DSA advertising repositories

The Citead team, updated

In short. DSA Article 39 requires designated very large platforms and search engines displaying ads to disclose ad records through public search tools and APIs.

Definition: Article 39 of the Digital Services Act (DSA) requires providers of designated very large online platforms and very large online search engines that display advertisements to maintain public advertising repositories. These searchable records disclose ad content, advertiser identity, targeting parameters and audience reach.

Key facts

  • Article 39 of the DSA requires a searchable repository supporting multiple search criteria and application programming interfaces (APIs), which provide programmatic access. Records remain available throughout an ad's display period and until one year after its last display.
  • The European Commission's guidance for designated services explains that designation triggers additional duties and gives the service four months to comply.
  • As of 17 October 2026, the Commission's designation list identifies Bing and Google Search as very large online search engines.

Which services must maintain a repository?

Article 33 of the DSA sets the threshold at at least 45 million average monthly active recipients in the EU and requires Commission designation. The additional obligations apply four months after the provider receives notification of that decision. Article 39 covers designated services that present advertisements on their interfaces.

For a business buying advertising space, the repository duty falls on the provider of the designated service. The business's identity can appear in the records as the person on whose behalf the ad runs, or as its payer.

The legal reference is:

Article 39
Additional online advertising transparency

What information belongs in the records?

Article 39(2) specifies the minimum contents. For each advertisement, the required information includes:

  • The record contains the ad content, including the product, service or brand name and the subject matter.
  • It identifies the person or organisation on whose behalf the ad appears, plus the payer when different.
  • It states the period during which the ad appears.
  • It states whether the ad targets particular audience groups and gives the main targeting parameters, including applicable parameters that exclude groups.
  • It gives the total number of recipients reached and, where applicable, aggregate figures by Member State for specifically targeted groups.

The same paragraph also includes commercial communications published on very large online platforms and declared through the functionality described in Article 26(2). That functionality lets users declare that their content contains commercial communications.

Article 39(1) requires reasonable efforts to keep repository information accurate and complete. It also excludes personal data of the recipients to whom an ad appears or could appear. Advertiser identification and aggregate audience figures therefore form part of the disclosure without exposing individual viewers' personal data.

How can a business or agency check a repository?

The access requirements in Article 39(1) provide a practical checklist: a specific public section of the service's interface, a reliable search tool supporting multiple criteria, and API access. An advertiser or agency can compare the recorded content, beneficiary, payer and display period with its campaign records. These checks follow the fields listed in Article 39(2).

A removed advertisement has a specific treatment. Under Article 39(3), when removal or disabled access follows alleged illegality or a breach of the service's terms, the repository excludes the ad content, beneficiary and payer information. It instead contains the applicable information about the decision specified in Article 17(3)(a) to (e) or Article 9(2)(a)(i).

FAQ

Do I need a repository for my business website?

Article 39 assigns this duty to providers of designated very large online platforms or search engines that display advertisements. Buying ads for your website can place your business's identity in the service's repository.

How long can I consult an ad's record?

Article 39(1) requires availability throughout the display period and until one year after the ad's last display on the service. Paragraph 3 sets the special disclosure rules for ads removed for alleged illegality or incompatibility with terms and conditions.

Can I see who viewed an advertisement?

Article 39(1) excludes viewers' personal data from the repository. Paragraph 2 requires total reach and, where applicable, aggregate figures by Member State for the targeted groups.

Sources

  1. European Parliament and Council, "Regulation (EU) 2022/2065 (Digital Services Act)", 19 October 2022
  2. European Commission, "DSA: Very large online platforms and search engines", updated 19 May 2026
  3. European Commission, "Supervision of the designated very large online platforms and search engines under DSA", updated 15 October 2026

Check how a page reads to answer engines. Open the GEO score analyzer

Test a page and see what to fix first

The analysis usually takes less than 10 seconds and needs no account.

400,000+ pages scored in the public benchmark