IAB Polska published a practical guide to political advertising under EU Regulation 2024/900 on July 28, 2026, sorting digital advertising businesses into three defined roles - sponsor, provider and publisher - and offering worked scenarios for billboard companies, pay-TV operators and programmatic ad sellers navigating the bloc's transparency and targeting rules.

The publication, titled "Przewodnik po reklamie politycznej" (Guide to political advertising), appeared on the IAB Polskawebsite. According to IAB Polska, the guide was prepared by the organization's experts based on an analysis of applicable regulations and the experience of the digital advertising market. It arrives roughly nine months after most provisions of the Transparency and Targeting of Political Advertising regulation took effect across the European Union on October 10, 2025, and about eight months before the bloc's centralized advertising repository is due to launch.

The document carries no legal force. IAB Polska describes it as neither a code of conduct nor a binding legal interpretation, but a working tool meant to help advertisers, platforms, publishers and agencies interpret a regulation whose broad definitions have already prompted several major platforms to exit political advertising in Europe altogether.

What the guide covers

Regulation (EU) 2024/900, commonly known as the Transparency and Targeting of Political Advertising rule, or TTPA, entered into force on April 9, 2024, following adoption by the European Parliament and Council in March of that year. Most of its provisions became applicable on October 10, 2025, while a separate deadline requires the European Commission to establish a centralized repository for online political advertisements by April 10, 2026.

IAB Polska's guide walks through the regulation's definitional architecture before moving into applied scenarios. According to the document, political advertising under the regulation means the preparation, placement, promotion, publication, delivery or dissemination, by any means, of a message, provided the activity is carried out by, on behalf of, or for the benefit of a political actor - unless purely private or commercial in nature - or that the message is liable and designed to influence an election, referendum, voting behavior, or a legislative or regulatory process at Union, national, regional or local level.

That second branch requires no link to a political party at all. A commercial message can fall under the regulation purely through its content, context, intended audience or timing, regardless of who paid for it. The guide notes that classification depends on functional elements set out in Article 8(1): the message's content, the sponsor's identity, the language used, the context and period of dissemination, the means of distribution, the targeted audience, and the underlying purpose. No single factor is decisive alone.

The guide separates three layered concepts. Political advertising is the chain of activities described above. Political advertising material is the concrete product carried through that chain - the poster, the banner, the video - published through any channel including print, broadcast, websites, search engines, streaming or online platform services. A political advertising campaign is a series of related material prepared, sponsored or financed together under a political advertising contract.

Five constitutive elements

According to the guide, an activity qualifies as political advertising when five elements are present, though the final two need not both apply simultaneously. The first is performing at least one activity in the chain: preparation, placement, promotion, publication, delivery or dissemination. Performing just one is sufficient - the guide cites an e-commerce company that also rents advertising space to third parties for political content, where the rental alone can qualify even though the company's main business is unrelated.

The second element is remuneration, understood broadly to include monetary payment and in-kind consideration, such as producing an advertisement in exchange for another service. The third is context: the activity occurs either as an internal action, carried out in the actor's own name, or within an organized campaign built on a contract and joint preparation, financing or sponsorship. Internal actions not involving targeting or ad-delivery techniques trigger none of the obligations under Chapter III of the regulation.

The fourth element concerns whether a message originates from, or serves, a political actor as defined in Article 3(4) - a category spanning political parties, entities linked to a party's sphere such as youth wings, candidates for elected office at any level, party officials, and persons representing any of the above, such as a foreign ministry spokesperson. A message issued on behalf of a political actor need not itself be designed to influence an election to qualify; the connection alone suffices.

The fifth element operates independently of any political actor connection. A message can qualify purely through its capacity and design to influence electoral outcomes, voting behavior or legislative processes, evaluated against the functional criteria above.

Worked examples from the guide

IAB Polska's document includes a table contrasting activities that qualify against those that do not. According to the guide, political messages presented by influencers at an association's request, in exchange for monetary or in-kind benefits, qualify because such communications cannot be treated as personal opinion. An influencer who independently encourages followers through a blog post to vote, expressing genuinely personal views, falls outside the definition - unless paid promotion is applied.

A political party commissioning an agency to prepare posts for its own social media account qualifies, according to the guide, while personal opinions published by a private individual on a personal blog do not. An ad-tech firm running targeted campaigns for an association raising climate awareness, unconnected to any legislative process, falls outside the definition, whereas a firm distributing material intended to steer voting behavior toward a position echoing one party's platform - the guide's example is a campaign promoting a nighttime alcohol sales ban - would in principle qualify.

The guide also addresses public officials acting in a private commercial capacity, offering the example of a local elected official who also owns a hotel and runs a campaign promoting vacation packages tied to bookings. According to the guide, this does not constitute political advertising and is treated as commercial information.

