Digital Campaigning without Social Media Ads in Europe: Political Visibility under the TTPA, with Jochen König

[MUSIC] Hey everybody, welcome to the social media and politics podcast. Bringing new expert insights into how social media is changing the political game. [MUSIC] I'm your host, Michael Bacetta, associate professor of communication at Loond University. [MUSIC] Remember, you can follow the show on X at SMNP podcast or visit us on the web at socialmediaandpolitics.org. [MUSIC] All right, y'all, thanks so much for tuning in. In this episode, we're going to pick up on one of the recurring sub-themes of this podcast around European Union regulation, and in particular, focus on the TTPA or the transparency and targeting of political advertising regulation. And this is something we talked about in the year-in-review episode, around minute 41. If you want the whole backstory, but the brief summary is that the TTPA increases disclosure requirements around political ads, and it also limits the ways that data can be used for micro-targeting. That's kind of the simplified version. And what's interesting about this is that even though this initiative has been in the works since at least the Cambridge Analytica scandal, in 2025, both Google and Meta decided that they wouldn't allow political ads on their platforms in Europe. And the reason for that, according to Meta, is that it's too burdensome, and the interference with how data is used to target ads will negatively impact user experience on the platform. And so while this is a very niche and wonky policy topic, what's interesting is that we haven't seen many elections since last year, and therefore we don't really know yet how parties and campaigns will respond to this limitation. The advertising budgets are still there. The digital budgets are still there. Campaigns still need to reach voters where they are, which is often online. So the question is, how will campaigns move forward? Will they focus on more organic strategies? Will they focus on different platforms? Will they focus more on offline campaigning or go more for earned media plays? Who knows, but we will see how this develops in the future. So I wanted to bring in an expert to discuss this. And my guest today is Jörgen König. He is a co-founder and CEO at Cosmonauts and Kings, one of the leading digital political consultancies in Europe, based out of Germany. And Jörgen is on an expert group for the European Commission to give feedback and provide advice on the implementation of the TTPA. So he's perfectly positioned to discuss what is happening right now, both on the regulatory and implementation side, but also from the perspective of running a digital political consultancy. How are they looking forward in an era where digital political ads on meta-s platforms are off the table? So we'll talk about that. We'll also get into the weeds for U-Policy Wanks out there around the definition of a political ad, getting into article number three, paragraph two, and combo with article number eight. We'll also talk about what Jörgen thinks are some potential alternatives to the micro-targeted ad format that still allows for political visibility to occur on meta-s platforms. And just in general, get a sense of what is happening right now on the ground around TTPA in what could be in hindsight a very transformative moment for political campaigning in Europe. So without further ado, let me turn it over to Jörgen Kuhnig. Again, he is a co-founder and CEO at Cosmonauts and Kinks. Jörgen, thanks so much for taking the time out. Welcome to the social media and politics podcast. Thank you very much for the invitation. It's a pleasure to be here. So before we dive into the TTPA, I thought we could set the stage a bit with discussing the state of digital political advertising in Germany because unlike in the US, German political ads aren't primarily used for fundraising. So before platforms restricted these ads, what roles did they serve for German campaigns and how central were political ads to party communication? The first time digital political ads on Facebook played a noticeable role in the National Wide Campaign was during the 2017 federal election in Germany. And since then, social media advertising has increasingly become a reach instrument for both national and local elections. Parties and campaigns use it to make candidate known, amplify campaign messages and reach voters based on geographic, socio-democratic and interest based parameters. And before platforms started restricting political advertising in the EU, campaigns in Germany use digital ads primarily in three ways. The first, as I mentioned, is message amplification. So campaigns would use paid advertising to ensure that key campaign messages reach a broad audience, especially during the final weeks before an election. Parties, campaigns and candidates use it to make the candidates known to amplify the messages and reach voters based on the social geographic parameters, especially like in the constituency and the interest based parameters. The second function was mobilization of specific voter groups. So parties would run targeted ads to encourage turnout among supporters or to mobilize particular demographic groups around specific issues. And compared to the US, the level of microtargeting was, let's say, very moderate. And then the German political culture and data protection was already in place limits on how granular you could target specific voter groups. And the third role was issue communication between elections, government actors, ministries, civil society organizations, but also corporates and interest groups use digital ads to communicate about policy initiatives and preferences in that sense, political advertising was not only a campaign to but also part of a broader political communication ecosystem that also played a role then in public affairs. And at the same time, we haven't seen a gradual emergence of microphone raising, especially from some parties and movements that try to adopt the campaign techniques from the United States. The focus was not that much on social media ads. It's more around mailing, but digital ads and social media were increasingly used to mobilize more donations online and variates from party to party, but some made quite impressive compared to quite impressive numbers in Germany. But compared to the US, there still remain small part of the campaign financing. So overall, digital political advertising became an important but not dominant pillar of party communication. It