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Article 39 · Regulation (EU) 2022/2065

Advertising repository

A public, searchable repository of every advertisement carried, with an API, retained for one year.

Applies to
VLOPs and VLOSEs
Frequency
Continuous; one year retention after last display

Designated providers must compile and make public a repository of the advertisements they present, retained for one year after the advertisement was last shown, searchable through a reliable interface and accessible through an API.

The repository must record the content of the advertisement, the natural or legal person on whose behalf it is presented and — where different — who paid for it, the period of display, whether it was targeted to a particular group and the main parameters used for that, any commercial communication published under Article 26(2), and the total reach broken down by Member State.

This is the obligation that has produced the most concrete enforcement to date. The Commission’s €120 million decision against X on 5 December 2025 found the repository incomplete and unreliably accessible, specifically citing missing advertisement content, missing topic information, missing paying legal entity, and excessive delays in processing transparency requests.

Worth knowing

  • Advertising repository failures were one of three counts in the first DSA fine.
  • TikTok gave binding advertising-transparency commitments accepted on 5 December 2025.
  • Services carrying little conventional advertising — Wikipedia, and now arguably ChatGPT — still hold the obligation; it is simply satisfied by a near-empty repository.