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Efforts by tech giants to be more transparent about the ads they run are — at very best — still a work in progress, according to a report looking at ads transparency tools. The report comes about a half year since the European Union’s Digital Services Act (DSA) rules for larger platforms came into force, mandating companies offer a searchable public ads library. Companies include: Apple, Google, Meta, TikTok and X.

In some cases, notably (but not exclusively) X’s, the level of ad transparency provided by the platform scores close to zero on all fronts, with available tools lacking vital data and functionality per the external assessment, which was conducted by free software maker Mozilla working with CheckFirst, a Finland-based disinformation research company.

The report’s top-line conclusion is that platforms’ ad oversight tools are falling short of delivering the intended transparency and democratic accountability in a critical year for elections globally.

“We find a huge variation among the platforms, but one thing is true across all of them: none is a fully-functional ad repository and none will provide researchers and civil society groups with the tools and data they need to effectively monitor the impact of VLOs [very large online platforms and search engines] on Europe’s upcoming elections,” the report authors write, naming AliExpress and X as the worst examples of those tech giants that do provide an ads library (Amazon has avoided providing one so far), before adding in a line that damns with faint praise: “[W]e struggle to tell you which one is best.”

A lack of critical data and effective tools to study platforms means independent researchers still face huge barriers when it comes to producing data-driven insights on the impacts of Big Tech. Without robust public interest research, how can the world’s wealthiest companies be held to account for business models that frequently rely on amping up user engagement to juice more ad views?

Just think of the discussion around social media use and teens’ mental health, as one example. Ads transparency tools that enabled external researchers to study the types of paid messaging targeting young people across different platforms could help shine a light on any problematic dynamics and platform incentives. But adtech giants evidently aren’t making this kind of research easy.

Still, the bald fact of 11 of the world’s largest tech companies providing ad repositories — most doing so as a direct result of the EU regulation — is “in itself” a basic form of progress, as the research authors see it. Even as none of the tools they’re offering are properly enabling researchers yet in their view.  

The pan-EU DSA provides for penalties of up to 6% of global annual turnover for compliance failures. So enforcement on poor performance could lead to hefty fines down the line. But despite this dialed-up regulatory risk, the report suggests tech giants aren’t exactly falling over themselves to shine a clarifying spotlight on a targeted messaging that funnels direct revenue into their coffers.

Compliance theater

Indeed, no platform got a “ready for action” green light assessment from Mozilla and CheckFirst. Meta, which has been operating an ads library for longest, has among the most mature offering in their view, yet its ads library still has “big gaps in data and functionality,” per the report. Likewise, Apple, LinkedIn and TikTok all have similar failings. Alphabet (Google), Booking.com and Pinterest are assessed as offering an even worse “bare minimum” effort.

Alongside the aforementioned “utter disappointment” of AliExpress and X, the report gives the same overall red rating to Bing, SnapChat and Zalando, saying their transparency tools also lack vital data and functionality.

Compliance theater is a concept familiar to EU privacy watchers when it comes to the design of consent flows for collecting permission from web users to track and profile their online activity for mircotargeted advertising. Judging by the report findings, something similar may be playing out in platforms’ early responses to DSA demands for ads transparency. Many appear to be seeing how little they can get away with, perhaps with the aim of testing how the Commission, which oversees compliance, responds; or just because they prefer to direct more of their resources into generating revenue than addressing legal compliance.

Around a dozen tech giants that offer very large platforms and/or search engines, which the report refers to as VLOs, face the strictest level of DSA regulation — including the requirement to publish an ads library. Mozilla and CheckFirst stress-tested ad libraries associated with the following e-commerce, social networking and marketplace platforms between December 2023 and January 2024: AliExpress, Alphabet (Google Search and YouTube), Apple App Store, Bing, Booking.com, LinkedIn, Meta (Facebook and Instagram), Pinterest, SnapChat, TikTok, X and Zalando — conducting independent tests aimed at assessing key issues like the tools’ functionality and reliability.

“We examine factors such as the depth of information provided regarding the advertisement and its advertiser, the targeting criteria employed, and the ad’s reach. Additionally, we evaluate the completeness of the ad repository, the availability of historical data, and the accessibility, consistency, and documentation of the tools provided,” the authors wrote, noting also that most (but not all) platforms provide a separate web-based ad repository and an API — hence they assessed these discrete implementations individually.

“Major gaps”

They do note there has been some developments since they carried out their transparency tools tests. The study is therefore only a snapshot of where things stood about half a year after the late August compliance deadline for VLOs.

They also haven’t assessed some deeper elements, such as the accuracy of information platforms provide, i.e. about who is paying for ads. Influencer or branded content is also not assessed. But the tests allow analysis of the pace of progress since compliance day, as well as enabling basic comparisons between platform offerings and shortcomings.

Among several key findings in the report are concerns related to accuracy issues and missing data. “Our accuracy testing found many cases where ads in the user interface were not found in the ad repository,” they note, adding: “This can limit the usefulness and trustworthiness of the repositories as a transparency tool.”

“We feel there are major gaps between the spirit of the EU regulation and these repositories in practice, which are supposed to ‘facilitate supervision and research into emerging risks brought about by the distribution of advertising online’,” the report authors conclude, pointing out that in the case of X, for example, it only provides a CSV file for download, which they also found to be “curiously slow.” (They argue that this type of historical access is “only useful if you already know everything about the ad you’re searching for,” suggesting that X, under divisive billionaire owner Elon Musk, is essentially attempting to kneecap independent research, even as he claims to respect the law.)

The social network formerly known as Twitter was the first platform to be formally investigated by the EU for suspected breaches of the DSA, including in the area of data access for researchers. That probe, which was opened in December, remains ongoing. But if DSA breaches are confirmed, X is positioned first in line to receive a hefty fine.

Also highlighting how platforms are kicking against the EU’s transparency mandate, at the time the report was compiled, Amazon was not offering an ad library at all — after being granted a temporary exemption from the obligation by an EU court last fall.

A higher court subsequently reversed that decision, late last month, so the e-commerce giant will have to put its promotional laundry on the line for external perusal after all. But, as the report suggests, it’s all too easy for platforms to inject intentional friction into transparency tools, whether by restrictive design or sloppy implementation or both. This undermines researchers’ ability to interrogate technosocial impacts and ad-driven business models, by making finding, sorting and filtering data about ads they’ve monetized much harder than it should be.

The report contains a series of recommendations to drive transparency on platforms, including design changes tech giants could implement, such as making ad libraries public without requiring a login; allowing unrestricted browsing; and offering enhanced search functionalities such as supporting searches by keywords, advertiser, country and date range and allowing filtering and ordering of results, to name a few of the suggested changes.

They also suggests steps for enforcers, such as developing guidelines for ads transparency that set minimum standards for what platforms must deliver in web repositories and APIs; and requiring the use of standardized APIs for research access to boost usability and enable cross-platform research.