EU DSA · Ad transparency

The Four Layers of Ad Transparency

Read the latest biannual DSA reports from every platform and they converge on one pattern: in the report, an “ad” is just a thing the platform moderates. None of them describe who advertised, to whom, why, or where you can look an ad up. The report is the thinnest slice of ad transparency — and mostly about taking ads down.

You can download Layer 4. To actually see the ads you need Layer 2; to know the rules, Layer 3; and every ad already carries Layer 1. The report is the bottom rung.

What the reports actually say about ads

Across all 16 unique reports analysed, ads show up only as a content-moderation subcategory (“we action ads against our Advertising Standards, here are the counts”). No report references its public ad repository (Art. 39), and no report covers targeting limits (Art. 26(3) / Art. 28). Several even carve ad data out entirely.

The four layers

Stacked top (most visible to a user) to bottom (least). Only the last one shows up in the report you can download.

Disclosure on the ad itself

Marked as an ad; who paid and on whose behalf; the "Why am I seeing this?" panel on every ad.

Art. 26(1)
Not in the report
Covers
All platforms (not just VLOPs)
Where it lives
On each ad ("Why this ad", "Why am I seeing this ad?")

The lines they can't cross

No targeting on special-category or sensitive data; no profiling-based ads to minors.

Art. 26(3)Art. 28(2)
Not in the report
Covers
All users / minors
Where it lives
Policy + enforcement

The numbers they report

Content-moderation counts plus independent audits — the only layer the biannual report actually covers.

Art. 15Art. 24Art. 42Art. 37
In the biannual report
Covers
VLOPs (audits)
Where it lives
The biannual reports (the PDFs we already list)

Why Layer 4 is the thinnest rung

  • Google / YouTube

    The report openly excludes ad-moderation done before an ad is surfaced ("content moderation actions on advertisements that are taken before the advertisement is surfaced on a VLOSE or VLOP are not included in this report"), so the bulk of rejections never appear. It does disclose that 0.17% of fully-automated ad enforcement decisions in the EU were overturned on human review.

  • Meta (Facebook + Instagram)

    Ads fold into "Advertising + Commerce Content", and ad review "relies primarily on automated tools."

  • TikTok

    Ads are an "Advertising Policies" sub-policy inside the removals table; advertisers appear only as a class of users who can appeal.

Layer 4 — the reports we analysed

The latest four biannual DSA transparency reports from each platform. This is the only layer the PDFs cover.

Google / YouTube

Combined VLOSE/VLOP report — YouTube has no standalone report; its DSA data lives in Google’s combined report.

Meta — Instagram

Mind the gap: Meta published a Facebook Apr–Sep 2024 report but no Instagram equivalent — IG jumps from Mar 2024 to Oct–Dec 2024.

See where each platform stands

We track every major platform's compliance with the EU's Digital Services Act — country by country.