Saturs
Regulation (EU) 2024/900 has applied since 10 October 2025 (Article 30(2)). A year on, the same misreadings keep coming up, and the Commission's own answer many of them. They run both ways. Some organisations think the rules do not reach them when they do, others apply them where they never reach. Here are the most common, each checked against the text.
PolAds calls the person behind an advertisement the advertiser, whom the Regulation calls the .
Myth or fact?
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“Only political parties and candidates have to worry about these rules.”
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Who, where and when
“Only parties have to worry about this”
A message by, for or on behalf of a political actor is political advertising unless it is purely private or purely commercial. But so is any other message that is ‘liable and designed to influence the outcome of an election or referendum, voting behaviour or a legislative or regulatory process’, whoever is behind it (Article 3(2)(b)). The Regulation applies to commercial advertising of that kind too (Recital 25), and the Commission names civil society organisations, think tanks and commercial companies among possible sponsors (Guidelines, section 1.1).
That includes advocacy. Some civil society statements have read campaigns and petitions as falling outside the rules, but the Commission's examples count a campaign started in response to a specific amendment, and an association's campaign for new legislation, as political advertising (Guidelines, section 2.2.6, examples 40 and 42).
“It is only about online ads”
Reg. 2024/900 Art. 2(1)
This Regulation applies to political advertising where the political advertisement is disseminated in the Union, is brought into the public domain in one or several Member States or is directed to Union citizens, irrespective of the place of establishment of the provider of political advertising services or of the place of residence or establishment of the sponsor, and irrespective of the means used.
Newspapers, television, radio, posters, leaflets and billboards are covered as much as websites and apps (Guidelines, section 1.3). Offline is often most of the money. In two Irish by-elections in 2026, 99.7% of the €225,000 spent on posters and ads went on non-digital campaigns (The Irish Times).
Only two parts are online only: the (Article 13(4)) and the rules on targeting with personal data (Article 1(1), point (b)). And being established outside the EU changes nothing, because what counts is where the advertisement is disseminated or whom it is directed to.
“It only matters around elections”
The definition covers legislative and regulatory processes as well as elections and referendums, at every level (Article 3(2)(b)), and a message by, for or on behalf of a political actor does not need to be designed to influence a vote at all (Guidelines, section 2.2.4). So the rules apply all year round.
What changes near a vote is the pace. In the last three months before an election or referendum, services for advertising linked to it may only go to a sponsor that declares itself an EU citizen, a resident with a vote in it, or an EU-established entity not ultimately owned or controlled from outside the Union (Article 5(2)). In the last month, publishers handle reports about advertisements linked to that vote within 48 hours (Article 15(7)).
Who
Not only parties
A company, an NGO, a think tank or a trade association can be the sponsor of political advertising.Art. 3(2)(b), Recital 25
How
Paid, in kind or in-house
A message counts when it is normally paid for, in money or in kind, or made through in-house activities.Art. 3(2)
Where
Online and offline
Whatever the means: print, radio, television, posters, websites and apps.Art. 2(1), 3(2)
When
All year round
Not only before an election. A message on a law or a regulation counts too, and some rules tighten as an election gets close.Art. 3(2)(b), 5(2), 15(7)
What the platforms' bans mean
“The platforms stopped, so it no longer concerns us”
Meta stopped political, electoral and social issue ads on its platforms in the EU from early October 2025 (Meta), and Google stopped political advertising in the EU from September 2025 (Google). That removes two channels, not the rules. A is any provider that publishes political advertising ‘through any medium’ (Article 3(13)), from broadcasters and newspapers to billboards, blogs and influencers (Guidelines, section 1.2).
The bans also leak. Researchers counted 457 political ads from Hungarian political actors' pages on Meta in January and February 2026 (Euronews).
