Policies and procedures

Clear policies and procedures are the foundation of compliance with the TTPA Regulation. They are the documented rules and step-by-step processes that providers of political advertising services create to ensure they meet transparency, due diligence, and targeting obligations under EU law. These internal documents guide how organisations handle political ads, verify sponsor information, label content, keep records, and respond to potential breaches.

Legal Basis

While the TTPA Regulation does not explicitly define "policies and procedures," it requires providers to implement specific processes and systems. For example:

"Providers of political advertising services shall ensure that political advertising published by them is clearly distinguishable from other content."

— Article 8(1), Regulation 2024/900

"Sponsors of political advertising shall provide the information referred to in paragraph 1 to the providers of political advertising services that they use. Providers of political advertising services shall ensure that such information is accurate."

— Article 9, Regulation 2024/900

These obligations necessitate documented policies and repeatable procedures to achieve compliance.

Why It Matters

Policies and procedures affect every actor in the political advertising chain: platforms, publishers, advertising agencies, sponsors, and even influencers. Without clear internal rules, organisations cannot consistently meet TTPA obligations such as labelling ads, collecting sponsor information, maintaining transparency notices, or establishing reporting channels for suspected breaches.

For providers of political advertising services, documented policies reduce legal risk and operational confusion. They ensure that staff know how to identify a political advertisement, what information to collect from sponsors, how to verify that information, and how long to retain records. Procedures also define escalation paths when something goes wrong—such as when a label is missing or sponsor data appears incomplete or inaccurate.

Competent authorities expect to see evidence of effective policies and procedures during audits or investigations. Clear documentation demonstrates that an organisation takes its obligations seriously and has systems in place to prevent, detect, and correct compliance failures.

Key Points

Internal rulebook: Policies set out what the organisation will do to comply with TTPA obligations; procedures describe how to do it step by step.
Covers the full cycle: Should address identification of political ads, collection and verification of sponsor information, labelling, transparency notices, record-keeping, and handling breach reports.
Training and accountability: Policies and procedures must be communicated to relevant staff and updated regularly as the law, technology, or business model changes.
Audit trail: Well-documented policies and procedures provide evidence of due diligence and good faith efforts to comply, which can be important in enforcement proceedings.
Cross-border consistency: For organisations operating in multiple Member States, harmonised policies help ensure uniform compliance with the fully harmonised TTPA Regulation.
Living documents: Should be reviewed and updated at least annually or whenever there is a significant change in law, platform features, or risk profile.

Policies and procedures vs. Terms and conditions

Policies and procedures are internal documents that guide how an organisation operates and complies with the law. Terms and conditions are external, contractual documents that govern the relationship between the service provider and its users (including sponsors and viewers). While terms and conditions may reflect compliance obligations (for example, by prohibiting unlabelled political ads or requiring sponsors to provide accurate information), they are not a substitute for internal policies and procedures. Both are necessary: policies and procedures ensure the organisation can deliver on its promises, while terms and conditions set expectations and provide a legal basis for enforcement against users who violate the rules.

Related Terms

Political advertising
Provider of political advertising services
Sponsor
Publisher
Transparency notice
Due diligence
Labelling
Record-keeping
Reporting channels
Competent authority

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.