Policy paper

Online Advertising Taskforce action plan

Published 30 November 2023

Ministerial foreword

Online advertising is a dynamic and ever-evolving ecosystem at the heart of the UK economy. The power it has in shaping the digital era is undeniable. However, with this influence comes a responsibility to ensure that all online advertising, particularly the advertising our children are exposed to, is safe, transparent and accountable. To act against the most concerning harms arising from the exponential growth of online advertising, urgent and collaborative action between government and industry is required.

When we published the response to our consultation on the Online Advertising Programme in July, we set out our plan to build a fit-for-purpose, agile regulatory framework. This will protect internet users from bad actors and increase protections for under-18s from adverts for products that are illegal to be sold to them, while supporting the long-term, sustainable growth of the online advertising sector. We committed to introducing legislation when Parliamentary time allows, and to publishing a further consultation on the details. We also announced the creation of the Online Advertising Taskforce, bringing together industry and government to build the evidence base and drive forward non-legislative action in the meantime.

Over the past months, members of the Taskforce have worked to shape an ambitious and targeted action plan. This plan brings together commitments to improve our understanding of these harms. It also builds on the existing work done by Taskforce members and actors across the advertising supply chain to protect users, especially children. There is a focus on working together to tackle the bad actors and proactively prevent serious and in particular illegal harms not only from reaching the consumer, but from entering the supply chain in the first place. This action plan is our commitment to ensuring that the digital advertising landscape remains safe, transparent, and accountable.

The UK’s world-leading advertising sector has an opportunity to spearhead responsible practices. But meaningful collaboration is key in upholding the standards and protections for consumers to enable advertising to continue playing a valuable economic role. This is why we are grateful to Taskforce members representing actors across the online advertising supply chain for their expert input, dedication and effort in shaping this plan. Tackling these complex challenges requires dedication from all sides, which is why I am particularly grateful for the work done by the government’s Anti-Fraud Champion, whose support will be of crucial importance as we look to ensure that consumers are kept safe online. We are also working closely with the Department for Science, Innovation and Technology (DSIT) and the Department for Business and Trade (DBT) to ensure joint action against harms within this space through the Online Safety Act 2023 and the Digital Markets, Consumers and Competition Bill.

Our mission is clear: to make the online advertising landscape safer for all, especially our children. We invite all industry leaders, digital platforms, and all those who engage with online advertising to join us in this endeavour. Together, we can achieve this vision and create a future where online advertising remains a force for good, benefits society, and protects our children.

The Rt Hon Sir John Whittingdale OBE MP
Minister of State for Media, Tourism and Creative Industries

Mark Lund, Deputy Chair

This Taskforce has come at a very apt time for the advertising industry. As online advertising reaches 80% of all spend in the UK, it is more than ever the key part of the interface between advertisers, media owners and the consumers who buy from both.

As such, the equation of trust on which advertising depends (if I trust your and like your message I will engage with your brand) lives or dies online.

The UK ad industry has consistently led the world in both creative excellence and quality of regulation. This Taskforce action plan is an opportunity for the industry to build on that proud record in the online space by pushing forward the initiatives that can shape legislation by getting to a great solution ahead of it.

The work so far has been excellent and it is now up to the Taskforce and wider industry to accelerate the momentum towards accountable action and clear results.

Mark Lund
Chairman, Advertising Standards Board of Finance
Deputy Chair, Online Advertising Taskforce

Introduction

The online advertising industry has experienced rapid growth as online media consumption has increased in recent years. Online advertising spend, such as on websites and social media, now outstrips traditional advertising like billboards and newspapers - in 2022, it made up 75% of total ad spend, equal to £26.1 billion.^{[footnote 1]}

However, along with the rapid growth of the sector have come increased risks for consumer harms and brand safety. These harms can have wide-reaching impacts on consumer confidence and trust, which risks the sustainability and effectiveness of online advertising. Evidence from our public call for evidence (2020), consultation (2022) and externally commissioned research indicated that user experiences of harm are driven by an absence of transparency and accountability in the supply chain.

That is why, through the Online Advertising Programme, we have been examining whether the current self-regulatory and co-regulatory regime for paid-for online advertising is sufficiently equipped to tackle these challenges. The government’s response to the consultation, published earlier this year, outlined our intention to intervene in a proportionate way to tackle what the evidence indicates are the most concerning harms associated with online advertising, working closely with industry.

While we will be developing and consulting on our proposals for regulation ahead of future legislation, in advance of that the Online Advertising Taskforce has been set up to drive ambitious non-legislative action and make a positive change in addressing the harms in scope of the Programme, illegal advertising and the inappropriate exposure of children to adverts for products and services illegal to be sold to them (‘in-scope harms’).

