Regional and local elections
Regional and local elections are elections held at the sub-national level within EU Member States, including elections for regional parliaments, city councils, mayors, and other local authorities. These elections determine representation and governance for specific geographic areas smaller than an entire Member State, and are subject to national and regional electoral laws as well as EU transparency requirements when political advertising is involved.
Legal Basis
While Regulation 2024/900 does not explicitly define regional and local elections, it applies to political advertising directed at individuals in Member States in the context of any election or referendum, including those at regional and local levels.
"This Regulation applies to the preparation, placement, promotion, publication and dissemination of political advertising, and the provision of related services, where such advertising is directed at individuals in one or more Member States, irrespective of where the preparation, placement, promotion, publication or dissemination takes place."
— Recital 16, Regulation (EU) 2024/900
The Commission's guidelines on the Digital Services Act further clarify that mitigation measures for electoral processes should extend to regional and local elections when risk assessments identify actual or foreseeable negative effects on these electoral processes.
Why It Matters
Regional and local elections are critical components of democratic participation across the EU, often seeing higher citizen engagement with issues directly affecting daily life such as public transport, education, healthcare, and housing. Political advertising plays a significant role in these campaigns, and the same transparency obligations under the TTPA apply regardless of the electoral level.
For sponsors, publishers, and providers of political advertising services, this means that campaigns for mayoral elections, city council seats, regional parliament elections, and similar contests must comply with labeling, transparency notice, and targeting restrictions just as strictly as national or European Parliament elections. The obligations apply across all 27 Member States, even though the specific electoral systems, timing, and governance levels vary significantly between countries.
Platforms and publishers should establish processes to identify when advertising relates to regional or local elections in any Member State where they operate, particularly since these elections may occur throughout the year with less international visibility than national campaigns. The three-month restriction on sponsorship by third-country entities or nationals applies equally to regional and local elections as to national ones.
Key Points
- Regional and local elections include any sub-national electoral processes such as regional parliaments, city councils, municipal elections, and mayoral contests
- All TTPA transparency obligations apply equally to regional and local elections as they do to national and European Parliament elections
- Publishers and platforms must identify and properly label political advertising for regional and local elections in all Member States where they operate
- The three-month pre-election restriction on third-country sponsorship applies to regional and local elections from the date the election is announced or scheduled
- Electoral calendars vary widely: some Member States hold regional and local elections on coordinated dates while others have rolling schedules throughout the year
- Risk assessments under the Digital Services Act should consider actual or foreseeable negative effects on regional and local electoral processes, not only national elections
Regional and local elections vs. National elections
While both are subject to identical TTPA transparency obligations, regional and local elections differ from national elections primarily in their geographic scope and the level of government being elected. National elections determine representation in a Member State's national parliament or executive, while regional and local elections determine governance for specific sub-national territories.
From a compliance perspective, the key operational difference is monitoring: providers of political advertising services must track electoral calendars across hundreds of regional and local jurisdictions throughout the EU, rather than just 27 national schedules. This requires robust systems to identify when advertising relates to an upcoming regional or local election in any Member State.
The substantive transparency requirements—labeling, transparency notices, record-keeping, and targeting restrictions—remain identical regardless of electoral level. A Facebook ad for a mayoral candidate in Lyon faces the same compliance obligations as an ad for a French presidential candidate.
Related Terms
- Political advertising
- Election or referendum
- National elections
- Elections to the European Parliament
- Political actor
- Sponsor
- Provider of political advertising services
- Publisher
- Transparency notice
- Targeting techniques