Digital Services Act

The Digital Services Act (DSA) is an EU regulation that sets harmonised rules for digital services across Europe, including obligations for online platforms to moderate illegal content, be transparent about advertising, and protect users' fundamental rights. For political advertising, the DSA works alongside TTPA to ensure platforms provide transparency tools and handle illegal content related to political campaigns.

Legal Basis

"This Regulation lays down harmonised rules on the provision of intermediary services in the internal market. Its purpose is to contribute to the proper functioning of the internal market for intermediary services by setting out uniform rules for a safe, predictable and trusted online environment, where fundamental rights enshrined in the Charter are effectively protected."

— Article 1, Regulation (EU) 2022/2065 (Digital Services Act)

Why It Matters

The DSA creates the regulatory framework within which political advertising operates online. For platforms, political parties, and advertisers, understanding the DSA is essential because it establishes baseline obligations for content moderation, transparency reporting, and advertising disclosures that apply to all online services—including political advertising.

The regulation introduces different tiers of obligations based on platform size. Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs) face additional requirements to assess and mitigate systemic risks to electoral processes, making the DSA particularly relevant during election periods when political advertising intensifies.

For publishers and providers of political advertising services, the DSA's transparency requirements for online advertising complement TTPA's specific political advertising rules. Together, these regulations ensure that voters can identify political ads, understand who paid for them, and report violations through accessible channels.

Key Points

Applies to all intermediary services: Hosting services, online platforms, and search engines operating in the EU must comply with DSA obligations regardless of where they are established.
Tiered obligations: Different rules apply to different service providers, with the strictest requirements for Very Large Online Platforms (45 million+ monthly users in the EU) and Very Large Online Search Engines.
Electoral process protection: VLOPs and VLOSEs must identify and mitigate systemic risks to elections, including disinformation, manipulation, and inauthentic behaviour during campaigns.
Advertising transparency: All online platforms must ensure users can identify advertisements, know who paid for them, and access meaningful information about targeting (Articles 26 and 39).
Illegal content mechanisms: Platforms must provide notice-and-action mechanisms for users to report illegal content, including illegal political advertising or hate speech in campaigns.
Coordinated supervision: Digital Services Coordinators in each Member State enforce the DSA, with the European Commission directly supervising VLOPs and VLOSEs.

Digital Services Act vs. Transparency and Targeting of Political Advertising Regulation

While both regulations address online advertising transparency, they serve different purposes and apply to different scopes. The DSA is a horizontal regulation covering all digital services and content types, establishing general obligations for platforms to moderate content, provide transparency, and protect fundamental rights across all their operations.

TTPA (Regulation 2024/900), by contrast, is a vertical regulation focused exclusively on political advertising. It sets specific transparency requirements for political ads (including offline ads), restricts targeting techniques using personal data, and limits sponsorship by third-country entities during election periods.

The DSA provides the infrastructure—notice-and-action mechanisms, ad transparency tools, reporting obligations—while TTPA sets the specific rules for what political advertising must disclose and how it can be targeted. Compliance with both is required: a platform must meet DSA's general advertising transparency obligations (Article 26) and TTPA's specific political advertising transparency requirements (Chapter II).

Related Terms

Very Large Online Platform (VLOP)
Very Large Online Search Engine (VLOSE)
Political Advertising
Provider of Political Advertising Services
Publisher
Transparency Notice
Digital Services Coordinator
Targeting Techniques
Online Platform
Intermediary Services

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.