Three stakeholder roles and the supply chain

The regulation defines three categories of interested parties, and the guide devotes substantial attention to how businesses should locate themselves within that chain. A sponsor is the natural or legal person at whose request, or in whose name, material is prepared, placed, promoted, published, delivered or disseminated. A provider is a person supplying political advertising services, excluding purely ancillary services. A publisher is a provider that publishes, delivers or disseminates political advertising through any medium.

The guide spends considerable effort defining "purely ancillary services," a term it acknowledges is deliberately imprecise under Recital 39. According to the guide, ancillary services supplement political advertising but exert no direct influence over its content or presentation and do not constitute control over its preparation or distribution. Examples include a cybersecurity contractor protecting a party's website, newspaper and poster printing on commission, poster installation, photography services for politicians, and rental of physical space for political advertising activity.

The guide sets out three chain configurations. In Variant A, a sponsor commissions one provider to prepare material, who separately commissions a third party to publish it - splitting provider and publisher roles across two entities, each bearing only its own obligations. In Variant B, one entity handles both preparation and dissemination, consolidating both roles. In Variant C, a sponsor obtains material from a provider and disseminates it independently without paid mechanisms - through an unsponsored social media post, for instance - meaning no publisher exists in the chain, and transparency obligations under Articles 11 and 12 do not apply, though the sponsor still bears provider-side obligations under Articles 6(2) and 9(1).

According to the guide, the regulation does not concern itself with the content or form of the material itself - what matters for classifying a publisher is not insight into that content, but whether a conscious decision enabled its dissemination. The guide frames the analytical task as locating each business along a financial and operational chain: initiator as sponsor, creator as provider, distributor as publisher.

Applied sector scenarios

IAB Polska's Political Advertising Working Group contributed three sector-specific scenarios. The first involves a company operating physical advertising structures such as billboards and bus-shelter panels. Where the company contracts with an intermediary such as a media agency and only disseminates supplied material, it is classified solely as a publisher, which under the regulation's definitions also makes it a provider by extension. Where it contracts directly with a sponsor such as a political party and both prepares and disseminates material, it is classified as both.

The second scenario addresses pay-television operators across cable, satellite, IPTV, OTT and digital terrestrial technologies. According to the guide, an operator that merely transmits channel signals without payment for political advertising, and cannot legally interfere with a broadcaster's signal under Poland's broadcasting law, provides purely ancillary services. The guide notes an alternative: an operator using dynamic ad insertion in coordination with a broadcaster, where political advertising appears within inserted ads, could be classified as a publisher for those channels.

The third scenario covers programmatic advertising sold through website banner inventory. According to the guide, a publisher deciding which categories of advertising to allow or block - even without controlling which specific message fills a given impression - may still qualify as a publisher, because making space available while allowing political material to circulate within it can be sufficient for that classification.

Targeting techniques and the capping question

The guide's final substantive section addresses Articles 18 and 19, which govern targeting techniques and ad-delivery techniques respectively. According to the document, targeting techniques under Article 3(11) are those applied through processing personal data to direct material toward, or exclude it from, a specific person or group. Ad-delivery techniques under Article 3(12) are optimization techniques that increase circulation, reach or visibility through automated processing of personal data, and which may also deliver material exclusively to a specific person or group.

The guide offers a notable position on geographic targeting. Where targeting criteria are set so material reaches an entire population affected by a political process - a whole voivodeship during local elections, or all of Poland during a presidential election - and the underlying technology relies only on regional targeting rather than per-user targeting, without detailed geolocation, a position is available that such activity does not meet the criteria for targeting techniques under Articles 18 and 19. The same reasoning, according to the guide, extends to IP addresses or user agents where those data points serve only the technical function of displaying an advertisement rather than selecting recipients by characteristics.

The guide devotes particular attention to frequency capping, the practice of limiting how many times a user sees a given advertisement. It distinguishes capping built on broader audience profiling - which would fall within targeting or ad-delivery techniques - from solutions relying strictly on a technical marker and an impression counter isolated to a single campaign. In the latter model, the counter only establishes whether a previously defined display limit has been reached; it is not used to build a recipient profile, is not linked to preference databases, does not reconstruct browsing history, and is not shared with the sponsor as information about a specific individual. The decision is binary: it determines only whether an emission limit has been reached, not who should see an advertisement based on personal characteristics.

Under that architecture, the guide states there are grounds for treating technical capping as not independently constituting a targeting or ad-delivery technique under Articles 18 and 19. It cautions that this applies only to solutions avoiding behavioral profiling, avoiding data about political preferences, and avoiding combination of the technical marker with other data enabling audience selection.

