The Three Groups With Obligations
Regulation (EU) 2024/900 does not place its obligations on a single actor. Instead, it distributes responsibilities across three distinct groups — each with different duties, different timelines, and different consequences for non-compliance.
Understanding which group you fall into is the first step toward compliance.
Group 1: Advertisers and Sponsors
An advertiser (or "sponsor" in the regulation's terminology) is anyone who commissions, funds, or is ultimately responsible for a political advertisement. This includes:
- Political parties — from national headquarters to local branches
- Candidates — anyone running for public office at any level, from municipal council to the European Parliament
- Elected officials — during their term of office, their advertising remains subject to the regulation
- Campaign organizations — groups formed specifically for a referendum, citizens' initiative, or electoral campaign
- NGOs and advocacy groups — environmental organizations, industry associations, citizens' initiatives, and any other entity whose advertising could influence an election or legislative process
- Individual citizens — even a private person who places a political ad (e.g., a paid social media post supporting a candidate) is a sponsor under the regulation
What sponsors must do
Under Art. 9 PAR, sponsors must create a transparency notice for every political advertisement they commission. This notice must be complete before the ad is published. It must contain information about the sponsor's identity, the payer (if different), the cost and funding source, the election linkage, any targeting methodology used, and a complaint mechanism.
Sponsors are the origin point of transparency. Without their notice, the entire chain breaks down.
Group 2: Publishers
A publisher is anyone who distributes a political advertisement to the public. The regulation uses a broad definition that encompasses both traditional and digital media:
- Newspapers — print and online editions
- Broadcasters — television and radio stations
- Outdoor advertising companies — operators of billboards, bus shelters, digital screens, and poster networks
- Online news sites — any website that publishes editorial content alongside advertising
- Advertising agencies — insofar as they arrange for the placement and distribution of ads
- Printing companies — when they produce and distribute advertising materials like flyers or posters
What publishers must do
Under Art. 11 PAR, publishers have a verification duty. Before publishing any political advertisement, they must verify that a valid transparency notice exists and that it meets the requirements of the regulation.
This is not a passive obligation. Publishers cannot simply assume that the advertiser has taken care of it. They must actively confirm that a notice is in place, and they must refuse to publish the ad if it is not.
Publishers have until October 2026 to fully implement their verification processes, but there is no reason to wait. The earlier you establish a verification workflow, the smoother the transition will be.
Group 3: Online Platforms
Online platforms occupy a special position under the regulation. They are defined as services that allow users to share content with the public — the definition aligns with the Digital Services Act (DSA). This includes:
- Social media platforms — Facebook, Instagram, TikTok, LinkedIn, X (formerly Twitter)
- Video platforms — YouTube, Vimeo, and similar services
- Search engines — Google, Bing, and others that display advertising alongside search results
- Advertising intermediaries — programmatic advertising networks, demand-side platforms, and ad exchanges
What platforms must do
Platforms have obligations that overlap with and extend beyond those of publishers. They must display transparency labels on political ads, maintain ad repositories that are publicly accessible, and ensure that transparency notices are available to users who encounter political advertising on their services.
Very large online platforms (VLOPs) as defined under the DSA have additional obligations, including systemic risk assessments related to the impact of political advertising on electoral processes.
The Critical Definition: What Makes an Ad "Political"?
The question of who must comply ultimately depends on whether an advertisement qualifies as "political" under the regulation. The definition in Art. 2 PAR is deliberately broad. An advertisement is political if:
- It comes from a political actor (party, candidate, elected official, campaign organization), or
- It is liable to influence the outcome of an election, referendum, or legislative process.
The word "or" is critical. Both conditions do not need to be true simultaneously. This has far-reaching consequences:
Any ad placed by a political party is automatically political advertising — even if the content appears non-political. A party's advertisement for a community event, a recruitment drive, or a general branding campaign all fall under the regulation simply because the sponsor is a political actor.
An ad by a non-political entity can also be political advertising if it could influence an election or legislative outcome. An environmental organization running ads that say "demand climate action from your representatives" two weeks before an election is placing political advertising — even though the organization itself is not a political party.
The Grey Areas
Some cases are straightforward: a party placing an election poster is clearly political advertising. Others are less obvious:
- Issue advocacy: An NGO's ad about healthcare reform that does not mention any candidate or party, but runs during an election campaign where healthcare is a key issue. Under the PAR, this likely qualifies as political advertising because it is liable to influence the outcome.
- Corporate lobbying ads: A company running ads in favor of or against a specific piece of legislation. This qualifies because it relates to a legislative process.
- Fundraising appeals: A candidate's fundraising email that includes persuasive messaging about their policy positions. This is political advertising.
When in doubt, the safer approach is to comply. Creating a transparency notice takes minutes and costs nothing. The consequences of non-compliance can be significant.
How The Taurus Helps Each Group
- Sponsors use The Taurus to create, manage, and publish their transparency notices through a guided wizard that ensures completeness.
- Publishers use The Taurus to verify that a valid notice exists before publishing an ad, fulfilling their Art. 11 verification duty.
- Platforms can integrate with The Taurus to access structured notice data for display in their transparency labels and ad repositories.
Regardless of which group you belong to, The Taurus provides the tools to meet your obligations under the regulation.
This article is for informational purposes only and does not constitute legal advice. For specific questions about your compliance obligations, consult a qualified legal professional.