What a publisher has to do

If you sell space or airtime for political advertising, the Regulation gives you duties of your own. Here they are, followed by what PolAds supports.

Are you a publisher?

Reg. 2024/900 Art. 3(13)
‘political advertising publisher’ means a provider of political advertising service that publishes, delivers or disseminates political advertising through any medium

Newspapers, broadcasters, outdoor screens, websites, platforms and influencers can all qualify (Guidelines C/2025/5514, section 1.2). Publishers are a subset of providers of political advertising services, so they carry the duties of every provider as well as their own (section 1.3). PolAds calls the sponsor the advertiser.

Duties you share with every provider

• Ask for declarations. Ask the sponsor, or the provider acting for it, to declare whether the service is political advertising and whether it meets Article 5(2), and have your contracts require it (Article 7(1) and 7(2)). Ask for a correction of anything manifestly erroneous (Article 7(4)). Otherwise you are not required to verify declarations (Guidelines, section 3.2.4.3).
• Respect the pre-election rule. In the last three months before an election or referendum, political advertising services pertaining to it may only be provided to a sponsor that declares it meets one of the conditions in Article 5(2).
• Keep records. Retain the information listed in Article 9(1) in machine-readable form for seven years (Article 9(3)), unless you are a micro-undertaking for which advertising is purely marginal and ancillary (Article 9(4)).
• Answer authorities. Acknowledge a national competent authority's request within two working days and answer within eight working days, or within 48 hours in the last month before an election or referendum, with lighter terms for smaller undertakings. Designate a contact point (Article 16).
• Answer interested entities. Interested entities may request the information you are required to have under Articles 9, 11 and 12 (Article 17(1)). They must be independent from commercial interests and fall in one or more of five categories: vetted researchers under Article 40(8) of the Digital Services Act (Regulation (EU) 2022/2065), members of a civil society organisation authorised under national or Union law whose statutory objectives are to protect and promote the public interest, political actors, national or international electoral observers recognised in a Member State, and journalists (Article 17(2)). Make best efforts to answer, or send a reasoned refusal, within one month at the latest (Article 17(3)).

Duties that are yours as publisher

Labels

Each political advertisement must be made available with a statement that it is a political advertisement, the sponsor and any controlling entity, the linked election or process, any use of targeting or ad-delivery techniques, and the transparency notice or where to find it (Article 11(1)). You ensure this information is complete and that the pointer to the notice is accurate (Article 11(2)). Labels must be adapted to the medium, prominent, and stay in place if the advertisement is shared further (Article 11(3)). Their format and template are set in Impl. Reg. 2025/1410, Annexes I and II.

Transparency notices

The notice contains the information in Article 12(1). You ensure it is complete, and that the amounts, methodology, repository link, complaint mechanism and reach figures are accurate before and during publication (Article 12(2), points (d), (f), (i), (j) and (m)). If you learn that something is incomplete or inaccurate, you make best efforts to fix it without undue delay, including by contacting the sponsor. If that fails:

Reg. 2024/900 Art. 12(2)
Where the information cannot be completed or corrected without undue delay, the political advertising publisher shall not make the political advertisement available or shall without undue delay discontinue the publication, delivery or dissemination of the political advertisement.

You then tell the sponsor about that decision. The notice must be easy to retrieve throughout publication, kept up to date, machine-readable at least when the advertisement is made available electronically, written in the language of the advertisement and accessible (Article 12(3)). You keep notices, with any modifications, for seven years after the last publication (Article 12(4)), with the same micro-undertaking exception (Article 12(5)).

The European repository

Publishers that publish online make each advertisement and its Article 12(1) information available in the European repository within 72 hours of first publication (Article 13(4)). Very large online platforms and search engines follow Article 13(2). The Guidelines say these obligations become relevant from its deployment (section 3.3.2).

Periodic reporting

Publishers that are not micro, small or medium-sized undertakings report the amounts and other benefits received, aggregated by campaign, in their management report (Article 14).

Complaints

Anyone must be able to tell you, free of charge and from the notice, that an advertisement you published does not comply (Article 15(1) and 15(2)). The mechanism must allow a substantiated explanation, the identification of the advertisement and the reporter's name and email address (Article 15(3)). You confirm receipt without undue delay (Article 15(4)) and make best efforts to examine and address the notification (Article 15(6), or the stricter Article 15(5) for very large platforms and search engines). In the last month before an election or referendum, notifications about an advertisement linked to it are processed within 48 hours, provided the notification can be processed completely on the information it contains, with best efforts for smaller undertakings (Article 15(7)). You give information on redress (Article 15(8)), tell the sponsor about measures that affect the advertisement (Article 15(9)) and may answer several notifications together (Article 15(10)).

Penalties

Member States set the sanctions for infringements of Articles 5 to 17, 20 and 21, and they must be effective, proportionate and dissuasive (Article 25(1)). The maximum financial penalty is based on economic capacity: 6% of annual income or budget, or 6% of annual worldwide turnover in the preceding financial year (Article 25(2)). Infringements of Articles 5, 7, 11, 12, 13, 15, 16 and 18 count as particularly serious in the last month before an election or referendum when aimed at citizens of the Member State concerned (Article 25(5)).

Where PolAds fits

• Sign-off. A notice that names you is not public until you authorise it. In Review & Authorise you confirm or set the dates and complete the Targeting & data declaration for online and outdoor formats. PolAds never authorises a notice automatically, whatever the deadline.
• Correction. Send back for correction returns a notice to the advertiser with your comment, in support of your Article 12(2) duty.
• Labels. On Pro, copy the label text or download the label and its QR code from Transparency Notices. On Basic, the advertiser hands you the label with the advertisement. Displaying it in your medium is still your job.
• Complaints. Every notice links to a complaint form built on Article 15(3), open until three months after its publication period ends. PolAds chose that period, and the Regulation does not set one. PolAds emails the receipt, tells the advertiser when you uphold a complaint and, on Pro, lets you decide complaints about the same advertisement together. Stopping the advertisement happens in your own medium.
• Amendments. You cannot edit a notice. The advertiser files an amendment and you confirm or reject it, under Reviews on Pro or from PolAds' email on Basic.
• Reach. For targeted online advertisements you report views and engagements.
• Retention. PolAds keeps notices and their amendments for at least seven years after each notice's end date.

Sign-off and complaints work on every plan, by email. See pricing for what Pro adds and information for authorities for requests to PolAds itself.

Sources

• Reg. (EU) 2024/900, Article 3(13)
• Reg. (EU) 2024/900, Article 5(2)
• Reg. (EU) 2024/900, Article 7(1), 7(2) and 7(4)
• Reg. (EU) 2024/900, Article 9(1), 9(3) and 9(4)
• Reg. (EU) 2024/900, Article 11(1) to 11(3)
• Reg. (EU) 2024/900, Article 12(1) to 12(5)
• Reg. (EU) 2024/900, Article 13(2) and 13(4)
• Reg. (EU) 2024/900, Article 14
• Reg. (EU) 2024/900, Article 15(1) to 15(10)
• Reg. (EU) 2024/900, Article 16
• Reg. (EU) 2024/900, Article 17
• Reg. (EU) 2024/900, Article 25(1), 25(2) and 25(5)
• Impl. Reg. (EU) 2025/1410, Annex I
• Impl. Reg. (EU) 2025/1410, Annex II
• Commission Guidelines C/2025/5514, section 1.2
• Commission Guidelines C/2025/5514, section 1.3
• Commission Guidelines C/2025/5514, section 3.2.4.3
• Commission Guidelines C/2025/5514, section 3.3.2