Abstract

With the entry into force of Regulation on Transparency and Targeting of Political Advertising (hereinafter “TTPA” or “Regulation 2024/900”), there are two regimes for online advertising transparency in the European Union legal order. One stems from the horizontal regime of the Digital Services Act (hereinafter “DSA”), and the other from the TTPA, which is limited exclusively to the political advertising sector. In practice, particularly from the perspective of a hosting services provider, doubts and potential problems may arise regarding the proper interpretation and application of both regulations. The aim of this publication is to propose a framework for identifying and implementing obligations of a hosting services provider in situations that are subject to both regulations, and to assess whether the TTPA acts as a lex specialis in relation to the DSA or whether the obligations are cumulative. The analysis is based on a comparison of legal norms and soft law documents, and its result will be a model allowing for the design of a unified implementation of transparency obligations in the interface while maintaining compliance with both regimes.