In-house activities

In-house activities refer to political advertising or campaigning conducted directly by political actors using their own channels, staff, and resources, without paying a third party to place, promote, or disseminate the content. When political actors publish content on their own social media accounts, websites, or through their own email lists without commercial promotion, these are typically considered in-house activities.

Legal Basis

The concept of in-house activities is addressed in the context of Regulation 2024/900, particularly in determining when transparency obligations apply to publishers and providers of political advertising services. While the regulation does not explicitly define "in-house activities" as a standalone term, it distinguishes between activities where political actors pay third parties for services and activities conducted through their own means.

"Political advertising services' means services that consist in the preparation, placement, promotion, publication or dissemination of a political advertisement, in return for remuneration or equivalent consideration, including a benefit in kind."

— Article 2(3), Regulation 2024/900

Why It Matters

Understanding in-house activities is crucial for determining which obligations under the political advertising regulation apply and to whom. When a political party posts campaign content on its own social media page without paying for promotion or boosting, the platform hosting that content may not be considered a "publisher" of political advertising for that specific post, as no service is being provided for remuneration.

This distinction affects compliance responsibilities. In-house activities still involve political advertising, and targeting rules under Chapter III of the regulation apply if personal data is used for online targeting or ad delivery. However, publisher transparency obligations may not apply to platforms in these scenarios, since they are merely hosting content rather than being paid to place or promote it.

The practical impact is significant for political actors, platforms, and regulators. Political parties can communicate directly with supporters through owned channels with fewer intermediary obligations, while platforms must assess whether they are providing a paid service or simply hosting unpaid user content. This affects labeling requirements, transparency notices, and record-keeping obligations.

Key Points

In-house activities involve political actors using their own channels and resources without paying third parties for placement or promotion
Transparency obligations for publishers may not apply to platforms hosting unpaid political content posted directly by political actors
Targeting rules still apply when personal data is used for online targeting, even in in-house activities
The key distinction is whether remuneration or equivalent consideration is exchanged for advertising services
Political actors remain responsible for compliance with targeting restrictions and data protection law in their in-house campaigns
Platforms must distinguish between hosting unpaid user content and providing paid advertising services to apply obligations correctly

In-house activities vs. Paid political advertising services

The fundamental difference lies in whether a third party receives payment or other consideration for placing, promoting, or disseminating political content. In-house activities are conducted directly by political actors through their own means, while paid political advertising services involve engaging external providers.

For example, when a candidate posts campaign messages on their verified social media account without paying for promotion, this is in-house activity. If that same candidate pays the platform to boost the post or promote it to a wider audience, the platform becomes a provider and publisher of political advertising services, triggering full transparency obligations.

This distinction affects which entities bear compliance obligations. In paid arrangements, both sponsors and providers/publishers have duties. In in-house activities, the political actor bears responsibility for any applicable obligations (such as targeting restrictions), but the platform hosting the content may not be subject to publisher-specific transparency requirements for that particular content.

Related Terms

Political advertising
Sponsor
Provider of political advertising services
Publisher
Remuneration
Targeting techniques
Political actor
Transparency obligations
Ad delivery techniques
Commercial promotion

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.