complemented organic social media, traditional media coverage and full campaigning. What changed in the last years that social platforms became the central arena were political discourse increasingly happens. So that made digital ads more strategically relevant even if the budgets remained relatively small compared to the US. So would you say that they actually worked to kind of intervene in those debates or kind of set the tone of those debates? Because I was looking into this and I saw that you can actually can raise money in Germany with quite substantial amounts. So even though you could use these small-dollar or small-Euro donations, it seems like the parties could actually work to jump into these debates where they were happening online. Yes. And if you're looking towards fundraising, interestingly, I know some cases where political parties and strategists decided to do microfund raising and actually use then the raised money for media budgets, especially for digital media budgets. So yes, they could jump into it, but it's also depending on the political culture, right? But we don't have this donation culture in terms of supporting a political party if you are not either a member of it or very clear for a very long time a supporter. But nevertheless, in certain political moments of the last years, it also shows that at Hock, microfund raising works, it varies from party to party, but there are parties who are increasingly using it. Yeah, interesting. So it seems quite above board. But meta and Google in October of last year decided to stop offering political ads rather than complying with the TTPA. And according to meta, the reasons were broadly that the TTPA introduced "unworkable requirements and legal uncertainties" and then more specifically that it would disrupt their advertising product by showing users less relevant ads. And so at a high level, do you think that meta's reasoning is fair and justified here? Or do you think that there's more to their decision, thinking about this kind of broader power play between platforms and EU regulators that we've seen over the past couple years? Yes. My short answer would be meta's argument is partially valid, but it's definitely not the full story. So TTPA does introduce quite complex requirements around transparency, sponsored identification, labeling and public ad repositories. From a technical and operational perspective, implementing that across the EU is not trivial, especially because one of the core challenges of the regulation is still the definition of what actually counts as a political advertising and what not. So the boundary between political communication, issue advocacy and general public affairs and messaging can be quite blurry. So yes, there is a real compliance challenge here, but at the same time, political advertising represents a very small share of the overall advertising revenues for companies like meta or Google. So economically speaking, it is relatively easy for them to withdraw from that market rather than adapt their systems. And that's why I think there is also a broader strategic dimension to this decision. So first, let from sometimes use these kinds of moves as a signal in regular regulatory negotiations. So even new regulation creates friction for the business model with drawing from a specific product can also be a way of demonstrating the consequences of regulation in creating pressure for future policy adjustments. And in this case, banning political and social issue ads altogether has an immediate effect on politicians themselves. Right. So because it directly affects them on how they can communicate with the voters and the public sphere. And second, there is a deeper democratic question, I think, by banning political ads entirely platforms can claim neutrality and reduce regulatory risk. But at the same time, the platforms and algorithms are already play a fundamental role in political opinion formation and democratic societies. And political discourse is happening on these platforms regardless of whether ads are allowed or not. So in a way, withdrawing from political advertising can also be seen as withdrawing from certain responsibilities, I think, and the platforms remain central infrastructure for democratic debates. But they step back from participating in a regulated and transparent framework or political communication. Yeah. And in a way, it kind of takes away their ability to exactly as you were saying, get into the messaging and the issue communication. That's a, yeah, super interesting perspective. But you know, what I'm curious about is from the regulators side, I mean, we haven't seen the same level of disclosure demands around commercial advertising, which is obviously much more of a money generator for these platforms. And it's interesting because the same systems that deliver political ads are also delivering probably more frequently, probably with more sophistication and probably with more impact, I would say, on the commercial side and getting people to buy products and persuade them about their attitudes towards certain commercial incentives. So why do you think that political persuasion is kind of viewed as especially high risk, even though commercial advertising relies on the same systems and can also shape behavior at scale. That's a very important question. And I think it's really goes to the heart of how regulators think about TTP and why they're also implemented. But it will persuasion is treated as a specially high risk, not because the technology is fundamentally different, but because the democratic stakes are different. So commercial advertising usually tries to influence what people buy. Political advertising can influence what people believe how they vote, whether they trust institutions, and ultimately, how democratic power is distributed. Right. So from a regulatory perspective, the concern is not only about targeting as a technique, but about the potential impact on democratic legitimacy, I would say, and I remember something the well-known German pain strategist Frank Stahls, which I'm very happy. So he's a friend of mine. One said at a political tech conference in Berlin back in 2018 that we co-hosted. And he said, politics is not about selling shoes, especially not in Germany. We talk about data in context of political opinion building processes. And that sentence really stuck with me because if a shoe brand targets me very effectively, it may influence my consumer choice. But if a political actor targets people with high-detailment