Ancillary Services
Ancillary services are supporting activities that help produce or deliver political advertising but do not involve making decisions about how, where, or to whom the ads are shown. Examples include printing posters, designing graphics, providing web hosting, or transporting campaign materials. These services are generally not covered by the transparency and targeting obligations of Regulation 2024/900.
Legal Basis
The EU Regulation on the transparency and targeting of political advertising does not explicitly define "ancillary services" in a single article. However, Recital 17 clarifies which services fall outside the scope:
"Services which do not involve making decisions concerning the preparation, placement, promotion, publication or dissemination of a political advertisement should not be considered to be political advertising services...Such services could include, for example, the printing of flyers, the production of video or audio materials, the mere transport or distribution of materials, web-hosting services, cybersecurity services, or the provision of payment services."
— Recital 17, Regulation (EU) 2024/900
Why It Matters
Understanding what counts as an ancillary service is crucial for determining who must comply with TTPA obligations. Printers, graphic designers, logistics companies, and IT infrastructure providers typically do not need to label ads, publish transparency notices, or follow targeting restrictions—as long as they only provide technical or logistical support.
However, the line can be blurry. A service is ancillary only if it truly does not influence how, where, or to whom the political ad reaches the audience. If a company goes beyond pure support—for example, by analyzing voter data to optimize ad placement or recommending targeting strategies—it may cross into the role of a provider of political advertising services and become subject to the regulation.
Businesses offering services to political campaigns should carefully assess whether their role is purely ancillary or involves substantive decisions about advertising strategy, targeting, or dissemination. When in doubt, consulting legal counsel or the relevant national supervisory authority is advisable.
Key Points
- Ancillary services support political advertising but do not control placement, targeting, or dissemination decisions
- Examples include: printing, graphic design, web hosting, cybersecurity, transport, payment processing
- Not subject to transparency labelling, transparency notices, or targeting restrictions under Regulation 2024/900
- The boundary matters: Services that influence targeting strategy or ad delivery may fall within scope
- Technology-neutral: The type of service matters, not the medium (applies equally to digital and offline support)
- National enforcement: Member States designate authorities to supervise and clarify scope questions
Ancillary Services vs. Political Advertising Services
The key distinction is control over advertising decisions. Ancillary services provide technical, logistical, or creative support without determining who sees the ad, where it appears, or how it is targeted. In contrast, providers of political advertising services (such as ad platforms, agencies, or influencers paid to disseminate political content) actively place, promote, publish, or deliver ads and must comply with TTPA transparency and targeting rules.
| Aspect | Ancillary Services | Political Advertising Services |
|---|---|---|
| Role | Technical/logistical support | Placement, publication, targeting decisions |
| Examples | Printers, web hosts, designers | Platforms, ad agencies, influencers |
| TTPA obligations | Generally not applicable | Transparency and targeting rules apply |
| Control over reach | No influence on audience | Direct influence on who sees the ad |
A company providing voter data analytics to optimize ad delivery is not ancillary—it is a provider of political advertising services.