The European Commission is preparing guidance for ad repositories that very large platforms and search engines must already provide under the DSA. The consultation concerns ad searches, information about the target audience, and access to content. The draft guidance will be consulted on in Q2 2027, and the final version is planned for Q2 2028.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 the 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 not a new law, nor the launch of a single European archive.
In brief
Authorities, researchers, journalists, civic organizations, providers, the advertising industry, and the general public can contribute by 2 December 2026.
The future guidance will address efficient ad searches, information about their targeting and distribution, and access to advertising content.
The DSA already requires public repositories identifying the person on whose behalf an ad appears and, if different, the person who paid for it. The repositories must allow searches using multiple criteria and access through an API.
The information must be retained for the duration of the ad’s display and for another year after the ad was last shown, with special rules for removed ads. The personal data of users to whom the ad was or could have been displayed 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The Commission plans to consult on draft guidance in Q2 2027 and publish the final version in Q2 2028.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 the call for contributions, the Commission aims to ensure that ad repositories can actually be used to examine campaigns, rather than merely exist as databases. The institution identifies three directions for the future guidance: easily searchable ads, useful information about how users are targeted and reached, and access to ad content. Contributions can be submitted through the initiative’s page on “Have Your Say”.
Participants are asked for examples of good practices and difficulties encountered, information missing from the repositories, and features that would make search tools and APIs more useful. The Commission is also seeking observations on the relationship between the DSA and other sectoral 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, misleading commercial practices, and the promotion of illegal products or services. The consultation seeks experiences and recommendations about how the repositories operate; 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 concerns online platforms and search engines designated as very large that display ads 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 allowing queries using multiple criteria and through application programming interfaces, API. These interfaces enable automated access to data, which is relevant for analyzing multiple ads.
The repositories must include the ad content, the product, service, or brand promoted, and the subject of the message; the natural or legal person on whose behalf the ad is presented; and, if different, the person who paid for it. The display period 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 ad was intended for certain categories of users and the main parameters used to include or, where applicable, exclude them. The total number of users reached and, where applicable, aggregate 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 ad 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, these elements alone do not establish the existence of fraud or the legality of an ad; that requires fact-checking and, where appropriate, investigations by the authorities.
Transparency does not entail publishing the identities of people who saw an ad. The DSA prohibits including in the repository the personal data of users to whom the ad 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 the information throughout the display period and for one year after the ad 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 ads removed or blocked because they are allegedly illegal or incompatible with the service’s terms. In these cases, the repository no longer includes the ad content or the identity of the person on whose behalf it was presented or of the payer, but it must provide the information required by the regulation about the measure taken and its reasons. The exception does not permit any trace of the ad to simply disappear from the repository.
The archiving obligation complements other DSA rules. Article 26 requires the identification of ads and information 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 the special categories of personal data protected by the GDPR. Separately, Article 28 prohibits ads 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, organization, and functionalities of the repositories, based on the possibility provided for in Article 39(3), after consulting 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 ads and related transparency information, including sponsors, funding, and expenditure. Participation in the pilot is voluntary, and the Commission stated that the official launch date would be announced separately.
DSA repositories are administered by very large services and concern ads 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 organize 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 the preparation of guidance, not a postponement of the current transparency obligations.
Latest News
21:23
21:08
20:52
20:43
20:42
See more news