As we set out in the consultation response, we are committed to protecting consumers and the public from harm, while at the same time supporting the growth and innovation of our world-renowned advertising industry. Our approach is to build on the self-regulatory and co-regulatory system already in place, with the Advertising Standards Authority and the Committee of Advertising Practice at the forefront. Through the Online Advertising Taskforce, we have a real opportunity for government and industry to work together to tackle illegal advertising and increase the protection of children, in anticipation of future regulation being introduced.

This plan brings together and builds on work that is already in progress to minimise harm and protect both consumers and businesses from harm. As well as government initiatives, it builds on the number of existing industry-led schemes and initiatives which already address harms associated with paid-for online advertising and improve understanding of where harmful advertising occurs, such as those led by members of the Taskforce such as the Internet Advertising Bureau’s (IAB) Gold Standard, the Incorporated Society of British Advertisers’ (ISBA) Influencer Code of Conduct, and Stop Scams’ Data Sharing Pilot. It also highlights the work done by the Advertising Standards Authority’s (ASA) Intermediary and Platform Principles (IPP) pilot, a leading example of the flexibility and innovative nature of the UK’s self-regulatory approach. Other initiatives led by industry members outside the membership of the Taskforce are also important in this space, including the work of the Trustworthy Accountability Group (TAG),^{[footnote 2]} for example in relation to malware and fraud.

The plan also reflects the important programme of work that has been taken forward by the government’s Anti-Fraud Champion, Anthony Browne MP, and the Home Office in delivering the Fraud Strategy, one key strand of which is the voluntary Online Fraud Charter, working with major tech platforms. The Charter is focused on tackling fraud, one of the most well-known, distressing and costly harms associated with illegal advertising. Sitting alongside that work, the Online Advertising Taskforce will look at solutions to the broader range of illegal advertising harms in scope of this Programme, and engage parties across the advertising supply chain.

It also recognises, though, that there is more that can and must be done. Under this plan, the government will commission further research and members will be encouraged to do more to share available information with each other about the origin, prevalence, and impact of the in-scope harms and insights relevant to facilitating takedowns of harmful adverts. It also calls for universal adoption of best in class principles across the supply chain to minimise harmful paid-for advertising.

The success of these commitments, and the Taskforce, will depend on all members, who represent a wide spectrum of parties across the supply chain, working together to solve the challenges we are faced with to make online advertising safer, transparent, and more trusted by consumers in the UK. The Taskforce will keep under constant review what additional steps could be taken as we find out more about the challenges that face us.

Objective

As set out in its Terms of Reference, the Online Advertising Taskforce will support the aims of the Online Advertising Programme to improve transparency and accountability in the online advertising supply chain. It will do this by agreeing upon and delivering a programme of work to help address illegal advertising and minimise children being served advertising for products and services illegal to sell to them (‘in-scope harms’), in anticipation of regulation being introduced in due course.

This action plan sets out how the Taskforce will work with the advertising industry, regulators and relevant government departments to:

1. Understand and improve the evidence around the in-scope harms.

2. Identify ways in which we can enhance voluntary initiatives or standards to tackle in-scope harms, by pushing the ambition and/or take-up of these initiatives and considering the development of new standards where gaps are identified.

It is a living document and we may publish further updates as needed going forward.

Taskforce members

• Rt Hon Sir John Whittingdale MP, Minister for Media, Tourism and Creative Industries (DCMS) - Chair
• Mark Lund, Chairman, Advertising Standards Board of Finance - Deputy Chair
• Anthony Browne MP, Anti-Fraud Champion, Home Office
• Guy Parker, Chief Executive, Advertising Standards Authority
• Phil Smith, Director General, Incorporated Society of British Advertisers
• Christie Dennehy-Neil, Head of Policy & Regulatory Affairs, Internet Advertising Bureau (IAB)
• Konrad Shek​, Director of Policy Research, Advertising Association
• Richard Lindsay, Director of Legal and Public Affairs, Institute of Practitioners in Advertising (IPA)
• Sayra Tekin, Director of Legal, News Media Association
• Simon Miller, Director of Policy and Communications, Stop Scams
• Antony Walker, Deputy CEO, TechUK
• Jemima Murray, Deputy Director of Fraud Policy, Home Office
• Daniel Okubo, Deputy Director of Online Harms Programmes and International, Department for Science, Innovation and Technology
• David Marshall, Deputy Director for Consumer Policy, Department for Business and Trade

The Online Advertising Taskforce action plan

Objective 1: Improve evidence of in-scope harms

The Online Advertising Programme’s consultation, as well as externally commissioned research published alongside it, found that while there is compelling qualitative data on the impact of illegal harms (such as fraudulent advertising), consistent and comparable data (qualitative or quantitative) on the prevalence of harms in paid-for online advertising is less certain.

That is why, through its first objective, the Online Advertising Taskforce aims to encourage actors across the supply chain to work together and share information where it is accessible and available and to build the evidence base around the in-scope harms further.