message designed to mobilize for your resentment or misinformation, that can influence collective decision-making in a democracy and even destabilize societies and democratic systems. And that has seen as a qualitatively different level of risk. And at the same time, I believe that the debate should not stop at regulating political ads alone. The real issue is much broader platforms and the digital infrastructures. They have become central arenas of democratic debates. And in many ways, the function today is part of the public sphere. And if that is the case, then they also carry a certain responsibility. Right? So I strongly believe we need regulatory frameworks that ensure the digital public sphere remains open fan trust worthy. And political actors must be able to reach citizens and voters to mobilize participation and to amplify democratic discourse. So that's the legitimate and necessary part of democracy. And looking ahead, this challenge will only become more complex with the rise of AI, which already is beginning to transform how political messages are produced, personalized and distributed at scale. It will make political communication more automated, more adaptive and potentially more persuasive. And that creates enormous opportunities for democratic participation, but significant risk if these technologies are used without transparency and accountability. So even if the rules under the TTPI are significantly stricter than in commercial advertising, I think that reflects the fair democratic principle when communication can influence elections and public trust and institutions society has every right to divide a higher level of transparency and responsibility compared to commercial advertising. Right. And I mean, the working model for the past couple years has been around self regulation of the industry. Right? So meta has introduced a number of, you know, specifically for political ads, sort of mechanisms to increase transparency. And you've argued that meta in particular has a responsibility to host political ads because the TTPI is actually built on these measures that meta introduced like verified political accounts or ad approval processes. So could you unpack that argument for us? Where does the TTPI map on to what meta has already built? And then where might the TTPI be asking too much from that existing and transparency infrastructure? TTPI did not appear out of nowhere. In many ways, the regulation is building on transparency mechanisms that platforms like meta already had introduced themselves after the Cambridge Analytica scandal. And for example, meta introduced several measures that later came the blueprint for regulatory thinking first, advertised the verification. So political advertisers had to verify their identity and location before being allowed to run political ads. And second, there's collater requirements where every ad had to show who paid for it. Third, the ad library, which stores political ads in a public archive. So researchers, journalists and citizens can see which messages were shown and to whom. And finally, meta already required and approve the process or legal and social issue based ads. So many of these ideas are directly reflected in the TTPI regulation. The regulation also requires that political ads clearly just clear through sponsored the ad, how it is targeted and in which political context it is used. It also requires that political ads are stored in a public accessible repositories and that users understand why they are seeing a particular ad. So in principle, the core philosophy of the TTP is not new to matter. And transparency around legal ads is something the platforms themselves already acknowledged as necessary several years ago, where things become more complicated as the scale in legal precision that TTPI requires. So the regulation turns what were previously platform policies into legal obligations. Platforms must now verify sponsors in a legally robust way. And with contracts, provide standardised transparency information, document targeting parameters, maintain auditable records of the regulators across all of you member states, and violations can lead to significant penalties. And that creates challenges for them. First, is the legal risk and definitional uncertainty. The regulation curve is not only election ads, but also issue based political communication related to legislation or public policies. That makes it harder for platforms to determine what counts as a political ad in the first place. Second challenge is the operational complexity. Platforms must ensure compliance across very recommended political landscapes with the member states with different languages and very different political actors and landscapes. And the third major challenge relates to the targeting restrictions under TTPA, which is a major major issue for these platforms. So the regulation requires that if personal data is used for political advertising, the data must have been directly collected from the user. And the user must have given explicit, consents specifically for political advertising purposes. And platforms like matter typically rely on behavioral signals and in field interests that are generated across their ecosystem and users usually consent to general advertising, but not specifically to political advertising based on their personal data. So in practice, TTPA forces platforms into a very different model, either they build completely new consent infrastructures for political ads or they limit targeting too much broader criteria like geography and contextual placement. And that creates a real structural tension for them, because political ads are suddenly expected to follow a completely different data logic than the rest of their digital advertising system. I'm thinking about this idea of the public sphere and how it relates to that that targeting change, because and maybe I'm simplifying here, but it seems like those targeting requirement changes mean that users would essentially have to opt in to being targeted, right? They would have to give their informed consent to be targeted. And then that's not really a model that would support broad open democratic discourse, right? Because it goes back to what you were saying about who donates to German parties, those who are, you know, part of the party membership. Those are the people who would sign up to be targeted by the parties. And so I wonder if that is, I don't know, again, I'm reflecting out loud, but I wonder if that has something to do with it where