A report on advertising transparency tools notes that the tech giants' efforts to increase advertising transparency are, at best, a work in progress. The European Union's Digital Services Act (DSA) for large platforms requires companies to provide a searchable library of public advertisements. These companies include Apple, Google, Meta, TikTok, and X.
According to an external assessment conducted by freeware developer Mozilla in partnership with Finnish disinformation research firm CheckFirst, in some cases, especially (but not limited to) X, the advertising transparency provided by the platform is close to zero on all aspects, and existing tools lack important data and functionality.
The report's overarching conclusion is that in a crucial year for global elections, platforms' ad monitoring tools have not achieved the expected levels of transparency and accountability.
"We found huge differences between these platforms, but one thing was true across all of them: none of them were fully functional ad banks, and none of them provided researchers and civil society with the tools and data they needed to effectively monitor the impact of VLOs (hyper-large web platforms and search engines) on Europe's upcoming elections," the report's authors wrote. "
The report's authors named AliExpress and X as the worst examples of tech giants that offer ad libraries (Amazon still doesn't), and then adds, "It's hard to say which company is the best."
The lack of critical data and effective tools for research platforms means that independent researchers still face significant barriers to coming up with data-driven insights about the impact of Big Tech. Without strong pro bono research, how can the world's richest companies be held accountable for business models that often rely on increasing user engagement to get more ad views?
Connecting the dots around social media use and adolescent mental health is an example of this. The Ad Transparency tool allows external researchers to look at the types of paid information targeted at young people on different platforms, helping to uncover any problematic dynamics and platform incentives. But it's clear that ad tech giants don't take this kind of research lightly.
However, the fact that 11 of the world's largest tech companies offer ad inventory – much of it as a direct result of EU regulations – is a fundamental step forward in itself, in the study's authors' view. Although, in their view, the tools provided by these companies are not yet sufficient to provide proper assistance to researchers.
The pan-EU DSA stipulates penalties for non-compliance of up to 6% of annual global turnover. As a result, enforcement against underperformers can result in hefty fines. However, despite this heightened regulatory risk, the report shows that tech giants have not completely given up on clarifying targeted information that directly generates revenue for their treasuries.
"Compliance Theater"
In fact, no platform has received a "ready" green light assessment from Mozilla and CheckFirst. In their opinion, Meta, which has been operating an ad library for the longest time, is one of the most mature platforms, but reports that its ad library still has "a big gap in terms of data and features." Similarly, Apple, LinkedIn, and TikTok have similar issues. According to assessments, Alphabet (Google), Booking.com, and Pinterest are even worse at the "minimum" effort.
In addition to the aforementioned "utterly disappointing" AliExpress and X, the report also gave Bing, SnapChat, and Zalando the same "red" ratings, saying that their transparency tools also lacked important data and features.
EU privacy watchers are no strangers to the concept of "compliance theater," which involves designing a consent process that collects web users' permissions to track and describe their online activity for targeted advertising. From the results of the report, it is possible that the early response of platforms to DSA's advertising transparency requirements may have been similar. Many platforms seem to want to see how far they can go, perhaps to test the reaction of the committee tasked with overseeing compliance, or simply because they prefer to devote more resources to revenue generation than to addressing legal compliance issues.
About a dozen tech giants that offer hyperscale platforms and/or search engines (the report refers to them as VLOs) face the strictest DSA regulation – including the requirement to publish ad libraries. Mozilla and CheckFirst stress-tested ad libraries related to the following e-commerce, social network, and marketplace platforms between December 2023 and January 2024:Mozilla and CheckFirst stress-tested ad libraries related to the following e-commerce, social network, and marketplace platforms between December 2023 and January 2024: AliExpress, Alphabet (Google Search & YouTube), Apple App Store, Bing, Booking.com, LinkedIn, Meta (Facebook & Instagram), Pinterest, SnapChat, TikTok, X, and Zalando – conducted independent tests designed to evaluate key issues such as the functionality and reliability of the tool.
"Factors we review include the depth of the ad and its advertiser information, the targeting criteria employed, and the reach of the ad. In addition, we evaluated the integrity of the ad library, the availability of historical data, and the accessibility, consistency, and documentation of the tools provided. They also noted that most, but not all, platforms offer separate web-based ad libraries and APIs, so they evaluated these independent implementations individually, the authors wrote.
"Significant gaps"
They did notice that things have changed a bit since they did the transparency tool test. Therefore, this study is just a microcosm of what VLO is doing about half a year after the compliance deadline at the end of August.
They also didn't evaluate some of the deeper factors, such as the accuracy of the information provided by the platform, i.e., who was paying for the ads. Influencers or branded content were also not evaluated. However, these tests allow for an analysis of the rate of progress since the date of compliance, as well as a basic comparison of the platform's offerings and shortcomings.
Several key findings from the report include issues related to accuracy issues and missing data. "Our accuracy tests have found many cases where ads in the user interface are not found in the ad library, which may limit the ad library's usefulness and credibility as a transparent tool," they noted. "
"We believe that there is a significant gap between the spirit of EU regulations and the actual practice of these information bases, which are supposed to 'facilitate the monitoring and study of the new risks posed by the spread of online advertising,'" the authors of the report concluded, noting that Company X, for example, only provides CSV files for download, and that they also found the download speed to be "surprisingly slow." (They argue that this type of historical access is "only useful if you already know everything about the ads you're searching for," suggesting that Elon Musk, a billionaire at Company X, while claiming to respect the law, is essentially trying to stifle independent research.)
The social network, formerly known as Twitter, was the first platform to be formally investigated by the European Union for alleged violations of Data Protection Laws, including with regard to access to data from researchers. The investigation began in December and is still ongoing. However, if the breach of the Data Protection Act is proven, X will be the first to be fined hefty.
In addition, Amazon did not offer an ad library at all after receiving a temporary waiver from the Court of Justice of the European Union last fall, which also highlights how the platform violates the EU's transparency requirements.
The decision was subsequently reversed by a higher court late last month, so the e-commerce giant will have to put its promotional clothing online for the outside world to see. However, as the report points out, platforms can easily inject intentional friction into transparency tools through restrictive design or sloppy execution, or both. This weakens researchers' ability to conduct research on the societal impact of technology and advertising-driven business models, making it more difficult to find, collate, and sift through data about advertising.
The report makes a series of recommendations to improve platform transparency, including design changes that tech giants can implement, such as making ad libraries public without having to log in, allowing unlimited browsing, and providing enhanced search capabilities such as support for searching by keyword, advertiser, country, and date range, as well as allowing search results to be filtered and sorted.
They also recommended that implementers take a number of measures, such as developing guidelines for advertising transparency to set minimum standards for the content that platforms must provide in web repositories and APIs, and requiring the use of standardized APIs for research access to improve usability and enable cross-platform research.