Expert Feedback on the Draft Commission Guidance for Regulation (EU) 2024/900 on the Transparency and Targeting of Political Advertising

his expert submission provides detailed feedback to the European Commission on the draft guidance for Regulation (EU) 2024/900 on the transparency and targeting of political advertising. It argues that the current guidance does not fully capture the complexity of contemporary political influence ecosystems, particularly the role of intermediaries, influencers, data brokers, and very large online platforms in shaping political messaging. The submission calls for clearer criteria on issue-based advocacy, hybrid and AI-generated content, cross-border campaigns, and promoted organic content, alongside stronger due diligence, record-keeping, and transparency standards. It also emphasises the need for coordinated EU-level enforcement, open ad transparency tools, and practical compliance supports for smaller actors. Overall, the submission frames effective implementation as essential to safeguarding electoral integrity, democratic accountability, and trust in political communication in an increasingly platform-driven media environment.