Information Transmission

Information transmission is the act of moving or conveying information across a communication network or from one point to another. In the context of the TTPA Regulation, it refers to the technical process by which online platforms and intermediary services enable data, content, or communications—including political advertising—to reach users without necessarily exercising control over the content itself.

Legal Basis

The concept of information transmission is fundamental to the liability exemptions for intermediary services under EU law, which are preserved in the Digital Services Act:

"An intermediary service that consists of the transmission in a communication network of information provided by a recipient of the service, or the provision of access to a communication network."

— Article 3, Regulation (EU) 2022/2065 (Digital Services Act)

While the TTPA Regulation (EU 2024/900) does not explicitly define "information transmission," it builds on the established framework of intermediary service liability, which distinguishes between the mere technical act of transmitting content and the act of publishing or disseminating content with editorial or commercial decisions involved.

Why It Matters

Understanding information transmission is crucial for determining when a platform or service provider is considered a "provider of political advertising services" under the TTPA Regulation. Not all technical transmission of political content triggers transparency and targeting obligations—only those services that actively place, publish, deliver, or disseminate political advertising upon request and for remuneration.

For businesses and platforms, this distinction affects whether they must comply with TTPA labelling, transparency notices, and record-keeping obligations. Services that merely provide the technical infrastructure for data transmission (such as hosting providers, cloud services, or internet service providers) are generally not considered providers of political advertising services, even if political advertisements pass through their systems.

For voters and citizens, recognizing the role of information transmission helps clarify which actors in the online advertising ecosystem are responsible for ensuring transparency. It underscores that accountability for political advertising lies with those who make decisions about placement and dissemination, not with every technical intermediary in the chain.

Key Points

Information transmission refers to the technical act of conveying data or content across networks without necessarily controlling or deciding on that content.
Mere technical transmission does not automatically make a service provider a "provider of political advertising services" under the TTPA Regulation.
Intermediary services that only transmit information generally benefit from liability exemptions, provided they do not initiate the transmission, select recipients, or modify content.
Ancillary services such as web hosting, cloud computing, or network infrastructure are typically excluded from TTPA obligations when they serve only as underlying infrastructure.
Active dissemination or publishing—where a platform decides to show, promote, or deliver content to the public—goes beyond mere transmission and may trigger TTPA obligations.
The distinction between transmission and dissemination is essential for determining compliance responsibilities under both the TTPA Regulation and the Digital Services Act.

Information Transmission vs. Dissemination to the Public

Information transmission is the technical process of moving data across networks, while dissemination to the public involves making content available to a potentially unlimited audience, often with editorial or algorithmic decisions. A cloud hosting provider may transmit data for a political party's website, but the party itself disseminates the content by publishing it online.

Under the TTPA Regulation, only services that disseminate or publish political advertising—not those that merely transmit it—are typically considered providers of political advertising services and subject to transparency obligations. This distinction protects purely technical intermediaries from regulatory obligations while ensuring accountability for those who actively place or promote political content.

Related Terms

Provider of Political Advertising Services
Publisher
Dissemination to the Public
Intermediary Service
Ancillary Services
Hosting Service
Political Advertising
Sponsor
Online Platform
Internal Activity

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.