How to take a “gold standard” approach to political advertising transparency and policy

As our lives go more and more online, we must all acknowledge the key global role the internet (and more specifically, social media) plays in the conduct of politics. 

To date, too little constructive action has taken place to reform the rules of democracy to account for this. Instead, interested parties hold their cards close and eye each other suspiciously across the table. In behaving that way, we are missing an opportunity. Democracy isn’t a card game. There should be no bluffing and no losers.

With the US election nearly done, it’s time to open up and move forward. The PR battle is (almost) over and the scrutiny will become less intense (though the elections never stop). As the spotlight moves on, the next phase of work should start. 

We acknowledge that Facebook has come further, faster than any of its competitors when it comes to political ad transparency. The Facebook Ad Library is a useful, if imperfect tool, and the company deserves more credit than Google (the digital political ad market has only two substantial players) for their transparency work. We are in a much better position on political ads than we were at any time in the last 4 years.

But we’re nowhere near the end. To date, in the absence of government regulations, private companies have been able to set and mark their own homework. Primarily, we want transparency to scrutinise political ads. But enormous, globe-spanning platforms also need to be comfortable with the idea that they can face – and benefit from – constructive scrutiny too. The internet is no longer a novelty in politics, but we still need new ways to understand what it means for democratic societies. 

To take this work forward, we set out an agenda for the future of political ad transparency. 

We’re clear about what we’re looking for when it comes to political ads. We think everyone else working in this space would benefit from making their positions clear too, and engaging in the political debate of finding satisfactory answers. We ask that the ideas we set out aren’t ignored, instead being honestly explored in the spirit of cooperatively arriving at a solution that benefits democratic accountability for all. 

To be clear: Who Targets Me stands ready to participate in and to help coordinate the conversations needed to move forward. 

What a “gold standard” for political advertising transparency looks like:

1. Increasing ad library data quality for accountability and research

Publish all political ads in their entirety.

Publish the spending associated with each ad.

Publish impressions, reach and demographic data (where possible).

Publish targeting information so the methods being used by campaigns are transparent. This includes labelling ads as to whether they are using one or more of:

  • Custom/uploaded audiences:
    • Uploaded lists, including the name of the list
    • Lists generated from website/mobile/app use
    • Data broker lists, including the name of the broker
  • Lookalike/modelled audiences:
    • Plus underlying custom audience
  • The general category of targeting:
    • Behavioural
    • Demographic
    • Interest-based
  • Specific language targeting.

Publish any behavioural, demographic or interest-based exclusions used to refine ad targeting.

Publish the placements (where the ads are to appear) selected by the ad buyer and ultimately delivered by the platform.

Publish broad, non-personal engagement data (comments, likes, shares, reactions), so it’s possible to study potential additional non-paid reach and potential polarising effects of specific content.

Improve the granularity of published data, particularly for larger spends and impressions figures. Make the ‘bands’ consistent in size.

Publish the optimisation method (e.g. for engagement, clicks, purchases) chosen by the buyer.

Periodically release data about ads that are not approved or taken down, along with the rule(s) broken.

Publish the rationale behind all non-approvals.

Provide API availability/status notifications.

Provide a feature log and release notes for the API and Ad Library/data publishing.

2. Auditing tools and processes

Regularly audit your platform’s ad delivery algorithm for unequal distribution effects to show, of 1,000 representative users, how many will:

  • See ad an ad with this targeting and a $100 budget.
  • The frequency with which they will see it
  • The frequency with which they will engage with it 

Provide detailed descriptions of ad approval processes and allow annual independent audits/verification.

Require annual re-verification of political advertisers.

Require advertisers to include and publish the details of relevant registrations with regulators (company registration or tax number, data protection registration, electoral commission registration)

Create a marketplace/area for 3rd party tools and research projects built using the political ad API data outlined above.

Create a public literacy program for digital political ads, offered to each user an election campaign.

Provide users with a summary of the political ads they have seen in the last 6 months. Allow them to download/share these lists in a privacy compliant way. 

Increase the granularity of what constitutes a “political advertiser” by allowing advertisers to self designate according to narrower categories – candidate, party, campaign, non-party campaign, NGO etc – and to mark when they’re standing for election (e.g. 2020 cycle).

Proactively seek out lists of candidates and parties from countries holding elections, funding research/civil society partners to do this if necessary. 

Provide geographical targeting/delivery data at the equivalent of the federal district level (congressional district, UK parliamentary constituency or similar).

Permanently label political ads using a distinct, unique label.

3. Election management

Participate in regular meetings with academia, journalists, regulators and civil society to discuss emerging and outstanding issues.

Nominate a local expert group before each election to provide a legitimate basis for work on:

  • Identifying what is “political” in the local context
  • Flagging risks to democracy or the voting process that might be promoted through ads
  • Propose local refinements to political ad rules
  • Ongoing monitoring

Publish a list of meetings with political campaigners where campaigning activity is discussed.

Standardise and publish the list of advice provided to political campaigners on use of platforms, support arrangements, processes, advice, consultancy and so on.

4. Ad Library standards

Work with other stakeholders to develop a universal ad library, fed by API data from many advertisers and platforms.

Contribute to discussions about an open technical standard for political advertiser and advert data.

Allow trusted advertising companies to submit data to ad libraries, based on a common standard. 

Open source relevant ad library code for use by researchers and other, smaller platforms and advertisers, for whom building an ad library is unfeasible.

5. Engagement with alternative regulatory proposals

Enter into open engagement with proposals via sandbox/Chatham House discussions on topics such as:

  • Mandating universal ad transparency
  • Reducing the number of ads available to advertisers
  • Removing social features from political ads
  • Offering flat rate pricing for political ads
  • Clarifying the nature and scope of fact checking programmes for political ads
  • Agreeing which companies should enforce political ad transparency rules
  • How to handle anonymity for campaigners in repressive/dangerous environments
  • Discussing ideas for achieving ‘balance’
  • Whether platform specific-rules deserve consideration under the law

6. Active monitoring of new practices

Regularly share challenges and trade-offs to do with managing:

  • Risks associated with new products and product ideas.
  • Innovations in digital marketing such as influencers, in-game and streaming advertising.
  • Changes to national legislation, legal precedent and so on.


We understand not all of our proposals will be possible. They may not even be entirely desirable, once all of the trade-offs have been discussed and balanced. The interests and wishes of civil society will always be different to those of private companies, academic researchers, journalists, governments, people running for office, regulators and other stakeholders. There are complexities and difficult practicalities at every turn.