Publisher obligations
Do I need to publish transparency notices?
Regulation (EU) 2024/900 on the transparency of political advertising imposes significant obligations on publishers. But not all organizations are affected equally. This page helps you understand the rules, the exemptions, and whether they apply to you.
What does the regulation require?
Since 10 October 2025, any organization that publishes, delivers, or disseminates political advertising in the EU must comply with Regulation (EU) 2024/900. Non-compliance can result in penalties of up to 6% of annual worldwide turnover.
The regulation covers all forms of political advertising: print, online, broadcast, outdoor, social media. If you place or publish political ads — even occasionally — you are likely a publisher under this regulation.
Publisher obligations at a glance
Art. 11
Labelling
Every political advertisement must carry a clear and prominent label identifying it as political, the sponsor's identity, and the linked election or referendum.
Art. 12(1–3)
Transparency notices
Each political ad must be accompanied by a transparency notice containing the sponsor's identity, amounts paid, the election it relates to, targeting techniques used, and reach data.
Art. 9
Record-keeping (7 years)
All records relating to political advertising services must be retained for 7 years. Micro-undertakings with marginal advertising are exempt from this requirement.
Art. 12(4)
Notice retention (7 years)
Published transparency notices must be retained and kept accessible for 7 years after the last publication date. Micro-undertakings with marginal advertising are exempt from this requirement.
Art. 14
Periodic reporting
Publishers must include information on political advertising amounts and targeting in their annual management reports. All SMEs (micro, small, and medium-sized) are exempt from this requirement.
Art. 15
Complaint mechanisms
Publishers must operate mechanisms for the public to report non-compliant political ads. Micro-undertakings are held to a best-efforts standard rather than strict compliance.
The micro-undertaking exemption
The regulation provides partial relief for micro-undertakings — but only if advertising is not a meaningful part of their business. Two conditions must both be met:
Condition 1: Micro-undertaking status
Under Article 3(1) of Directive 2013/34/EU, your organization qualifies as a micro-undertaking if it does not exceed the limits of at least two of these three criteria on its balance sheet date:
- Balance sheet total: EUR 350,000
- Net turnover: EUR 700,000
- Average number of employees during the financial year: 10
You must stay below the limits on at least two of the three criteria. If you exceed two or more, you do not qualify as a micro-undertaking.
Condition 2: Advertising is purely marginal and ancillary
Being small is not enough. The regulation additionally requires that advertising services — not just political advertising, but all advertising — are purely marginal and ancillary to your main activities. This is a high bar.
The word "purely" is a strong qualifier in EU law. It signals that the threshold is strict: advertising must be truly negligible relative to your main business, not merely a minor revenue stream. If advertising is part of your business model — even a small part — the exemption is unlikely to apply.
What the exemption actually covers
Even if you qualify, the exemption is partial. It only relieves you from:
- 7-year record-keeping (Article 9)
- 7-year transparency notice retention (Article 12(4))
You are still required to label political ads, create and publish transparency notices, transmit information, and handle complaints.
What does "marginal and ancillary" mean in practice?
The regulation does not define a specific revenue threshold or percentage. Instead, it requires a case-by-case assessment of whether advertising services are truly negligible relative to the organization's main activities. Key factors include:
- What share of total revenue comes from advertising services?
- Is advertising listed as a business purpose in your commercial register entry or articles of association?
- Do you have staff, departments, or processes dedicated to selling or managing ad placements?
- Would your organization function essentially the same without the advertising revenue?
- Do you actively solicit advertising clients, or do ads arrive unsolicited and occasionally?
The critical distinction: the question is not whether political advertising specifically is rare, but whether advertising services in general are negligible. A small newspaper that derives 30% of revenue from advertising would struggle to claim the exemption — even if political ads make up only 1% of all ads.
Examples: Who is exempt and who is not?
Full obligations likely apply
Local newspaper selling ad space
A newspaper — print or online — that regularly sells advertising space. Even if political ads are rare, advertising is part of the core business model. The exemption almost certainly does not apply.
Radio or TV station selling airtime
A broadcaster that sells airtime for advertisements. Advertising revenue is a fundamental part of the business, making it very difficult to argue that advertising is purely marginal.
Online platform or social media company
Platforms where advertising is the primary revenue model. Advertising is self-evidently the core business — full obligations apply regardless of company size.
Billboard or outdoor advertising company
Outdoor advertising firms exist to place and display ads. This is the main activity, not a marginal one.
Exemption may apply
Sports club or community association newsletter
A small club that publishes a newsletter or bulletin board and occasionally accepts a paid political ad. The main activity is running the club — advertising is peripheral. If the club is also a micro-undertaking, the exemption likely applies.
Small event venue with occasional political events
A venue that occasionally rents space for political campaign events and displays political signage as part of the rental. The main activity is venue rental, not advertising services.
Parish or community website
A very small community website that occasionally publishes a political notice alongside its main community content. Advertising plays no meaningful role in the organization's activities.
Print shop producing political flyers
A print shop that only prints materials without deciding where or how they are placed may not even qualify as a publisher under Article 3(6). Pure printing is an ancillary service — the regulation may not apply at all.
Ancillary services: Not a publisher at all
There is a separate, broader exclusion in the regulation. Under Article 3(6) and Recital 39, providers of purely ancillary services are not considered providers of political advertising services at all. These are services that complement advertising but have no direct influence on its content, preparation, placement, or dissemination.
Examples of ancillary services:
- Transportation and logistics
- Printing and reproduction services
- Graphic, sound, or photographic design
- Catering for campaign events
- Computer and IT services
- Cleaning and maintenance
- Postal and courier services
If you exclusively provide these kinds of services without any control over where and how the ads are placed, you are outside the scope of the regulation entirely — no obligations apply.
Disclaimer: This page provides general information about Regulation (EU) 2024/900 and is not legal advice. The assessment tool gives a preliminary indication based on simplified criteria. Whether the micro-undertaking exemption applies to your specific situation depends on the particular circumstances of your case. We recommend consulting qualified legal counsel for a definitive assessment. The regulation's application may also be influenced by national transposition measures in your Member State.
The Taurus provides the infrastructure to manage transparency notices, compliance links, and complaint handling.