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The funding step raises more questions than any other part of the registration form. Who counts as a payer, what is a , and why does the total already contain it? Here are the answers.
PolAds calls the person behind an advertisement the advertiser, whom the Regulation calls the .
What the notice has to say about money
Four points of Article 12(1) concern funding. The first is about who pays.
Reg. 2024/900 Art. 12(1)(b)
the information required under point (a) on the natural or legal person that provides remuneration in exchange for the political advertisement if this person is different from the sponsor or the entity ultimately controlling the sponsor
The other three are about the amounts.
Reg. 2024/900 Art. 12(1)(d)
the aggregated amounts and the aggregated value of other benefits received by the providers of political advertising services, including those received by the publisher in part or full exchange for the political advertising services, and, where relevant, of the political advertising campaign
Point (e) asks for ‘information on public or private origin of the amounts and other benefits referred to in point (d) as well as whether they originate from inside or outside the Union’. Point (f) asks for ‘the methodology used for the calculation of the amounts and value referred to in point (d)’.
Notice how the Regulation frames the figure: it counts what the receive, in money and in other benefits, in exchange for their services.
The sponsor provides and ensures the accuracy of points (b) and (e) (Article 7(3)). The publisher ensures the accuracy of points (d) and (f) before and during publication (Article 12(2)).
Who pays
In the Advertiser step PolAds asks Is the advertiser the paying entity? (or Are you the paying entity? when you file for yourself).
- Yes: you fill in one funding block for the advertiser.
- No: the funding details show a Payers section. Declare every person or organisation that paid, with their identity, contact details and address. Use Add another payer for each further payer.
A payer who is different from the sponsor and from the is identified on the notice, in the section the Implementing Regulation's template calls ‘The entity paying for the political advertisement’ (Article 12(1)(b), Impl. Reg. 2025/1410 Annex II, template point 3).
For each payer, or for the advertiser when it pays, you enter:
- Total amount (excl. VAT) and Currency
- Amount type: Invoiced, Estimated / Budget or Other, with a description for Other
- Funding origin: Public funds and/or Private funds, and From within the EU and/or From outside the EU
- benefits in kind, if there were any
The origin questions answer point (e). Being established in the EU does not by itself mean the money comes from the EU.
Is the advertiser the paying entity?
- Yes
One funding block, for the advertiser
- No
A Payers section, with every payer’s identity, contact details and address. Add another payer for each one
For each payer, or the advertiser when it pays
- Total amount and currencyExcluding VAT
- Amount typeInvoiced, Estimated / Budget or Other
- Funding originPublic and/or private, from within and/or outside the EU
- Benefits in kindIf there were any
- A payer other than the advertiser and the entity controlling it is named on the notice, as the entity paying for the political advertisementArt. 12(1)(b)
- Being established in the EU does not by itself mean the money comes from the EUArt. 12(1)(e)
What a benefit in kind is
The Regulation speaks of ‘other benefits’ received in part or full exchange for the services (Article 12(1)(d)). The explain that consideration for a service includes benefits in kind, such as discounts, travel arrangements, accommodation or access to events or places that would otherwise be paid for (Guidelines C/2025/5514, section 1.2.1).
On PolAds, under Add benefits-in-kind if relevant (optional), click Add an entry for each benefit. Each entry has three fields, and a fourth, Description of Valuation Method, when the method is Other:
- What was contributed: a short description. It is published, so leave out names, email addresses and phone numbers.
- Valuation method: Market value, Cost to provider, Rate-card or list price, Comparable commercial rate, Independent third-party appraisal or Other, with an explanation for Other.
- Value of benefit: in the same currency as the payer's total.
If everything was paid in money, leave the section empty.
Why the total already includes the in-kind value
The 's template asks for one figure for the advertisement: ‘[Total figure and currency.]’ (Annex II, template point 5). Its note says what that figure contains.
Impl. Reg. 2025/1410 Annex II, note 5
The total figure shall include the amounts invoiced, budgeted or charged by the providers of political advertising services, including the publisher, in exchange for the political advertising services they provided for the political advertisement concerned. Where applicable, it shall also include the monetary value of all the benefits in kind received and/or to be received by the providers of political advertising services, including the publisher, in exchange for the political advertising services they provided for the political advertisement concerned.
So the total is money plus the value of benefits in kind, in one figure. That is why the Total amount (excl. VAT) you enter counts both: the amounts the providers invoiced, budgeted or charged, and the value of the benefits in kind they received or will receive. Your in-kind entries are a breakdown of it, not an addition to it. The sum of the entries can never exceed the total. The form stops you before you submit, and PolAds checks it again on the server.
A worked example. A payer pays a publisher €7,500 and also gives it exhibition space at a conference, worth €2,500 at the list price, in exchange for the same advertisement.
- Enter a Total amount (excl. VAT) of 10,000.
- Add one in-kind entry with a Value of benefit of 2,500 and the valuation method Rate-card or list price.
The notice then shows a total of €10,000 and, beneath it, an in-kind value of €2,500 with the description and the method. The usual mistake is to type only the cash, 7,500, as the total and then add 2,500 in kind. The form reads that as 5,000 in money and 2,500 in kind, and the notice under-declares the total.
Total amount (excl. VAT) to enter10,000 EUR
7,500 EUR in money and 2,500 EUR in kind, in one figure
The in-kind entries are a breakdown of the total, not an addition to it, and their sum can never exceed it
The usual mistakeTotal 7,500 EUR
7,500 EUR typed as the total, 2,500 EUR added in kind
The form reads 5,000 EUR in money and 2,500 EUR in kind, and the notice under-declares the total by 2,500 EUR
How the figure is explained
The methodology note of the template asks the notice to clarify whether the total reflects invoiced, budgeted or charged amounts, whether it includes VAT, and, for benefits in kind, the valuation method used (Annex II, note 8). On PolAds the field label says the amount excludes VAT, the Amount type records the basis of the figure, and each in-kind entry carries its own valuation method. The notice also has a calculation methodology section of its own (Annex II, template point 8).
Several payers, several currencies
Each payer has its own currency, and PolAds never converts between currencies. A notice with payers in more than one currency shows a total per currency, and its methodology section says that no conversion was made.
The campaign total
Article 12(1)(d) asks for the amounts ‘where relevant, of the political advertising campaign’ as well, and the template has a separate point for it (Annex II, template point 6). You do not type a campaign budget on PolAds. The campaign total is worked out from the amounts declared for each advertisement, and you confirm it in the Advertisements step.
Next: a first campaign end to end shows the whole registration, and amending a live notice covers an amount that changes after sign-off.
Sources
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