if you have to target based on much, much broader indicators, there's an argument that that's actually good for the public sphere because it keeps things very open and public, the party messaging, rather than targeting specific blocks of voters with certain messages. Yes, you could argue that totally, but I think we have to differentiate between the transparency and accessibility to bets and to certainly know which target groups are in it. And the other one is which data is targeting being done for political advertising, right? And especially in light of the German history, I'm very reluctant and it's in general and very important and distinguished topic to say, what kind of data do we want to share and what kind of data do we want to make accessible and how aware are we of that? And I would say that in general, the use of personal data in a way that we saw it in, let's say, between 2016 and 2020, because over the year, the platforms also more and more restricted the targeting parameters within their systems. I think it's always a very granular decision and from my perspective, I think we do primarily geographical targeting. We do primarily contextual targeting. We do primarily social demographic targeting that works for me and it also had worked over the last year, so it doesn't really make a difference for my end. But for the platform, it makes a big difference, right? Because you also have to collect the data directly from the user. So you're not allowed to aggregate data from third parties. You're not allowed to aggregate data from any other place. So you have this immediate data collection responsibility if you want to use personal data. So the level is extremely high. And I think that the one thing is to restrict the usage of data. The other one is to make sure that the usage of data is transparent. And I think that are two different things. But in general, the most important thing, and that's the good thing about TTPAs, to increase transparency, to increase accessibility, hopefully, on the long run. Right. And so I think that brings us to the idea of what that actually looks like in practice. So for meta, a key friction point seemed to be the detailed reporting on each individual ad. And then keeping them up to date with like over 15 categories of information. And like, some of these are quite simple. It's, you know, who sponsored it and one of their contact details. But other categories seem to be more demanding, like targeting explanations. And I'm just wondering if the logics of how campaigns operate and what the TTPA is demanding are kind of at odds. Because what the TTPA wants is more reporting about why you're targeting one of the explanations for why you're doing this. And I feel like sometimes campaigns are really just more dynamic and iterative. They're testing a lot of things. They're kind of throwing pasta at the wall and seeing what sticks. And I'm not sure that that logic fits with. Here's my detailed argument for why I'm targeting this group versus that. So I'm just wondering if you think that those reporting requirements and how campaigns actually run on the ground are kind of incompatible. That's a very good observation because it highlights one of the real tensions between how digital campaign works and how regulation typically works. Right. So digital campaigning is inherently dynamic and iterative. So campaign teams often run multiple advions, test different messages or audiences and adjust them depending on performance or developments in the campaign. Right. So the logic of digital advertising is built around experimentation and optimization. But it also important to keep in mind that in the European context compared to countries like the United States or I would say now even UK, the scale of ad variations and testing that I have seen in Germany and in other European countries is actually much more limited. So campaign budgets are smaller fundraising plays a much smaller role in agriculture is generally more cautious when it comes to highly aggressive testing strategy. So the level of experimentation that regulators are dealing with in Europe is already significantly lower than for example, yet. And at the same time platforms like matter already introduced a approval and transparency process for political ads several years ago. Before a political ad could run, it had to go through an approval process. Sometimes that review took just a few minutes. Sometimes it takes several hours. Campaign teams were only used to work with those constraints and planning that campaigns accordingly to set up the transparency register for each ad and to build an infrastructure where you comply with TTPI. That's initially quite substantial, but it's manageable and it's also manageable in terms of technologies and software possibilities that we have right now. And what TTPI now does is essentially turn parts of these platforms based processes into legal obligations. So the regulation requires detailed transparency information for each ad who sponsored it right. So the political context, the targeting criteria as you mentioned, the amount, spend explanations, why users are seeing this ad and all this must be documented. So yes, there is a friction between a fast-moving digital advertising system and regulatory framework that requires structured transparency and recommendation. But I would say the gap is possible to close because platforms already build much of these infrastructures. The main difference now is the level of standardization, legal accountability and documentation. Then ultimately, the reflects a broader democratic trade-off. Digital campaigning thrives on speed and experimentation, but democratic transparency requires the citizens understand who is trying to influence them and how. If political persuasion happens in highly personalized digital environments, then transparency cannot remain and after thought it has to become a part of the infrastructure of political communication itself. Digital campaigning optimizes for speed and experimentation while democratic regulation optimizes for transparency and accountability. The challenge of TTPI is to make those two notjiks work together. Yeah, and what I'm getting from hearing you speak is that it's really about these legal requirements that I think platforms and regulators were trying to work in this model. And then once the legal framework comes in, it takes on a whole nother level of seriousness and consequences. And that brings me to my next question, which is about compliance. Because compliance