Record-keeping obligations

Record-keeping obligations require providers of political advertising services to maintain detailed records of political advertisements they publish or disseminate. These records must include information about sponsors, targeting methods, costs, and reach, and must be kept for a specified period to enable supervision by authorities. Proper record-keeping is essential for ensuring transparency and accountability in political advertising across the EU.

Legal Basis

"Providers of political advertising publishing services and publishers shall keep the records necessary to prove compliance with this Regulation for a period of five years after the publication or dissemination of a political advertisement."

— Article 12, Regulation 2024/900

Why It Matters

Record-keeping obligations ensure that there is a verifiable trail of all political advertising activities, making it possible for regulatory authorities to supervise compliance with transparency and targeting rules. Without these records, it would be impossible to verify whether political advertisements were properly labelled, whether sponsors were correctly identified, or whether targeting techniques were used lawfully.

These obligations affect all publishers of political advertising, including online platforms, social media services, newspapers, broadcasters, and advertising agencies. They must maintain comprehensive documentation that can be provided to competent authorities upon request during investigations or routine supervision. The records serve as evidence that the provider has fulfilled their obligations under the TTPA Regulation.

For smaller publishers and platforms, implementing systems to capture and store the required information can require investment in administrative infrastructure. However, the standardized EU-wide requirements help create a level playing field and reduce the compliance burden compared to navigating different national rules.

Key Points

Publishers and providers must keep records for five years after publication or dissemination of each political advertisement
Records must include details about the sponsor, costs, reach, targeting methods, and other transparency information
Documentation must be sufficient to prove compliance with all TTPA obligations
Records must be made available to competent national authorities during supervision and enforcement procedures
Failure to maintain adequate records can result in penalties and fines under national implementation laws
Record-keeping systems should be designed to capture all required information automatically where possible

Record-keeping obligations vs. Transparency notices

Record-keeping obligations and transparency notices serve complementary but different purposes in the TTPA framework. Transparency notices are public-facing information that must be displayed to citizens when they view a political advertisement, showing who paid for it and basic targeting information. Record-keeping obligations, by contrast, are internal documentation requirements that providers must maintain for regulatory supervision.

While transparency notices make limited information visible to the public in real-time, record-keeping creates a detailed, comprehensive archive that authorities can audit to verify compliance. Think of transparency notices as the "front end" that citizens see, while record-keeping is the "back end" that regulators use to ensure the system works properly. Both are mandatory, but they serve different audiences and functions.

Related Terms

Political advertising services
Publisher
Provider of political advertising services
Transparency notice
Sponsor
Competent authorities
Supervision and enforcement
Targeting techniques
Ad-delivery techniques
Due diligence obligations

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.