The advertising transparency repository meta: VLOPs’ and VLOSEs’ non-compliance with Article 39 of the EU Digital Services Act

The EU Digital Services Act (DSA) requires the largest online services to provide a repository of all advertising shown, including each ad’s content, its advertiser’s identity, and associated data on which user demographics were targeted, and how many users were eventually reached. Theoretically, mandated ad libraries provide unprecedented access and transparency and would be invaluable tools for advertising research and regulatory enforcement. However, these repositories must exist and be compliant with various disclosure obligations to be useful in practice. Only 17 of the 24 services that were obliged to comply in April 2026 (70.8%) ostensibly provided a publicly accessible online interface-based ad repository. We studied the capabilities of 12 repositories (as some services shared one). Basic data ( e.g. , ad content, display period, and advertiser identity) were reliably provided by most. However, as to more granular user targeting and reach metrics, the data provided were often insufficiently detailed, with only Meta (one of 12 repositories; 8.3%) providing the precise user demographic targeting criteria used and the exact number of users reached broken down by targeted demographic groups. Whilst the European Commission has proactively enforced other DSA obligations against many services, ad repository compliance has not been adequately enforced. Concerningly, seven of 24 obliged services (29.2%) failed to provide one at all. Stricter enforcement is necessary to ensure that the DSA achieves its legislative aims in practice by allowing the public ( e.g. , academic researchers and journalists) and regulators to properly scrutinise online advertising. Presently, for most purposes, we recommend first trying the generalist Meta Ad Library (covering Facebook and Instagram).

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Publication Details

Journal
Computer law & security review
Published
2026-10-15
DOI
https://doi.org/10.1016/j.clsr.2026.106415
Primary Topic
Digitalization, Law, and Regulation
Type
article
Field-Weighted Citation Impact
0.00

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article

The advertising transparency repository meta: VLOPs’ and VLOSEs’ non-compliance with Article 39 of the EU Digital Services Act

Leon Y. Xiao, Callum Deery, Xiaoyao REN
Computer law & security review
Digitalization, Law, and Regulation
article

The advertising transparency repository meta: VLOPs’ and VLOSEs’ non-compliance with Article 39 of the EU Digital Services Act

Leon Y. Xiao, Callum Deery, Xiaoyao REN
article en

Abstract

The EU Digital Services Act (DSA) requires the largest online services to provide a repository of all advertising shown, including each ad’s content, its advertiser’s identity, and associated data on which user demographics were targeted, and how many users were eventually reached. Theoretically, mandated ad libraries provide unprecedented access and transparency and would be invaluable tools for advertising research and regulatory enforcement. However, these repositories must exist and be compliant with various disclosure obligations to be useful in practice. Only 17 of the 24 services that were obliged to comply in April 2026 (70.8%) ostensibly provided a publicly accessible online interface-based ad repository. We studied the capabilities of 12 repositories (as some services shared one). Basic data ( e.g. , ad content, display period, and advertiser identity) were reliably provided by most. However, as to more granular user targeting and reach metrics, the data provided were often insufficiently detailed, with only Meta (one of 12 repositories; 8.3%) providing the precise user demographic targeting criteria used and the exact number of users reached broken down by targeted demographic groups. Whilst the European Commission has proactively enforced other DSA obligations against many services, ad repository compliance has not been adequately enforced. Concerningly, seven of 24 obliged services (29.2%) failed to provide one at all. Stricter enforcement is necessary to ensure that the DSA achieves its legislative aims in practice by allowing the public ( e.g. , academic researchers and journalists) and regulators to properly scrutinise online advertising. Presently, for most purposes, we recommend first trying the generalist Meta Ad Library (covering Facebook and Instagram).

Computer law & security reviewVol. 63
City University of Hong Kong (HK)
City University of Hong Kong
Openalex Percentile: Top 3%
Digitalization, Law, and Regulation
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