Compliance Program

A compliance program is a structured system of policies, procedures, and controls that organizations put in place to ensure they follow applicable laws and regulations. In the context of political advertising, it helps sponsors, publishers, and providers of advertising services meet their transparency and targeting obligations under EU Regulation 2024/900.

Legal Basis

While Regulation 2024/900 does not explicitly define "compliance program," it establishes obligations that require organizations to implement systematic compliance measures:

"Providers of political advertising services shall establish and implement internal processes and resources that are appropriate and proportionate to enable them to comply with their obligations under this Regulation."

— Recital 40, Regulation (EU) 2024/900

Why It Matters

Anyone involved in political advertising—from political parties and candidates to online platforms, advertising agencies, and influencers—must understand and fulfill specific legal requirements around transparency and data protection. A compliance program provides the framework to ensure these obligations are consistently met.

Without a structured compliance program, organizations risk penalties, reputational damage, and undermining democratic processes. For platforms and publishers, this means implementing systems to label political ads, provide transparency notices, and maintain accessible reporting channels. For sponsors and advertisers, it means ensuring proper documentation, respecting targeting restrictions, and working only with compliant service providers.

Effective compliance programs are particularly important given the cross-border nature of political advertising and the complexity of coordinating requirements from the TTPA Regulation, GDPR, national electoral laws, and sector-specific rules. They help organizations move from reactive problem-solving to proactive risk management.

Key Points

Systematic approach: A compliance program organizes all policies, procedures, training, and monitoring activities needed to meet TTPA obligations consistently
Risk-based design: Programs should be scaled to the organization's size, role in political advertising, and the complexity of campaigns they handle
Core elements: Typically includes staff training, internal controls, record-keeping systems, reporting channels, regular audits, and clear accountability
Continuous improvement: Programs must adapt to new regulations, evolving campaign techniques, and lessons learned from audits or enforcement actions
Documentation requirement: Organizations must be able to demonstrate their compliance efforts to supervisory authorities
Cross-functional coordination: Effective programs involve legal, technical, marketing, and data protection teams working together

Compliance Program vs. Code of Conduct

A compliance program is an internal management system that ensures an organization meets its legal obligations, while a code of conduct is a set of ethical principles and behavioral standards that guide organizational culture and decision-making.

Compliance programs are legally mandated and focus on specific regulatory requirements (transparency notices, data protection, record-keeping). Codes of conduct are often voluntary and address broader values like integrity, fairness, and respect for democratic processes.

However, they work together: a strong code of conduct shapes the culture that supports compliance, while the compliance program provides the structure and accountability to enforce both legal requirements and ethical commitments.

Related Terms

Political advertising
Provider of political advertising services
Sponsor
Publisher
Transparency notice
Targeting techniques
Due diligence
Record-keeping obligations
Competent authority
Data protection compliance

Very transparent. Every political ad will be labelled, linked to a transparency notice with detailed information, and online ads will be searchable in a central European repository.

The Network coordinates election-related cooperation between member states. National contact points for TTPA enforcement should be members of this network where possible.

Election campaigns will need to ensure all paid advertising includes proper labels and transparency notices. Sponsors must be prepared to provide required information to all service providers.

Several major platforms currently do not allow paid political advertising, including some large social networks. This limits where political actors can place paid online advertisements.

The TTPA applies from 10 October 2025. Member States had until 10 April 2025 to designate competent authorities, and the Commission must provide label templates by 10 July 2025.

Publishers must ensure completeness and accuracy of certain information but are not required to verify all sponsor claims. They must correct manifestly erroneous information when they become aware of it.

Yes. When a hosting provider and a website both display an ad, both are considered publishers with responsibility for their specific services. Contracts should clarify how they share compliance duties.

If a publisher removes or disables access to a political ad due to illegality or terms violations, they must still provide access to the transparency information for the full seven-year retention period.