Summary
We tested TikTok's ad library by searching for and cross-referencing advertisements visible on the platform against what the archive returns, to assess whether the tool functions as intended under the DSA.
Our findings point to gaps in three areas: examine the transparency gaps in TikTok’s ad library and what they mean for DSA enforcement in practice:
- serious limitations in the search and discoverability of ads. Although TikTok’s ad library allows searches by advertiser, keyword, country, and publication date, some core functions are ineffective or not transparent in how they work. In practice, many publicly shown advertisements cannot be retrieved through the archive, and
- important content- and product-related information is missing - such as video descriptions, hashtags, or details on the promoted product or service (where the ads lead, who is behind them).
- separate archive for “other commercial content”, including influencer marketing and branded content, lacks crucial information on promoted products, commercial relationships, and financial responsibility.
Formal compliance alone is not enough: ad repositories must also be searchable, complete, and meaningful for the researchers, civil society groups, and supervisory authorities that rely on them. Where transparency tools don't function properly, effective monitoring of harmful, deceptive, or illegal advertising becomes far more difficult.
Recommendations
Fix search and retrieval: TikTok should ensure that all publicly running ads are actually discoverable through the Ad Library's search function, rather than remaining invisible despite being active on the platform.
Add missing advertiser and content information: TikTok should include key missing fields - such as video descriptions, hashtags, linked destinations, and advertiser identity - in both the main Ad Library and the separate archive for branded content.
Bring branded content transparency in line with the main library: TikTok should apply the same standard of completeness to its branded content and influencer marketing archive as to the main Ad Library, given that commercial relationships and financial responsibility are currently unclear there.
AdGuardians — funded by netidee.
This research was conducted as part of the “AdGuardians” project, which was made possible by netidee funding from the Internet Foundation.
