When the European Union first proposed a standalone Regulation on the Transparency and Targeting of Political Advertising (TTPA), expectations were high. Emerging in the wake of the Cambridge Analytica scandal and part of the European Democracy Action Plan (EDAP), the initiative was meant to demonstrate the EU’s commitment to protecting democracy in the digital age and addressing specific risks to electoral integrity.
It was also meant to go further than both data protection rules contained in the General Data Protection Regulation (GDPR) and transparency rules in the Digital Services Act (DSA). Civil society organisations hoped it would mark a turning point, introducing strong safeguards on targeting and data use. Yet from the start, the proposal attracted criticism from all sides: too restrictive to be workable, too vague to be effective, and ultimately watered down into a compromise quickly concluded before the end of the legislative term.
As the Regulation enters into application on 10 October 2025, its prospects appear shaky. While a thorough consultation process has been conducted in the months leading up to its full application, it has been marked by a heavy presence of industry voices and limited participation from civil society and researchers. And yet it was the industry itself that eventually stepped out of the market to avoid compliance with the new rules, considered as not workable.
Mind the regulatory gaps
Much of the Regulation’s detail has been deferred to implementing acts and non-binding guidance documents. While the guidance offers welcome clarifications — notably on deadlines, the definition of political advertising, and the exclusion of private individuals’ opinions and media editorial content —, it was only published two days before the entry into application, and key areas such as the treatment of influencers and in-house advertising services remain under-defined, risking over-compliance by civil society or inconsistent enforcement.
The most serious blow to the Regulation’s relevance, however, comes from the reaction of the digital advertising industry itself. Major platforms such as Google and Meta have opted to withdraw from providing political advertising services in the EU, effectively leaving the Regulation without a meaningful field of application. If no one is offering regulated services, the new rules risk becoming largely symbolic, with little real-world impact in the best-case scenario and negative impact in the worst.
In fact, this withdrawal threatens to shrink the space for political speech online. Faced with legal uncertainty and the risk that content could be classified as political advertising under the Regulation’s broad definitions, platforms may increasingly choose to remove such content altogether. Combined with existing practices like the shadow-banning of political content, this could quickly turn online political debate into a thing of the past.
Yet political campaigning itself will not disappear; it will simply move elsewhere. Instead of transparent, regulated advertising, political campaigns are likely to become more opaque and harder to monitor, shifting offline or taking subtler forms through influencers, bots, or new, less visible tactics. In this scenario, the Regulation risks achieving the opposite of its original goal: reducing transparency instead of enhancing it.
Finally, the Regulation also foresees a review two years after the European elections. It remains unclear whether this timeline refers to 2026, given that the Regulation was already in force but not yet fully applicable before the 2024 elections. If so, that review should be seen as an opportunity to address the shortcomings highlighted above, rather than as a pretext to “simplify” the rules by rolling back the existing digital rights acquis.
Serious times call for serious measures
If the EU wants this Regulation to be taken seriously, it must first demonstrate that it takes it seriously itself, by addressing the main concerns highlighted above. For this reason, the European Commission should re-engage with diverse stakeholders, including civil society, academia, and election experts, to shape future revisions and ensure alignment with the EU’s broader obligations under the DSA to mitigate systemic risks to democratic processes.
The review of the Regulation could also be an opportunity to take a more encompassing approach which addresses not only transparency but also the underlying targeting and profiling practices that distort democratic discourse; and safeguard legitimate civic activities by ensuring that advocacy, fundraising, and issue-based campaigning by civil society organisations remain outside the Regulation’s scope when they do not pose risks to electoral integrity.
Online platforms on the other hand should re-examine the possibility of serving political advertising in the EU, especially ads that are not based on tracking and profiling, in a manner that is more conducive to civic discourse and electoral processes; and increase transparency around content distribution systems, particularly how engagement-based ranking affects the visibility of political and civic content and whether it systematically privileges polarising voices.
The EU’s Political Advertising Regulation was conceived as a flagship response to threats facing democratic discourse online. Yet without stronger enforcement, deeper reforms, and sustained political will, it risks fading into irrelevance, a missed opportunity to meaningfully reshape the digital political sphere, in the very moment where this is needed more than ever. As challenges around elections and political speech mount across Europe, the question is no longer whether such regulation is needed, but whether the EU will have the courage to take it seriously.
