Since 10 October 2025, EU-wide rules have required political advertisements to identify their sponsors and disclose key information about their funding and targeting. The first step for organisations is deciding whether a communication qualifies as political advertising.
The EU Regulation on the transparency and targeting of political advertising has applied in full since 10 October 2025. It covers online and offline advertisements at EU, national and local level. Political ads must be clearly labelled, with information including who paid for them, how much they cost and, where targeting or ad-delivery techniques are used, which audience was selected. The European Commission’s overview sets out the main requirements.
The regulation does not prohibit political advertising or control what an advertisement may say. It establishes transparency and due-diligence requirements for sponsors, advertising-service providers and publishers. Organisations commissioning or placing campaigns should establish their responsibilities before an advertisement is prepared, promoted or published.
When does a communication count as political advertising?
The definition covers messages prepared, placed, promoted, published, delivered or disseminated, normally for payment, through an organisation’s own activities or as part of a political advertising campaign. It includes messages made by, for or on behalf of a political actor, unless they are purely private or commercial. It also covers other messages that are liable and designed to influence an election or referendum, voting behaviour, or a legislative or regulatory process.
This second part means that a message can qualify even if the sponsor is not a political party or candidate. But a communication does not become political advertising simply because it discusses a public issue. The Commission’s implementation guidelines say organisations should consider the message’s content, sponsor, wording, context, means of distribution, target audience and objective. There must be a clear and substantial link between the message and its potential to influence a vote or a legislative or regulatory process.
That assessment may be relevant to companies, trade associations, charities and campaign groups promoting or opposing a policy proposal. A paid campaign calling on the public to support a proposed law may be in scope. A company advertisement focused solely on a product or service would not normally qualify, although the circumstances and purpose of the message matter.
Editorial content and personal opinions have specific protections. Political opinions or other editorial content under editorial responsibility are not treated as political advertising unless a third party provides specific payment or other remuneration for, or in connection with, their preparation or distribution. Views expressed in a personal capacity are also outside the rules. Public authorities’ official communications are excluded where they provide information and are not designed to influence an election, voting behaviour or a legislative or regulatory process.
What must an advertisement disclose?
A political advertisement must carry a clear label and a transparency notice. Depending on the circumstances, that notice must identify the sponsor and any entity that ultimately controls it, the election or referendum to which the ad relates, the period it is intended to run, the amount paid and the source of funding. Where audience targeting or ad delivery has been used, the notice must also describe the audience and the techniques involved.
Sponsors should be ready to provide accurate information to the agencies, platforms and publishers handling their campaigns. Those service providers have their own duties, including checks to identify political advertisements and ensure that labels and transparency notices are provided. Responsibilities can therefore extend across the campaign’s supply chain.
Restrictions on online targeting
The regulation adds conditions for online targeting based on personal data. Such data may be used for political advertising only if it was collected directly from the person concerned and that person gave explicit consent specifically for this purpose. Profiling based on special categories of personal data, including data revealing political opinions, is prohibited. Political advertising may not be targeted using personal data of someone known with reasonable certainty to be at least one year below the voting age.
Organisations should review how audience lists were obtained, what consent was given and how targeting decisions are made. They should also confirm that agencies and platforms can provide the information needed for the transparency notice. General data-protection requirements continue to apply alongside the political-advertising rules.
A practical check before publication
Before approving a campaign, organisations should record its sponsor, purpose, audience, content, funding and distribution method. They should assess whether it could influence an election, voting behaviour or a legislative or regulatory process, and document why they consider it to be inside or outside the rules. If it is political advertising, the sponsor and its providers should agree who will supply and verify each part of the required information.
The regulation calls for a case-by-case assessment. A consistent review before publication can help organisations distinguish ordinary communications from political advertising and identify disclosure or targeting requirements in time to meet them.
