At Mozilla we believe that greater transparency in the online advertising ecosystem can empower individuals, safeguard advertisers’ interests, and address systemic harms. It’s something we care passionately about, and it’s an ethos that runs through our own marketing work. Indeed, our recent decision to resume advertising on Instagram is underpinned by a commitment to transparency. Yet we also recognise that this issue is a structural one, and that regulation and public policy has an important role to play in improving the health of the ecosystem. In this post, we give an update on our efforts to advance system-level change, focusing on the ongoing discussions on this topic in the EU.
In December 2020 the European Commission unveiled the Digital Services Act, a draft law that seeks to usher in a new regulatory standard for content responsibility by platforms. A focus on systemic transparency is at the core of the DSA, including in the context of online advertising. The DSA’s approach to ad transparency mandates disclosure well above the voluntary standard that we see today (and mirrors the ethos of our new Instagram advertising strategy).
Under the DSA’s approach, so-called ‘Very Large Online Platforms’ must:
- Disclose the content of all advertisements that run on their services;
- Disclose the key targeting parameters that are associated with each advertisement; and,
- Make this disclosure through publicly-available ad archives (our recommendations on how these ad archives should operate can be found here).
The DSA’s ad transparency approach will give researchers, regulators, and advertisers greater insight into the platform-mediated advertising ecosystem, providing a crucial means of understanding and detecting hidden harms. Harms fester when they happen in the dark, and so meaningful transparency in and of the ecosystem can help mitigate them.
Yet at the same time, transparency is rarely an end in itself. And we’re humble enough to know that we don’t have all the answers to the challenges holding back the internet from what it should be. Fortunately, another crucial benefit of advertising transparency frameworks is that they can provide us with the prerequisite insight and evidence-base that is essential for effective policy solutions, in the EU and beyond.
Although the EU DSA is trending in a positive direction, we’re not resting on our laurels. The draft law still has some way to go in the legislative mark-up phase. We’ll continue to advocate for thoughtful and effective policy approaches for advertising transparency, and prototype these approaches in our own marketing work.