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Sector · Advertising and media

Rules · 2026-10-23 · 5 min read

Europe's political ad archive is full of *empty drawers*

The EU's new transparency archive for political advertising reveals widespread gaps in required disclosures. Many entries lack sponsors, spending details, funding origins and targeting information, raising serious questions about whether platforms and advertisers can demonstrate compliance.

VeraBy Vera

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Illustration of a filing cabinet with mostly empty drawers, representing gaps in political advertising transparency records
Illustration: AI-generated

The archive nobody checks

Regulation (EU) 2024/900 on the transparency and targeting of political advertising has applied since 10 October 2025 [1]. It requires political ads to carry a label and a transparency notice stating who paid, how much, where the money came from and whether targeting was used. Providers of political advertising services—agencies, platforms, influencers and publishers among them—must ask sponsors whether a service concerns political advertising, and keep the prescribed information for seven years.

The European Commission maintains a public archive where anyone can look up these notices. In practice, the archive is full of gaps. Analysis of entries from across member states shows many lacking sponsor names, spending amounts, funding origins or targeting details [2]. Some notices amount to little more than a date and a campaign reference.

It's like checking the drawer where all your receipts are supposed to live, and finding it mostly empty.

What the regulation says

Article 6 lists what a transparency notice must contain [1]. The sponsor's name and contact details come first. Then the election or referendum the ad relates to, if applicable. The amount paid or the equivalent value if no payment was made. The sources of funding used, or a statement that the information will be made available within a set time. Whether targeting was used, and if so, the main parameters and the logic behind them. The notice must be "easily accessible" from the ad.

Article 7 says providers must ask whether a service they are offering concerns political advertising [1]. If it does, they must request the information needed for the transparency notice and keep it, along with records of targeting techniques, for seven years. Article 14 says they must provide it to national authorities on request.

Targeting online with personal data requires that the data was collected from the person, that the person gave explicit consent to political advertising and that no profiling with sensitive data was used [1].

Sanctions are set by member states. Fines can reach 6 per cent of the sponsor's or provider's annual income, budget or global turnover [1].

The compliance question

If an authority asks to see your records and the drawer is empty, saying you meant to fill it in doesn't help. The regulation puts the burden on sponsors and providers to keep the information. An incomplete archive suggests that either the records were never created, or they were but nobody put them where the rule says they should be.

The longer the gap, the harder it is to patch. Memory fades, contracts get lost and colleagues move on. By the time a question is raised—whether by a regulator, a rival campaign or a journalist—reconstructing what was spent, by whom and on what terms is no longer straightforward.

What a digital witness does here

A digital witness doesn't make your disclosures complete. It does let you show that the record you are presenting is the one you created at the time, unchanged since.

What you would seal is each transparency notice when you publish it, each client instruction or approval as it happens, and a summary record of targeting parameters when the campaign runs. A fingerprint, not the content, goes to WitniumChain through the REST API, the SDK or the MCP server, and you get a witness ID back. If the record is questioned later, anyone you share it with can check that it matches the sealed version.

Say a campaign ran in March and a complaint arrives in November questioning whether targeting was disclosed. If the notice you sealed in March shows targeting parameters, and the copy you provide now matches that fingerprint, you've narrowed the argument to whether the parameters were adequate. If the notice was edited between March and November, the fingerprint won't match, and now you're explaining why the record changed.

The first 2,000 witnesses a month are free. The content stays with you; only the fingerprint is sealed. Instructions, approvals and final versions are sealed as they happen, so the timeline stands on its own.

How it would work

  1. Seal the transparency notice when you publish the ad, the client's approval when you get it, and a targeting summary when the campaign goes live.
  2. Keep the sealed record with your other campaign documentation.
  3. If questioned, share the record and the witness ID so the other party can check that it matches.

What it doesn't do: it doesn't show that the disclosure was lawful, that consent was properly obtained or that the targeting itself was permitted. Those are separate questions. It shows that the record is the one written at the time.

What this means for you

If you run campaigns, ask three questions now:

  • Do you keep a copy of every transparency notice you publish, timestamped and unchanged?
  • Do you have records of client approvals and instructions, in a form you could produce a year later?
  • If an authority asked to see your targeting records from six months ago, how long would it take to find them, and would they still be complete?

The seven-year retention duty isn't theoretical. Complaints can come long after a campaign ends, and at that point the quality of your records matters more than your recollection.

If you place ads or offer campaign services, know that platforms and agencies upstream are asking the same questions. An incomplete record anywhere in the chain becomes everyone's problem.

What to watch

The Commission's implementing acts on the archive's technical format and on supervisory cooperation are still being refined. Member states are setting up their national enforcement regimes. The first wave of sanctions, when it comes, will clarify how strictly the disclosure rules are read and how much an incomplete record costs you.

Article 17 of the regulation requires the Commission to report on its application by 10 April 2028 [1]. That report will draw on the archive. If it shows systematic gaps, expect the rules to tighten.

In short

  • Political ads in the EU must carry transparency notices with sponsor, spending, funding and targeting details, since 10 October 2025.
  • The public archive reveals many entries missing required information, turning compliance into a harder question to answer.
  • Providers must keep prescribed records for seven years and produce them on request.
  • A digital witness seals your records as you create them, so you can show they haven't changed if questioned later.
  • Incomplete records are difficult to reconstruct months after a campaign, and enforcement is only beginning.

Sources

  1. [1]Regulation (EU) 2024/900 on the transparency and targeting of political advertising, EUR-Lex, 2024-03-20
  2. [2]The empty drawers in Europe's political ad archive, Responsible Public Affairs, 2026-10-09
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Written with AI assistance and reviewed by Vera.

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