Interactive Advertising Bureau
27 July 2023

Digital Services Act is an Opportunity for Industry Standardization

 

IAB Europe’s DSA Taskforce Actively Working to Support Compliance Efforts, Open For Members to Join

IAB Europe continues to work with industry members to support compliance needs; this time with the EU’s Digital Services Act (DSA). IAB Europe’s DSA Task Force expects to release a solution for industry adoption later this year, but today we are seeking involvement from the broader ecosystem for further development. Ad supply chain businesses should prepare to put DSA support on product roadmaps looking ahead to the DSA 16 February 2024 date of applicability.

As currently drafted, the proposed solution begins with the “back-end”, enabling the piece of the DSA puzzle that provides transparency information within the supply chain and leaving the user-facing disclosures to be developed by market actors.This does not preclude future work standardizing aspects of user experience. Within the IAB Europe DSA Taskforce, we seek further discussion.

Background

The DSA was adopted in October 2022.  Along with the Digital Markets Act (DMA), the DSA is intended to improve the confidence of both private consumers and business users of Online Platforms as defined by DSA in the products and services they access via those platforms, as well as the advertising they are exposed to on them, and to ensure a level playing field between platforms.  The DSA lays down transparency obligations in relation to advertising; these obligations apply to online platforms, “very large online platforms” (VLOPs), and “very large online search engines” (VLOSEs).  

Article 26 DSA has been the main focus of our taskforce. It requires online platforms to ensure that users have real-time access to certain elements of information about ads shown to them on an online platform:

  • That the ad is indeed an ad;
  • The identity of the advertiser;
  • The identity of the party that financed the ad, if it is different from the advertiser;
  • Information about the “main parameters” used to determine the recipient of the ad;
  • Where applicable, information about any means users may have at their disposal to change those main parameters.  

Although the legal obligation to provide the user-facing information disclosures applies to online platforms, it is clear that in many advertising scenarios, those platforms will need to rely on third-party vendors for the information that will be required to populate the disclosures.  DSA obligations are on the Platforms and VLOPs to provide transparency about the advertisement displayed to consumers – this necessitates the supply chain ecosystem’s involvement in supporting Platforms and VLOPs across RTB, Non-programmatic, Audio/Video, and In-App scenarios.

Therefore, our focus has been on the collection and delivery of the Art. 26 information from the parties in the supply chain that have the information. 

Expected Roles to support IAB Europe DSA Transparency

Fulfilling DSA Art. 26 obligations will require cooperation and collaboration between players in the supply chain. In this blog post, we are sharing our draft of roles and responsibilities for compiling and delivering Art. 26 ad transparency information. Given timing, we want to encourage businesses to allocate resources to support DSA transparency industry solutions. IAB Europe intends to support a wide range of use cases.  Depending on the use case, different actors will perform different roles.  In any case, the online platforms who are the object of the legal requirements will have different options currently being discussed in the Taskforce. The following are only proposed draft scenarios, and are subject to change with further Taskforce development. 

By sharing these draft Roles, we want to indicate that many business types could have a role to play, and encourage further discussion.

Business Type Proposed Top Level Roles and Requirements by End of Year [Work-in-Progress, Subject to Change]
Platforms and VLOPs
  • Display DSA ad transparency information.
  • Support rendering the transparency information, either by building tech or relying on tech partners.
  • Contribute to DSA transparency of user targeting parameters if any sell-side pre-targeting was applied.
  • If applicable, Point users to a mechanism for choice, for example a TCF CMP.
  • Option to support Platforms who want to block ads without DSA transparency info.
Platform/VLOP tech partners
  • Publisher ad servers may need to support Platforms/VLOPs to render DSA transparency info.
  • Video/audio players may need to support rendering DSA transparency info.
CMPs
  • Option to support Platforms/VLOPs who want their CMPs to render DSA Transparency to users.
SSPs
  • Contribute to user targeting parameters if sell-side targeting was applied.
  • Option to support Platforms who want to control bid responses not carrying the DSA transparency info.
DSPs
  • Initiate the DSA transparency object, unless initiated by another party.
  • Provide DSA transparency information, including “behalf” and “paid” passed from advertiser/agency to the supply chain.
  • Contribute to user targeting parameters intended to disclose to consumer (as per DSA), where applicable.
  • Support wiring fields to creative for rendering DSA Ad Transparency information in-ad.

Based on the draft roles/responsibilities listed above, we encourage advertising ecosystem businesses to prepare product roadmaps to coordinate with partners on this matter and develop support for DSA compliance before the end of the year. The Task Force is open for IAB Europe members to participate. We anticipate an actual release of the solution for adoption in the coming months, and look forward to collaboration to arrive there. 

Next steps you can take;

  • Schedule development resources on your product roadmap.
  • If you have any questions or would like to get involved with the taskforce to refine the DSA transparency solution, please email dsateam@iabeurope.eu 

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