Designing a Paid Digital Campaign Under EU Transparency Rules
How to plan, build, and publish paid digital political advertising that meets the requirements of Regulation (EU) 2024/900 — from targeting decisions to the transparency label.
Sofia Marchetti leads digital strategy at Agenzia Europea Comunicazioni, a Rome-based consultancy specialising in EU institutional communications, political campaigns, and advocacy. She has managed digital programmes for EP election campaigns in Italy and coordinated pan-European digital content strategies for advocacy coalitions. She is a regular trainer on EU compliance for digital campaign teams.
Disclosure
Sofia Marchetti is employed by Agenzia Europea Comunicazioni. The agency has worked with a range of political and civil society clients; client relationships are disclosed where relevant to article content. She has no personal financial interest in any platform or technology referenced in her articles.
Peer reviewed
Elena Christodoulou
Legal Counsel, Political and Regulatory Affairs, Christodoulou & Partners
Reviewed May 2026
What it covers
How to structure a paid digital campaign from planning through targeting, creative, publishing, and archiving — at every stage accounting for the requirements of Regulation (EU) 2024/900.
Who it is for
Digital campaign managers, paid media buyers, and compliance leads responsible for political advertising in EU member states.
When to use it
Before starting any paid digital political advertising campaign directed at EU audiences. Also relevant when reviewing existing campaigns for compliance.
Key takeaway
Compliance with Regulation (EU) 2024/900 is not a post-production step — it must be designed into the campaign from the targeting brief through the creative specification to the publication workflow.
In brief
- Targeting based on special category personal data, including inferred political opinion, is prohibited by the regulation.
- Every ad must carry a transparency label with specific information about sponsor, funder, and targeting parameters.
- The transparency label must be visible without the viewer taking additional steps — embedded small print does not comply.
- A campaign repository must be maintained for the duration of the campaign and for a period after it ends.
- Publishers — including digital platforms — bear joint compliance obligations with advertisers.
Framework
The compliant paid digital campaign workflow
A six-stage framework for planning and executing paid digital political advertising under EU transparency and targeting rules.
| Layer | Label | Description |
|---|---|---|
| Stage 1: Targeting brief | Define lawful parameters | Confirm targeting criteria exclude special category data and comply with GDPR lawful basis |
| Stage 2: Creative specification | Build in the label | Specify transparency label contents in the brief before creative production begins |
| Stage 3: Platform authorisation | Verify eligibility | Complete platform political advertiser verification before buying begins |
| Stage 4: Publishing | Label and deploy | Publish with transparency label visible; confirm platform archive requirements are met |
| Stage 5: Monitoring | Track compliance | Monitor label display, targeting performance, and spend reporting in real time |
| Stage 6: Archiving | Document and retain | Maintain campaign records for the regulatory retention period |
Targeting decisions: what is permitted and what is prohibited
Regulation (EU) 2024/900 creates the most significant restrictions on political ad targeting in the EU's regulatory history. The regulation prohibits the use of special category personal data under GDPR Article 9 — including political opinions, religious beliefs, racial or ethnic origin, health data, and sexual orientation — for the purpose of targeting political advertising. Critically, the prohibition extends to data inferred from these categories, not only to explicitly collected special category data.
The practical implication of the prohibition on inferred data is far-reaching. Platform targeting systems that use behavioural signals to infer political interest — for example, targeting users who have engaged with politically related content — may involve inferred political opinion data, depending on how the inference is constructed. Campaign teams should not assume that platform-native targeting tools automatically comply with the regulation. Where there is uncertainty about whether a targeting parameter involves inferred special category data, the conservative compliance position is to avoid it.
What is permitted under the regulation is contextual and interest-based targeting that does not involve inference of special category characteristics. Geographic targeting, age-based targeting, and targeting based on stated interests that are not proxies for special category characteristics are permissible, subject to the documentation and disclosure requirements. The targeting brief is the moment at which compliance must be confirmed — not after the campaign is live.
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