with the TTPI is one thing, but then non-compliance is another thing. And researchers and watchdogs who've been monitoring political ads have found clear examples of social issue political ads still getting through meta-system in Hungary and in Germany, for example. So do you think that the restriction of political ads is even technically enforceable, or are these systems just too easy to circumvent? The monitoring you mentioned is extremely important. And researchers like Dr. Fabio Voter from the University of Amsterdam are doing pioneer in work in detecting political ads that still appear on these platforms like meta-despite existing restrictions so shout out to Fabio. But I think it's important to distinguish between two different types of political ads. First, they have clearly identifiable political ads. For example, ads run directly by political parties, candidates or campaign organizations. These ads are usually relatively easy to classify and regulate because the actor behind them is known and the political intent is very explicit. So you can identify them quite easy. But there's a second category of political ads that is much harder to detect. These are issue-based ads or political messages that are not clearly identifiable at the political advertising coming from the question like who's the sponsor, what's the intent of it. So they may come from NGOs, advocacy groups, companies, interest groups, unions or other actors. And they often address political issues and topics like climate policy, taxation, migration without explicitly supporting a specific candidate or party. And the second category creates most of the enforcement challenges. And that is exactly whether the debate becomes interesting because TTP assumes that political advertising exists in both forms and therefore focuses on transparency and accountability platforms like meta. On the other hand, they're trying to solve the problem by just completing banning any political or social issue ad altogether. But banning something that is partially clear and partially ambiguous will almost always create loopholes and inconsistency. So the real question is not whether enforcement will ever be perfect because it won't be. The real question is which regulatory approach creates more transparency and accountability. A regulated system where political ads are visible and documented. All system where political messaging still circulates on platform but outside of any structured transparency framework. I personally believe transparency based regulation like the TTP is more realistic approach. Political communication will appear on these platforms regardless. And the goal should therefore be to make it visible and accountable rather than assuming it can simply be removed from the digital public sphere because now that they also, for example, matter in terms of the ad library is turning that a little bit down, I would say, or closed it. in terms of political ads, how they are detecting it. And the irony on the one hand is, oh yes, there were a couple of ads now that went through the system. So on the one hand, these tech companies have the most sophisticated technology to monetize and to detect our attention span down to a second. And based on that, in milliseconds, changed the algorithm in the recommendations. But they are not able to detect certain political ads. So I don't believe that it's a technological question. It's more like how serious you take it and how afraid you are in terms of consequences. Absolutely. Because meta mentions explicitly that if there are ads that go ahead and run and they catch them, they'll be rejected. And then repeat offenses can lead to permanent advertising restrictions. And that seems kind of like a slap on the wrist, right? But are there any other consequences for these violations? I mean, you mentioned it from the TTPA side. Is there something in the TTPA or the DSA that really has teeth? And where is that actually directed? Is the penalty directed to the platform or is it directed to the advertiser? So the penalty is basically directed to everybody. TTPA is not saying like if there's a donation, the sponsor is responsible, right or the provider of political advertising services or the publisher, the publisher in this case also would be a platform or a media site. But we also have to keep in mind that TTPA is not fully enforced yet in most U.P countries. So TTPA is in place and it's legally binding. But many nationals, supervisory authorities responsible for the enforcement are still being designated. And the EU transparency repository for the global ads has not even been fully implemented yet. It's not even online. So the system is still in a transition phase and will take some time until the regulation upgrades at full scale. However, once the enforcement infrastructure is in place, the mechanism is quite clear. Violations like political ads that researchers detected, such in the case you mentioned, Hungary or Germany on matter, can be reported to the national competent authorities. And from that point on, it becomes the responsibilities of those authorities to investigate and enforce the penalties provided under the TTPA. So platforms and publisher have a responsibility and can also be obligated and have a risk for paying fees and penalties because they're responsible to make sure that if there's political advertising on their systems, on their platforms, on their sites, it has to be TTPR compliant. And if it's not, they also are responsible for it. Each EU member state designates a national authority that oversees compliance. If companies platforms or the political actors or the service provider of political advertising services violate the transparency or targeting rules, regulatorys can impose significant administrative fines. The regulation requires that penalties must be effective, proportionate and persuasive. And in serious cases, they can reach up to 6% of the annual work right turn over of the responsible entity. But financial penalties are not the only tool. Authorities can also impose corrective measures. For example, they can require platforms or advertisers to stop running specific political ads, correct transparency, informational comply with reporting and documentation obligations. So there is also a cross-border coordination between regulators, which become relevant when political ads target audiences in multiple EU countries. Yeah, so many frameworks. Yes, so many frameworks. And so overall, the enforcement framework is actually quite strong. I would