If you go looking for a single EU database that shows you who is paying to target your neighbourhood, your language group, or your voters with political ads, you will not find it. Not because the transparency is missing, but because the premise is wrong. Two different legal instruments create two different repositories, at two very different stages of maturity. Conflating them wastes the one resource you cannot recover: the time before a vote, a procurement hearing, or a statutory response clock runs out.
Here is the distinction that matters, and then a workflow you can run today with what actually exists.
Two repositories, two legal bases
The DSA ad repositories. Under Article 39 of the Digital Services Act (Regulation (EU) 2022/2065), providers of very large online platforms (VLOPs) and very large online search engines (VLOSEs) must maintain publicly accessible repositories of the advertisements displayed on their services. The European Commission describes these repositories — commonly called ad libraries — as providing information on the content of advertisements, who paid for them, the period during which they were displayed, how many users the advertisements reached, and the main criteria used to decide who saw them. The Commission frames them as tools for public scrutiny of online advertising, including safeguarding the integrity of elections, and states that they enable researchers, civil society, journalists and national authorities to detect risks including disinformation campaigns. Source: Commission call for evidence on advertising repositories and the related news item.
The EU political-advertising repository. This is a separate instrument. Regulation (EU) 2024/900 on the transparency and targeting of political advertising entered into full application on 10 October 2025. It requires political ads at EU, national and local level to be clearly labelled and to indicate who paid for them, their costs, and — when targeting or ad delivery techniques are used — the specific audience being targeted. On 12 October 2026 the Commission launched a pilot version of the European Repository for online political advertisements. The Commission says the repository will facilitate the work of researchers, civil society organisations, political actors, electoral observers and journalists in scrutinising the political advertising landscape. Source: Commission page on transparency and targeting of political advertising.
So: the DSA repositories are per-platform, cover ads generally, and are operating now. The EU political-ads repository is a single portal, purpose-built for political advertising, and is in pilot. Neither is a finished civic tool. Both are usable, with discipline.
One more trap to name before we start. The DSA transparency database is not an advertising repository. It collects statements of reasons — platforms’ explanations of content moderation decisions, i.e. why content was removed or restricted. It answers a different question from “who paid for this ad.” Keep the two evidence types separate or your findings will not survive scrutiny.
Step 1: Check whether the platform is in scope at all
Article 39 obligations attach to designated VLOPs and VLOSEs. If the platform your community actually uses — a local forum, a regional classifieds site, a niche messaging app — is not designated, the absence of an Article 39 repository is a scope fact, not a transparency failure. Write that down before you write anything else. The Commission publishes the list of designated platforms; check it against your community’s actual media diet rather than against the platforms you read about in Brussels coverage.
This step protects you from the most common error in civil-society ad monitoring: concluding “nothing found” means “nothing hidden.” Sometimes it means “not covered.”
Step 2: Build a search protocol before you open a single repository
Browsing an ad library aimlessly produces screenshots, not evidence. Decide in advance what you are looking for and how you will know you found it. A workable protocol has four parts:
- Community terms. The place names, language variants, transliterations, and misspellings your community actually uses. Include the terms your opponents use.
- Candidate sponsors. Parties, campaigns, PAC-equivalents, advocacy groups, and the opaque intermediary names that appear as payers. Search the payer field, not only the ad text.
- Time window. Anchor it to a real deadline — an election date, a planning decision, a reauthorization vote — and record the exact dates you searched.
- Platform list. Only the designated platforms from Step 1, in the order your community actually uses them.
Log every query, the date, the platform, and the result count. This log is the difference between a finding and an anecdote. It also lets a colleague, a lawyer, or a regulator reproduce your work.
Step 3: Read each record against the Article 39 fields
For every ad you pull, check whether the record gives you the five things the Commission says the repositories should provide: the ad content, who paid, the display period, the reach figure, and the main criteria used to decide who saw it. Note which are present, which are blank, and which are present but unusable — a reach figure with no date range, a payer name that is a shell, targeting criteria described only as “interests.”
Record gaps as findings. A missing field is a documented fact about the repository. It is not proof of wrongdoing by the advertiser, and it is not proof of coordination, illegality, or foreign interference. Those are conclusions that require evidence beyond a repository record. If your report implies otherwise, the platform’s lawyers will have an easy day and your community will have learned nothing durable.
