their interfaces, known by the abbreviations VLOP and VLOSE. Providers must offer a public repository, in a section of the service, through a reliable search tool that allows queries using multiple criteria and through application programming interfaces, or APIs. These interfaces enable automated access to data, which is relevant for analysing multiple advertisements.
The repositories must include the content of the advertisement, the product, service or brand promoted and the subject of the message, the natural or legal person on whose behalf the advertisement is presented and, if different, the person who paid for it. The period during which it was displayed must also be indicated. Identifying these actors must not be confused with the mandatory publication, under this article, of the amount spent on each campaign.
Audience data has a separate role: the repository must show whether the advertisement was intended for particular categories of users and the main parameters used to include or, where applicable, exclude them. The total number of users reached and, where applicable, aggregated figures by Member State for the targeted groups are required. The article also covers commercial communications published on very large platforms and identified through the mechanism by which users declare such content.
For an investigation, the difference lies between seeing an isolated advertisement and being able to track multiple messages associated with the same payer, the same period or targeting criteria. Information about the message, payer and distribution can help identify links between campaigns. However, this information alone does not establish the existence of fraud or the legality of an advertisement; these require fact-checking and, where appropriate, investigations by the authorities.
Transparency does not entail publishing the identities of people who saw an advertisement. The DSA prohibits including in the repository the personal data of users to whom the advertisement was or could have been presented. Aggregated audience information and targeting parameters must therefore be distinguished from a named list of recipients.
The repositories must retain information throughout the period of display and for one year after the advertisement was last presented on the service concerned. This allows campaigns to be examined retrospectively. Providers are also required to make reasonable efforts to ensure that the information is accurate and complete.
There is a special rule for advertisements removed or blocked because they are allegedly illegal or incompatible with the service’s terms. In these cases, the repository no longer includes the advertisement’s content or the identity of the person on whose behalf it was presented or the payer, but it must provide the information required by the regulation about the measure taken and the reasons for it. The exception does not allow every trace of the advertisement to simply disappear from the repository.
The archiving obligation complements other DSA rules. Article 26 requires advertisements to be identified and information to be provided about the person on whose behalf they are presented, the payer and the main display parameters, available when the user sees the message. It also prohibits advertising based on profiling that uses special categories of personal data protected by the GDPR. Separately, Article 28 prohibits advertising based on profiling that uses the personal data of a user whom the platform knows, with a reasonable degree of certainty, to be a minor.
These provisions are not being introduced by the November consultation. The Commission is preparing guidance on the structure, organisation and functionalities of the repositories, based on the possibility provided for in Article 39(3), following consultation with the European Board for Digital Services, relevant vetted researchers and the public. The guidance is intended to support the supervision and enforcement of existing obligations without itself amending the text of the DSA.
The initiative differs from the European repository for political advertising, launched as a pilot on 12 October under another regulation. That is a central mechanism for political advertisements and related transparency information, including sponsors, funding and expenditure. Participation in the pilot is voluntary, and the Commission said that the official launch date would be announced separately.
DSA repositories are administered by very large services and concern advertisements on their own interfaces, not only political messages. The current consultation does not yet create a central repository and does not replace the October pilot. The distinction also matters when using the data: the fields, coverage and rules of the two mechanisms are not identical.
After the call for contributions closes on 2 December, the Commission intends to organise a targeted public consultation on draft guidance in the second quarter of 2027. Publication of the final document is planned for the second quarter of 2028. The timetable concerns preparation of the guidance, not a postponement of the current transparency obligations.
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