The guide flags an important caveat on timing. As of the date it was prepared, the European Data Protection Board had not yet adopted the guidelines referenced in Article 22(2) concerning personal data processing for targeting or delivering political advertisements. The guide characterizes its own operational position on this point as provisional, pending those EDPB guidelines, and states that the wider document represents a first attempt at systematizing interpretation of the applicable rules that will be developed and updated as new guidance, legal practice and market experience emerge.

Why the guide matters now

The publication lands at a moment when the practical consequences of the TTPA have already reshaped how political messaging moves through digital channels in Europe. Both Google and Meta withdrew from serving political advertising across the EU ahead of the regulation's October 10, 2025 effective date, citing the breadth of the definition and the operational difficulty of reliably identifying qualifying content at scale. That withdrawal removed two of the largest distribution channels for paid political messaging from the European market, pushing campaigns, parties and issue advocates toward alternative channels - exactly the kind of physical, broadcast and programmatic scenarios that IAB Polska's guide now works through in detail.

For agencies, ad-tech vendors and publishers who remain active in adjacent spaces - billboard networks, pay-TV distribution, programmatic exchanges - the guide functions as a self-assessment tool at a point when regulatory ambiguity carries real commercial weight. A business that fails to recognize its own classification as a provider or publisher of political advertising risks missing obligations around record-keeping, transparency notices and, closer to April 2026, the European repository this content must ultimately feed into. Conversely, businesses that mistakenly treat commercial activity as falling under the regulation risk applying compliance overhead - including forgone ad revenue from third-country restrictions during pre-election periods - where none is legally required.

The unresolved question sitting underneath the entire guide is what the EDPB's eventual guidelines on targeting and ad-delivery techniques will say. IAB Polska's capping analysis represents a considered interpretive position, not a settled one, and the organization's own footnotes acknowledge that Recital 26 and points 5-6 of the Commission's draft implementation guidance from 2025 describe similarly ancillary scenarios only in terms of what would "probably" be treated as ancillary, rather than offering firm rulings. That interpretive uncertainty is not unique to Poland. It mirrors a broader pattern across the EU's digital rulebook, where the EDPB has increasingly stepped in to reconcile overlapping obligations - as with its September 2025 guidelines on the interplay between the Digital Services Act and the GDPR - after industry bodies and platforms had already begun operating under their own working interpretations.

Timeline

  • March 11, 2024: The Council of the European Union adopted Regulation 2024/900 on the transparency and targeting of political advertising.
  • April 9, 2024: The regulation entered into force following its adoption.
  • November 2024: Google announced its withdrawal from EU political advertising ahead of the regulation taking effect.
  • 2025: The European Commission released draft implementation guidance for sponsors, providers and publishers under the regulation.
  • July 25, 2025: Meta announced it would end political advertising in the EU ahead of the regulation's effective date.
  • September 3, 2025: Google's Ads API began enforcing EU political advertising declarations across API versions.
  • September 11, 2025: The EDPB adopted Guidelines 3/2025 on the interplay between the DSA and the GDPR, an example of the kind of clarifying guidance still pending for Articles 18 and 19 of the political advertising regulation.
  • October 10, 2025: Most provisions of the TTPA regulation took effect across EU member states.
  • October 2025: Google added political ads coverage to its Transparency Center as the regulation's effects took hold.
  • April 10, 2026: The European Commission's deadline to establish a centralized repository for online political advertisements.
  • July 28, 2026: IAB Polska published its Guide to Political Advertising, addressed to advertisers, platforms, publishers and agencies.

Summary

Who: IAB Polska, the Polish digital advertising industry association, working through its Political Advertising Working Group of legal and industry experts, published the guide for advertisers, ad-tech platforms, publishers, agencies and any entity involved in running or servicing political campaigns.

What: A practical, non-binding guide interpreting Regulation 2024/900, defining political advertising, political advertising material and political advertising campaigns, classifying businesses as sponsors, providers or publishers, working through purely ancillary services, three supply-chain variants, three applied sector scenarios covering billboards, pay-TV and programmatic advertising, and an interpretive position on frequency capping under Articles 18 and 19.

When: The guide was published on July 28, 2026, roughly nine and a half months after most provisions of Regulation 2024/900 took effect on October 10, 2025, and about eight and a half months before the European Commission's April 10, 2026 deadline to establish a centralized political advertising repository.

Where: The guide addresses the Polish market specifically but interprets an EU-wide regulation that applies uniformly across all 27 member states, covering both online and offline political advertising activity.

Why: The regulation's broad, function-based definition of political advertising already prompted Google and Meta to withdraw from the practice across the EU in 2025, leaving physical, broadcast and programmatic channels - the exact scenarios IAB Polska's guide addresses - as the remaining routes for political messaging, at a moment when businesses in those channels still lack final EDPB guidance on how targeting and ad-delivery rules apply to their operations.