In December 2025, the European Commission published a draft plan for the European repository for political advertisements, as required by the TTPA. The Civil Liberties Union for Europe (Liberties) fully supports the establishment of such a repository and stresses that it is urgently needed. However, we found that some parts of the Commission’s new draft do not fully support the TTPA’s democratic goals. That is why Liberties, offering a civil society viewpoint, urges the Commission to incorporate our feedback in its final strategy.

Why is the TTPA important?

Transparency in political advertising is essential for democracy. Online political content has come to play a major role in shaping public opinion in the EU, so it is necessary to clearly identify paid political ads to allow people to see who is trying to influence them (and how). The EU’s new TTPA regulation on the transparency and targeting of political advertisements aims to ensure this by requiring platforms to introduce specific new measures, for example, to show how much a sponsor is spending on a given political campaign.

Why is the European repository necessary?

One main part of the TTPA is the creation of a central repository for political advertisements in Europe. Once set up, this would require platforms to share information about every political advertisement they display, such as the content of the ad, who is supported by it, who paid for it, when it was published, and what language it was displayed in. This will help users hold platforms and advertisers accountable for the information they are fed, give researchers data to study online campaigns and show how paid content shapes opinions.

What needs to be improved?

After reviewing the Commission’s proposal, Liberties has three main points to raise:

1. It needs to be clearly stated that platforms cannot escape responsibility, accountability and transparency by formally banning political ads. Recently, Google and Meta have technically banned political ads on their platforms – a policy they pursue incoherently in practice. Typically, both platforms are slow to remove political ads when these are published “under the radar” – allowing them to reach users despite formal bans.

How the EU interprets the TTPA is therefore very important. Liberties calls on the Commission to strengthen the rules for big online platforms, so they cannot use formal bans on political ads to avoid responsibility for what takes place on their platforms. These companies must still identify paid political content as such and share it in the European repository.

We ask the Commission to ensure that platforms:

• Identify political advertisements without much delay
• Collect all necessary information about paid political content if it managed to slip through
• Share this information in the European repository

Additionally, we ask the Commission to rethink how political influencers are regulated under the TTPA. Currently, platforms do not need to ensure that paid influencers’ posts are sent to the repository, and influencers have no responsibility themselves to do so. As influencers play an increasingly central role in shaping voters’ opinions, paying them to participate in a campaign should not be done under the radar.

2. The draft plan is not precise enough - which could cause indefinite delays.

The plan demands that, before the launch of the new repository, platform providers must get sufficient time to adapt to the new rules. However, it does not define what is considered sufficient time, which risks delaying the launch far into the future. This can have many negative consequences for European democracy, as the repository is urgently needed to help journalists and activists hold politicians accountable. We ask the Commission to decide on a specific timeframe for the repository’s launch immediately.

3. The “multistakeholder” expert group set up by the Commission only includes platform company representatives. In the draft plan, it says that the establishment of a European repository for political ads requires the involvement of a wide range of experts - an idea we fully support. However, in practice, the expert body created by the European Commission for this task consists only of representatives of platform providers. The lack of other voices in this group is obvious and concerning. Therefore, we ask for the inclusion of other perspectives in the expert group setting up the European repository - these should entail the insights of researchers, consumers and civil society organisations too.

In short, we call for more transparency, accountability, clarity and inclusivity. The TTPA is a legislation for the European people – the Commission’s final strategy should reflect this.

Where to read more?

For a more detailed analysis of the Commission’s new strategy, please look at our public consultation feedback here.

For our earlier papers on political advertising regulation, please consult our repository here.

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