say the philosophy behind the TTPA is similar to other recent EU digital regulations, right? High transparency requirements combined with potentially very significant financial penalties if actors fail to comply. And right now we are still in the implementation phase. But once enforcement systems is fully operational, the TTPA will have real regulatory teeth. Yeah, as you mentioned, I mean, this is still sort of being rolled out in terms of enforcement. And I don't know if the European Commission really anticipated the full pullback of meta and Google. But they have established the European Commission and expert group to discuss the TTPA and you're part of that expert group. And so I'm curious without, you know, disclosing anything confidential, what's your sense of the temperature right now? Are regulators and platforms entrenched in their positions and talking past each other? Or is their room for compromise and even altering the framework or the penalties? Yes. So the first meeting took place at the beginning of March, 2026. To be honest, the first meeting of the expert group was still quite administrative in nature. So it's probably truly to draw now strong conclusions about where the discussions will ultimately go. The group is primarily designed to support and advise the European Commission on the implementation of TTPA. At this stage, I also do not expect major short-term changes either to their regulatory framework or to the platforms current decision to withdraw from publicly advertising in the EU. The situation is still unfolding and implementation will take time. From the first meeting, I took away, let me put it this way, I took away two early impressions. My first impression is that one concern I have is that I'm not not yet entirely sure, trying to make this very diplomatic side. I'm not yet entirely sure whether there is a full awareness of the practical uncertainties around the definition of political advertising. In other words, when exactly an ad falls under the scope of TTPA and when does it not? These definitional questions have significant practical consequences for the publishers, for the advertisers and for regulators. In my view, providing more clarity here relatively quickly will be very important. So I'm looking from my perspective towards the direction that is and also something I actively advocate, that the expert group together with the Commission continues to develop additional guidance for the implementation of TTPA to help to reduce some of the current uncertainties. And let me put it this way, I'm also optimistic that we will see meaningful progress and access on the EU transparency repository for political advertising in 2026. So my overall impression is that the stage that we are still very much in a holy faith of the implementation, the expert groups meets at least four times a year. It's extremely interesting and very diverse group of experts, I think they're 13 members. It was a very active discussion even on the first meeting. So everyone came in with a lot of topics with a lot of issues to address and a lot of concerns. And I'm very positive that it goes into the right direction. Is the Commission open to that and seeing the challenges or just as I get the sense from looking towards also the member states by saying, okay, that's now TTPA and you have certain possibilities to implement TTPA in your member states. But I think it's important that the awareness of the uncertainty, yeah, what is falling under the scope of TTP and what not is the first step that should be addressed and not the first step of the TTPA to the repository to I don't know, build in a block in for a tool or whatever. So yeah, I'm extremely honored and happy to be part of this group and I was very happy to be to be nominated for it and looking forward to share as much as I can forward how the consultants the process with the Commission goes on. I think it's really interesting you bring up the definition of a political ad because if I recall correctly, that was like the big thing that the TTPA brought. It was like finally, we have the definition of political ads. We've sorted it and it seems like now it's back on the table that okay, we've got to go and look at this definition again. Yes, so we have an article number three paragraph to the definition of political advertising and if you allow me I'm just going to read it. It's quite long but just to get a sense of it, right? So TTPA defines political advertising as it means the preparation, placement, promotion, publication, delivery or dissemination by any means of message normally provided for remuneration or through in-house activities or as part of a political advertising campaign by or on behalf of a political actor, blah, blah, blah, which is liable and designed to influence and this is not extremely important. The outcome of an election or referendum voting behavior or that's the most critical part, legislative or regulatory process at Union National Regional or local level. So the definition on the one hand makes very clear following in the TTPA who's a political actor and who's not and who is defined as a political actor and TTPA is very obvious and very clear and very distinguishable. That's great. The uncertainty results out of the last part, like also influence the outcome of an election that can be very obvious or more subtle, voting behavior the same and the most challenging thing is to influence a legislative or regulatory process at the Union National Regional or local level. And the thing is that you have to see the definition together with article number eight because article number eight then is about the identification of what is political advertising and in this article that is related to the definition and article number eight. 