“If a platform refuses it, the law forbids it”
The opposite reading is as common. The Regulation does not ban political advertising. It lays down rules on transparency, on targeting and on enforcement (Article 1(1)). A platform's social issue category is its own policy and far wider than the legal definition. The Commission's examples put a public health prevention campaign, a charity's fundraising for cancer research and an NGO's campaign against online scams outside political advertising altogether (Guidelines, section 2.2.6, examples 44, 46 and 47).
Your own posts, both ways
“Every post we publish needs a label”
The label and the transparency notice are duties of a publisher providing a service (Articles 11(1) and 12(1)). When your organisation publishes a message itself, through its own staff and channels, no one provides that service. The message can still be political advertising, made through (Article 3(2)), but the Commission's examples 26 to 29 each end with no label and no notice needed, even where an agency was paid to prepare the message (Guidelines, section 2.2.2).
It does not switch everything off. Targeting the post with personal data brings in the targeting rules, and a paid agency keeps its own duties as a provider (Guidelines, section 2.2.2).
“Paying someone to post it keeps it organic”
The opposite mistake is to call content organic when someone was paid to publish it. An influencer paid by a third party is no longer just a user of a platform (Recital 47) but a political advertising publisher, who labels the post (Guidelines, section 2.2.2) and provides a transparency notice (section 3.3.6). A boosted post is political advertising the platform publishes (section 1.2.1.1, example 4). And payment includes benefits in kind (Guidelines, section 1.2.1).
The same political message, published two ways:
You post it yourself
On your own website, account or newsletter, with no one paid to publish or boost it
No label and no notice
- It can still be political advertising, made through in-house activities.
- The label and notice duties bind a publisher providing a service, and there is none hereGuidelines 1.3, 2.2.2
- Targeting it online with personal data still brings in the targeting rules.
You pay someone to publish it
A newspaper, a broadcaster, a platform’s boost or an influencer, paid in money or in kind
Label and transparency notice
- The publisher shows a label with each advertisement and makes a transparency notice availableArt. 11(1), 12(1)
- You, as sponsor, give the publisher the information for themArt. 7(3)
Messages the rules leave out
“Opinions and journalism count too”
Reg. 2024/900 Art. 1(3)
Political opinions that are expressed in a personal capacity shall not be considered to be political advertising.
Editorial content, such as a news report or an opinion column, is not political advertising either, unless someone pays for it (Article 1(2)). Nor are official information on how to take part in a vote, official information from public authorities that is not designed to influence, and the free presentation of candidates that the law provides for (Article 3(2), points (i) to (iii)). A message also does not become political advertising after the fact because it goes viral (Guidelines, section 2.3).
The exclusions have limits. An opinion stops being personal when a third party pays for it (Recital 30), and an opinion that a political advertising service later promotes can be considered political advertising (Recital 29).
“Every brand campaign about a cause is political”
Commercial advertising can be political advertising when it meets the definition, but in the Commission's words it ‘should not be automatically confused with political advertising’ (Guidelines, section 2.3). A brand campaign on equality or sustainability in principle mirrors the brand's identity and values, and one about donating part of the proceeds to a cause is likely purely commercial (examples 48 and 49). The line is crossed when it takes a side in a live process, such as a transport company promoting what its customers would save if highway rules under debate in parliament were changed (example 50).
“Any online political ad needs consent”
The conditions in Article 18(1), personal data collected from the person and their explicit consent among them, apply to targeting and ad-delivery techniques ‘that involve the processing of personal data’. Placing an advertisement on a website because of what the site is about, and showing it to every visitor alike, is not that, as Sweden's data protection authority explains in its guidance of 16 March 2026 (in Swedish). Where you do target with personal data, the conditions are strict, and people known to be at least one year under the voting age are off limits (Article 18(2)).
The label and the notice
“One page about our political ads is enough”
Each political advertisement carries its own label, with the or a clear indication of where to find it (Article 11(1)). A link or QR code in the label must lead directly to the notice (Impl. Reg. 2025/1410, Annex I, section 1, point 6), so a general page about your campaigns does not do that job. The label also stays in place when the advertisement is shared further (Article 11(3)).