Step 4: Separate political advertising from everything else
The DSA repositories do not classify ads for you. A record in a platform ad library may be commercial, issue-based, or political in the sense of Regulation (EU) 2024/900 — and the repository will not necessarily tell you which. The political-advertising Regulation’s own definitions and the Commission’s October 2025 guidelines on identifying political advertising are the reference point for that judgment, not the ad library’s category labels. Treat classification as an analytical step you perform and document, not a field you read off.
This matters most for the ads that sit on the boundary: a small-business association buying “issue” ads before a referendum, a trade group running “informational” content during a procurement consultation. Those are exactly the ads your community needs to see, and exactly the ones a naive keyword search will miss.
Step 5: Put the coming EU portal on your calendar, not in your workflow
The single EU political-ads portal is not ready. The Commission’s timeline is documented and worth diarising:
- 9 April 2026: the Commission adopted an Implementing Act setting out the common data structure, standardised metadata, authentication and API for the European repository for online political advertisements.
- 12 October 2026: pilot version of the repository launched.
- 2 December 2026: the call for evidence on upcoming DSA advertising-repository guidelines closes. The Commission invites responses from researchers, civil society organisations, journalists, VLOP/VLOSE providers and the advertising industry.
- Second quarter of 2028: publication of those guidelines is planned, following a targeted public consultation in 2027.
Sources: the Commission political-advertising page and the call for evidence page.
Two practical consequences. First, until the guidelines land, search quality across platform repositories will vary, and that variation is itself a finding worth documenting. Second, the call for evidence closing 2 December 2026 is the nearest open channel for telling the Commission what your community actually needs from a searchable ad repository — for example, that “how users are targeted and reached” be described in terms a non-specialist can verify. If you have run Steps 1–4, you have concrete material to submit. The Commission’s own list of what the guidelines will advise on includes making repositories easily searchable, providing insights on targeting and reach, and making ad content accessible.
What this workflow does not do
It does not give you a single search box across all platforms. It does not tell you whether an ad is lawful. It does not establish who is behind a shell payer, and it does not detect coordination between advertisers. It does not cover platforms outside the VLOP/VLOSE designation, and it does not substitute for the political-ads repository once that becomes operational. Where you need those things, you need different sources: company filings, campaign finance records, national electoral authorities, or the DSA transparency database for moderation decisions — each with its own limits.
A reproducibility checklist
Before you publish or file anything, confirm you can answer yes to each of these:
- Did I record the date and time of every search, and the exact query string?
- Did I confirm each platform’s designation status against the Commission’s list, and note any platform I excluded and why?
- For each ad cited, did I capture the five Article 39 fields — content, payer, display period, reach, targeting criteria — and mark which were missing?
- Did I keep repository records and DSA transparency-database records in separate evidence files?
- Does every claim in my write-up trace to a saved record, a cited legal text, or a named Commission document — and does every interpretive claim say so?
- Have I stated plainly what my evidence does not show?
If you can answer yes to all six, you have something a journalist can check, a regulator can act on, and a community can use. That is the standard the deadlines deserve.
Questions readers actually ask
Is there one EU database where I can search all political ads?
Not yet. The DSA Article 39 repositories are run by individual designated platforms. The single EU-wide repository for online political advertisements, created under Regulation (EU) 2024/900, launched in pilot form on 12 October 2026. Until it is fully operational, cross-platform searching means visiting each platform’s repository and logging your queries.
Does a missing ad from a repository mean it was never shown?
No. It may mean the platform is not designated, the ad fell outside your search terms or date window, the repository’s search is weak, or the record is incomplete. Each of those is a different finding with a different remedy. Document which one you are looking at.
Can I use the DSA transparency database to find ad buyers?
No. That database holds statements of reasons explaining content moderation decisions — why content was removed or restricted. It is a companion source for a different question, not an advertising repository.
What is the nearest deadline I can act on?
The Commission’s call for evidence on advertising-repository guidelines closes on 2 December 2026. It is open to civil society organisations and journalists, and it is the most direct route to shaping what a usable repository looks like before the guidelines are published, which is planned for the second quarter of 2028.