3.2.b, names eight different dimensions, like content of message, sponsor of the methods, the language, the context, in which the message is convened, the means by which the message is prepared place promoted, the target audience and the objective of the message. And if we then furthermore look towards the guidelines of the commission for the implementation of TTP A, on the one hand TTP A is very clearly, you need a strong connection between a regulatory process, a policy process, add a political ad that TTP A gets applied. But it creates a lot of uncertainty because when does influence start and when does influence start to either for example, initiate stop or promote certain policy proposals or preferences. And does this happen if I for example, talking more in an abstract way about promoting democratic values or I don't know, promoting tax questions, my taxes have to go up or down or left or right. And there's a level of uncertainty that is still there. I think we already see step by step a more differentiated definition that is going to help, especially NGOs, interest groups and corporates that also want to place political topics. But these two articles to gather with a guideline still leave a lot of room of interpretation, which leads to the moment that sponsors have to check their ads and their campaigns case by case and really get deep into it and do kind of a yeah, what I also do for clients is that I develop an argumentation why it is TTP or why it is not TTP A. Yeah, I know it's a different world than research, but it's trying to instrumentalize something that is so indirect and diffuse. There's just too many steps when it comes to influence like an ad influencing a policy. It's hard to just measure those lines. So I'm going to circumvent from commenting on that. But I want to pick up on something you said earlier about this idea that politicians are directly affected by this, right? And it gets to this idea of who has the power to control political visibility online. Is it the parties, the politicians, is it the regulators, is it the platforms? And you've argued that political visibility is vital for democracy because it is the foundation of trust. And if the current model lessons political visibility because you know, the main distributors, the platforms of this content have sort of stepped back, what might a more democratically positive alternative look like? I think instead of banning political advertising, all to get the like the platforms are doing it, they could take a different approach and reset baseline of political visibility on their platform. So one idea that I have, and it's not solving this very complex and difficult question, but just to show that there could be ideas in small steps towards it that lowers the challenges that parties and candidates and members of parliament are now facing because they cannot reach on these platforms via ads, the constituency or citizens. And also, yes, even if it's hate ads, they now have to apply to the algorithm logics of the platform. So one idea would be to guarantee that very fine political actors, for example, ministries, institutions, elected officials, political parties or registered candidates can reliably reach the citizens who have chosen to follow them on the platform. So today, even if you follow a political representative, the algorithmic systems of often decide whether you actually see the post or not in a democratic context, that's problematic because citizens who deliberately choose to follow their representative should not depend on opaque algorithmic filtering. So platforms often argue that algorithms prioritise the most relevant content for the users. But when it comes to democratic communication, the relevance of political information should not primarily depending on algorithmic ranking. If a citizen clearly follows a ministry and elected representative or candidate or party, the relevance of that communication has already been established by that decision by that choice to further this account. And platforms could therefore guarantee that content from their verified accounts reaches, for example, 100% of their followers organically without any paid promotion. And the ironies that, for example, matter has a system already in place because you had to register for political advertising. And for a limited number of posts, for example, let's say three posts per week, this would ensure that essential democratic communication reliably reaches citizens who have chosen to follow these actors while still allowing platforms to maintain their broader algorithmic systems for the rest of the content ecosystem. So just to put them these accounts that verify the accounts in another algorithmic system logic, where advertising is still necessary, for example, when candidates want to build an audience during a campaign, platforms could introduce only one standardised and fully transparent advertising format that could also be TTPI compliant. The purpose would not be mass persuasion, but simply helping political players actors to build sustainable communities of followers, especially as members of parliament candidates and parties. On matter, this could take the form of follower ads and on YouTube live channel subscription ads, promoting official political or institutional channels, hate reach then would serve the purpose of community building rather than highly personalised persuasion. And different platforms could adapt this principle in slightly different ways. Facebook and Instagram could guarantee the delivery of a defined number of posts. For these accounts, that the followers see each week and limit the possibility for advertising for follower growth on YouTube, all content from verified channels could automatically reach subscribers supported by transparent subscription ads and search platforms like Google official institutional sources could certainly be prioritised during elections, which Google did in the past. The advantages of such a model would be quite clear because political communication would remain visible without relying on complex targeting systems. And it also wouldn't rely on money, wouldn't rely on financial resources. Transparency would simpler, regulation easier to enforce and citizens would be able to clearly see who's communicating with them on these platforms. And at the same time, platforms would demonstrate also responsibility instead of withdrawing from political ads and political communication basically altogether. Or to put it simple, the goal should not be less political communication online, but more visible and accountable political content. Yeah, I like that. On two fronts, one is that in these discussions, the organic content often gets left out. So you're kind of looking for a, in a sense, a full boost of organic content. And it also separates it from the commercial incentives we were talking about earlier, because this would not make sense for, to give this opportunity to a brand, right? Yes, because that, and that's where Meta is making its money. So this is kind of like a carve out for political actors to get this super boost or kind of direct mail if you want for free, because that's not really going to affect the platform's bottom lines in the first place. So I, I like that idea a lot, but under the model