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05/2026

Stress Testing Advertising Repositories

A comparative analysis of Meta, TikTok, Google, and Snapchat's advertising repositories under Article 39 DSA - none fully compliant, though the gaps differ sharply by platform.

AdvertisingENDE
ad libraries assessed
4
criteria evaluated
13
fully comply with the DSA (39) requirements
0/4

Summary

We tested the advertising repositories of Meta, TikTok, Google, and Snapchat against Article 39 DSA, which requires very large online platforms to provide a publicly accessible, searchable advertising repository. Using a 13-criteria evaluation matrix covering accessibility, searchability, reliability, and data quality, we assessed each platform's browser-based archive and tested search reliability by locating ads seen in the platforms' feeds within their respective repositories. Assessment was conducted as of April 2026.

Key Findings:

  • All four platforms formally provide an advertising repository, but none fully comply with the DSA requirements.
  • While Meta comes closest to meeting the DSA requirements, Snapchat shows the largest deficits; TikTok and Google fall in between with different gaps each.
  • All four platforms show signifi cant gaps in the coverage of commercial communications (e. g. branded content).

Search reliability is a weak point across all four platforms. Meta's search is the most stable, but ads can still disappear from the archive over time, and text search doesn't always surface relevant results. Google's search is structurally limited to advertiser name or URL, making thematic research without prior knowledge of the advertiser effectively impossible. TikTok's keyword search often fails despite broader filters on paper, and Snapchat performed worst - as of March 2026, most ads visible in the feed couldn't be located in the archive at all, though an April 2026 update brought some improvement.

Data quality shows similar gaps. Payer and beneficiary information is self-declared and freely entered on all four platforms, with only Google and Meta offering optional advertiser verification. Targeting and reach disclosure is more detailed on Meta, TikTok, and Snapchat than on Google, which reveals only broad categories and requires 27 separate country queries for full EU coverage. The deepest gap is in commercial content: Google has no dedicated archive section for branded content at all, and while Meta, TikTok, and Snapchat do, creators rarely apply the required labelling - so the relevant ads simply don't appear.

Recommendations

Set minimum functional standards for search: The European Commission should require content-based keyword search across the full text of advertisements as a baseline.

Make advertiser identity verification mandatory: The European Commission should require identity verification for advertisers as a minimum standard.

Enforce genuine coverage of commercial content: The European Commission should require platforms to fully capture commercial communications like branded content.

Project & funding

AdWatch — funded by Kiras Sicherheitsforschung, FFG, and Bundesministerium Finanzen.

  • Kiras Sicherheitsforschung
  • FFG
  • Bundesministerium Finanzen

This research was conducted as part of the "AdWatch" project, and funded by the KIRAS security research programme of the Federal Ministry of Finance.

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