In line with this, we fully support improving transparency in political advertising. Last year we voluntarily introduced enhanced verification requirements for U.S. political advertisers, in-ad disclosures for election ads, and a new transparency report and political ad library for the U.S. mid-terms. We deployed similar tools for the Indian and EU parliamentary elections. While we had intended to introduce similar measures in Canada, unfortunately the new online platforms provisions introduced in Bill C-76 do not reflect how our online advertising systems or transparency reports currently function. It was simply not feasible for us to implement the extensive changes that would have been necessary to accommodate the new requirements in the very short time we had before the new provisions took effect.
First, the definition of “online platform” includes any “Internet site or Internet application” that sells advertising space “directly or indirectly”, and imposes the new registry obligation on any platform that meets certain minimum traffic thresholds. This captures not only social media or large online advertising platforms, but also most national and regional news publishers, virtually all multicultural publications, and most popular ad-supported websites and apps, making its application extraordinarily broad.
Second, the provisions specifically require that each site or app maintain their own registry. Unlike some companies, Google provides a wide array of advertising products and services. Advertisers can purchase campaigns through Google that will run on both Google sites and/or third party publisher sites. These systems are automated. Often there is no direct relationship between the advertiser and the publisher. While the page is loading, the site will send a signal that a user meeting certain demographic criteria is available to be advertised to. The advertisers will then bid for the opportunity to display an ad to that user. The winning advertiser's ad server displays the winning ad in the user's browser. This all happens within fractions of a second. The publisher does not immediately know what ad was displayed and does not have immediate access to the ad that was shown. To accommodate the new provisions, we would have had to build entirely new systems to inform publishers that a regulated political ad had displayed and then deliver a copy of that ad and the requisite information to each publisher for inclusion in their own registry. This was simply not achievable in the very short time before the provisions took effect.
Third, the provisions require the registry to be updated the same day as the regulated political ad is displayed. This effectively means that the registry must be updated in real time, as a regulated political ad that was displayed at 11:59 p.m. would need to be included in the registry before midnight. Due to the complexities of our online advertising systems, we simply could not commit to such a turnaround time.
A final complication is that “election advertising” includes advertising “taking a position on an issue with which a registered party or candidate is associated”. These are generally referred to as “issue ads”. Issue ads are highly contextual and notoriously difficult to identify reliably, especially as the definition is vague and will change and evolve during the course of a campaign. Given these challenges, we generally prohibit this class of advertising in countries where it's regulated, such as our recent prohibition in France.