that we're sort of currently working with and that may change, the TTPA will influence digital political communication in Germany and in particular political consultancies like yours. And so I'm curious, if targeted ads remain restricted, how does the nature of digital political consultancy change? Like what's becomes more important in the absence of ads? And is there anyone who stands to kind of benefit and lose from those changes? Yes, very important question, because it definitely will shift and already is shifting the way how digital political communication works. And if targeted political ads becomes more restricted, organic visibility and content strategy will become much more important than political actors will need to invest more in building their own audiences and communities on platforms rather than relying on hate amplification to reach voters quickly during campaigns. It means that cross credibility and long-term communication will matter more than short-term ad campaigns. Political actors will need to develop consistent digital presences, create content that resonates organically with citizens and engage in a more direct dialogue with the audiences. At the same time, I think it's also important to acknowledge that when we see most of the political content on platforms, it's like it's like being at a party and standing at the corner and being the narrative talks about politics where everyone is having a very good time. And sometimes it feels like that that political content in the past was kind of disturbing. The entertainment on these platforms or the outrage on these platforms. And now that the organic social first content also has to adapt to the or even more has to adapt to the algorithmic logic and also to the triggers that makes content viral that also brings a lot of risk with it. For consultancies like ours that actually shifts our focus more towards strategic communication, content development, data-driven understanding of digital discourses and identifying very early trends on platforms, especially at the moment on TikTok to see with social first content how we can get into it right now. And in many ways, it strengthens the importance of social first communication, narrative building and understanding how information is spread organically on these platforms. At the same time, if platforms maintain their restriction on political ads, pro-crematic advertising is already becoming one of the few digital distribution channels that can still operate in a TTPA compliant way. In that environment, targeting is already relying much more on geographic parameters, for example, personal co-targeting and contextual targeting, meaning ads appear next to relevant content rather than being targeted through personal behavior data. In the short term, this could lead right now and we see this to higher campaign costs and more complex media planning, because the accessibility to these ads forwards is not as easy and convenient as it was previously on these platforms. If you think about a really low-cropane in a rural area, somewhere in rural, and you want to reach voters there during election campaign and you don't have big money for billboards, you don't have maybe even in this countryside and infrastructure for digital out of home. And the newspapers, maybe there's one maximum in the honor of how many people read the newspaper today anymore. So how do you reach them? And yes, you can say, oh, political advertising and matter and so on is bad and it's not worth it. Yeah, but if you're in a rural area and you're running a profit, what is your possibility and then back then these ad formats actually helped based on postal co-targeting to reach citizens on these platforms. And now with pragmatic advertising, we are not at the stage right now, but I'm very optimistic that the market is moving this direction because the market has to move the budget is there to just shifting that we make these ad formats more accessible, ironically more democratic, but even low tech campaigns with smaller budgets have the possibility to use it. And this leads to another important point that will likely be winners and losers in this new environment actors who already have strong visibility in terms of the savage political parties well on candidates may benefit from it right because there we have a large audience at the same time you candidates more parties and civil society initiatives might find it harder to build visibility. If now certain performance are not accessible, but stepping back, I think the bigger transformations actually about social first communication and the growing role of artificial intelligence. So political communication is increasingly shaped by how narratives content and information most organically through these platforms and in that environment, the role of agencies and consultancies changes as well. It becomes less about simply distributing messaging through ads and more about helping put the actors navigate the digital public sphere and the standing how this causes involves how algorithms shape visibility and how communicate authentically and effectively in a complex online environment. In many ways, the future of digital political consultancies not primarily about advertising. It's about navigating the public sphere in a social first and an eye driven communication that's going. Absolutely, I think that the TTPA is kind of this niche, but very, very important interaction between the platforms regulators and consultancies like yours is it's fascinating and I think that the platforms are agile consultancies like yours are agile and there's a lot of uncertainty about. How this will shift digital political communication, but I think it will be looking back quite transformative and I know you're on the the front lines of this debate so yuck and thanks so much for taking the time out and sharing your insights with us. Michael, thanks so much for having me on the podcast, you're listening to it for quite a while and it's great to be here for the first time. I've just been speaking with yuck and koonik co founder and CEO at cosmonauts and kings. And that's a wrap for this episode of the social media and politics podcast. Thank you so much for tuning in and thanks to rick guard koonik, no relation for setting up this interview. As you may have noticed, pods are becoming more interspersed because I am totally in the weeds so just keep an eye out on those feeds for the next episode. Until then, I'm your host Michael Pasetta signing off from alama. See you next time.