That does not mean every repeat needs a notice of its own. The Commission accepts one notice for the same advertisement published several times or through different media, and one notice for a whole campaign where the information in it would not differ (Guidelines, section 3.3.1, examples 52 and 53).
“We can just edit the notice”
The notice must be ‘kept up-to-date during the entire period of publication of the political advertisement’ (Article 12(3)), and when your information changes or turns out to be wrong you pass the correction to the publisher (Article 7(3)). But the change does not erase what was there. Publishers keep their notices ‘together with any modifications thereto’ for seven years after the advertisement last ran (Article 12(4)). On PolAds that change is an amendment, and every earlier version stays on record, as amending a live notice explains.
“The publisher answers for everything on the notice”
The responsibility is split. You, as sponsor, provide and ensure the accuracy of the information Article 7(3) lists, such as who you are, any entity that ultimately controls you, who pays, the dates and where the money comes from. The publisher answers for the amounts and how they were worked out, the repository link, the complaint mechanism, the reach and the completeness of the notice (Article 12(2)). Providers need not verify what you declare unless it looks manifestly erroneous (Guidelines, section 3.2.4.3), which puts the weight on getting it right when you file. Sanctions can reach sponsors as well as providers (Article 25(1)).
“Nobody is checking”
Anyone, a person or an organisation, can tell a publisher that one of its political advertisements breaks the rules (Article 15(1)), and address the notifications they receive and pass on those that belong to another Member State (Article 24). Member States set the sanctions, and the Regulation caps financial penalties at 6% of the annual income, budget or worldwide turnover of the sponsor or provider (Article 25(2)). Breaches of the core duties in the last month before an election, aimed at voters in that country, count as particularly serious (Article 25(5)).
Where PolAds fits
- The registration form asks for each part of the transparency notice and shows you which step fills which part, see a first campaign end to end.
- Every notice gets its own label, with a QR code that leads straight to it, and a change is an amendment that keeps the history.
- Every public notice links to a complaint form, so a report reaches the publisher.
Not sure your message is covered? Try the ad check, or read do I need a transparency notice?
Sources
- Meta, ending political, electoral and social issue advertising in the EU, updated 6 October 2025
- Google Ads, political content policy update for the EU, 5 August 2025
- Euronews, 8 April 2026
- The Irish Times, 20 May 2026
- IMY, guidance on targeted political advertising online, 16 March 2026, in Swedish
- Reg. (EU) 2024/900, Article 1(1) to 1(3)
- Reg. (EU) 2024/900, Article 2(1)
- Reg. (EU) 2024/900, Article 3(2) and 3(13)
- Reg. (EU) 2024/900, Article 5(2)
- Reg. (EU) 2024/900, Article 7(3)
- Reg. (EU) 2024/900, Article 11(1) and 11(3)
- Reg. (EU) 2024/900, Article 12(1) to 12(4)
- Reg. (EU) 2024/900, Article 13(4)
- Reg. (EU) 2024/900, Article 15(1) and 15(7)
- Reg. (EU) 2024/900, Article 18(1) and 18(2)
- Reg. (EU) 2024/900, Articles 24 and 25
- Reg. (EU) 2024/900, Article 30(2)
- Reg. (EU) 2024/900, Recitals 25, 29, 30 and 47
- Impl. Reg. (EU) 2025/1410, Annex I, section 1, point 6
- Commission Guidelines C/2025/5514, sections 1.1 to 1.3
- Commission Guidelines C/2025/5514, sections 2.2.2 to 2.3
- Commission Guidelines C/2025/5514, section 3.2.4.3
- Commission Guidelines C/2025/5514, section 3.3.1
- Commission Guidelines C/2025/5514, section 3.3.6
Šajā ierakstā skaidrots, kā PolAds interpretē regulu. Tā nav juridiska konsultācija.
