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A Systematic Review of VLOPs’ and VLOSEs’ Ad Repositories under the EU DSA

Snurb — Friday 11 September 2026 20:45
Politics | Government | Search Engines | Social Media | ECREA 2026 | Liveblog |

The next speaker at the ECREA 2026 conference in Brno is by Leon Xiao, whose focus is on the regulation of Very Large Online Platforms and Search Engines (VLOPs and VLOSEs) by the EU Digital Services Act; these are defined as having more than 45 million active users in the EU (10% of the total EU population). 25 such platforms had already been identified (two of those VLOSEs, the remainder VLOPs); three more were added recently (including ChatGPT, as a VLOSE).

Under DSA Article 39, these now need to provide a publicly accessible, transparent, and searchable repository of advertising on their platforms; this must be searchable using multi-criteria queries and available via API, must include ad content and metadata, must identify targeting and reach, and must retain records of removed ads. These requirements have been implemented in very different ways by the different platforms, however.

This study, then, explored systematic compliance gaps across different platform practices, and establish the evidence for further research and compliance enforcement. It focussed especially on video game advertising, as well as a range of other products and services, and has captured all search results in screenshots which are now shared for further use via OSF.

Many of the public ad repositories were found to be defective; some more so than others (with X being the least compliant). A number of others in fact did not provide public ad repositories at all. Overall, functionality accessibility is relatively good; content availability, and targeting and reach, are worse, and removed ad availability is generally poor.

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