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EU DSA · EU-DSA-ART39-VLOP-AD-TRANSPARENCY

EU DSA Article 39 - Additional online advertising transparency for VLOPs and VLOSEs

Maintain a searchable public advertisement repository containing all ads shown, accessible for the ad display period plus one year

HIGHRecord-keeping dutyTransparencyBinding regulationIn forceApplies from 17 February 2024

Where this comes from

Provision: Article 39 - Additional online advertising transparency for VLOPs and VLOSEs

Instrument: EU Digital Services Act (Regulation 2022/2065)

Citation: Regulation (EU) 2022/2065 of the European Parliament and of the Council, Article 39

Text version: Regulation (EU) 2022/2065 (DSA), OJ L 277, 27.10.2022

Read the official text ↗

Who it applies to

It applies when all of these are true:

  • Service is a Very Large Online Platform/Search Engine (45M+ EU users)
  • Service has users in the European Union
  • Service displays advertising

What engineering work it implies

Sample acceptance criteria Landfall generates for this obligation:

  • Assess necessary repository publication, update and archival evidence using advertisement references and operation outcomes, subject to the source-specific record and retention requirements.
  • Public search analytics is off by default; do not record query text, viewer identifiers or browsing histories merely because the repository is public. Any additional analytics requires a separate purpose and legal assessment.
  • Assess minimal operational and rate-limit events separately from search analytics, with necessary fields, restricted access and defined expiry.
  • Identify the specific logging purpose, applicable source requirement and necessary events/fields; document when no additional event log is justified.
  • Prefer minimized metadata and scoped references; do not collect user IDs, IP addresses, raw payloads or credentials by default. Assess any additional personal data and its legal basis before capture.

Questions people ask

Does EU DSA Article 39 - Additional online advertising transparency for VLOPs and… apply to my service?
It applies when Service is a Very Large Online Platform/Search Engine (45M+ EU users); Service has users in the European Union; Service displays advertising.
From when does this apply?
EU DSA Article 39 - Additional online advertising transparency for VLOPs and… applies from 17 February 2024. Its current status is: in force.

Find out whether this one lands on you

Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.

Run the pre-scanAll EU DSA obligations

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