The plan puts forward two broad principles on how we can tackle this lack of evidence: through increasing available research and encouraging information sharing. Each of the principles brings together actions building on existing and ongoing work from member organisations to demonstrate how evidence can be improved. The Taskforce will provide a forum for considering and disseminating the results widely among interested organisations, with each representative member deciding the best way to take the actions forward in a way that works for their own membership.

Principle 1: The Taskforce will improve available research and build up evidence base about in-scope harms

DCMS will publish a further consultation on the Online Advertising Programme policy package.

This consultation will seek views on the proposed regulation, to ensure it is coherent, logical and can be designed and implemented in partnership with industry. DCMS will seek feedback and input from the Taskforce members in creating a more granular list of the sub-harms under the two broad categories of in-scope harms, to be included in the consultation.

DCMS will undertake research on online users’ experiences of advertising harms, including in-scope harms.

The purpose of this research is to understand the prevalence and range of online advertising harms experienced in the UK, including paid-for illegal advertising and paid-for adverts for products and/or services illegal to be sold to children. This will provide robust quantitative results supported by qualitative insights in relation to the in-scope harms of the Online Advertising Programme and the Taskforce. The resulting comprehensive baseline of experiences can be used to monitor change in future prevalence and range of in-scope harms. The Taskforce will look at what additional research might be needed in due course.

The ASA will publish case-study research identifying the online supplier pathway relating to age-restricted ads appearing on websites and other online environments disproportionately popular with under 18s.

This research will monitor for ads for products that are illegal to sell to under 18s, in breach of the CAP Codes, to websites and other online environments that attract an audience of which 25%+ are under 18. The monitoring will identify the relevant parties in the supply pathway that have facilitated the distribution of these ads with a view to inviting their input as to why the breach has occurred.

Stop Scams UK, through its Data Sharing Pilots, will explore how to build up and share evidence on scam adverts.

Stop Scams existing scam intelligence work takes data reported into a scam reporting service and uses it to harvest robust data on the scam journey as well as information about bad actors. Expanding this work to include paid-for online scam adverts and sharing the findings from the Pilot with members on the Taskforce could inform existing industry efforts to minimise and prevent such ads from appearing in the paid-for space.

Principle 2: The Taskforce will facilitate the gathering and sharing of information about in-scope harms across the supply chain

The Online Advertising Taskforce will work to understand how information could be best shared between industry, government and regulators, building on existing mechanisms, to increase the understanding of the prevalence and origin of in-scope harms and facilitate the ASA’s independent monitoring of in-scope harmful ads.

Working groups with a range of players across the supply chain will consider how relevant information about in-scope harms (e.g research, anonymised or aggregated data, internal reporting or monitoring) could be shared. The intention is that this will inform work to increase the data available for ASA monitoring of advertiser compliance and to enable sharing of actionable intelligence about in-scope harms activity. Additionally, publishers working with malware detection firms could work to feed data on malware prevalence, where they can obtain it, into intra-industry information sharing mechanisms.

Through the Online Safety Act, Ofcom will have information-gathering powers to oversee enforcement of the regulatory framework, which includes the duties on relevant regulated service providers relating to fraudulent advertising.

Ofcom will have the power to require information from regulated companies and relevant third parties. Major platforms will also be required to publish annual transparency reports, setting out online safety information as requested by Ofcom, which may include information about the measures taken by providers to comply with the fraudulent advertising duties.

The Prime Minister’s Anti-Fraud Champion, and the Home Office through its Online Fraud Charter, will work towards facilitating the sharing of information about fraudulent advertising, including with Taskforce members.

As part of this the Home Office, working closely with DCMS and DSIT, the National Cyber Security Centre, the Information Commissioner’s Office, law enforcement and other industry partners, will explore what data, both internal and external, could facilitate the identification and prevention of fraud. The Charter will also work with signatory platforms towards a streamlined reporting function for fraudulent advertising. Sharing the information supplied through reporting could provide a better understanding of where bad ads have been hosted or appeared, for other relevant actors to access. Taskforce members are therefore encouraged to engage with the Online Fraud Charter, to work towards making data available and sharing information available about fraudulent advertising (in conjunction with commitment 1 under this principle), and to facilitate wider uptake of relevant voluntary initiatives contained in the Charter across the supply chain, where feasible.

Objective 2: Enhance initiatives to tackle in-scope harms

There are already a range of voluntary industry initiatives and standards in place across the online advertising supply chain aimed at mitigating advertising harms. In the response to the government’s Online Advertising Programme consultation, 20 industry initiatives were referenced that could help tackle the range of harms considered by the consultation.

As part of its second objective, the Taskforce aims to support and extend the industry initiatives that seek to, or have the potential to, address the drivers of the in-scope categories of harm. This action plan brings together a list of actions and initiatives that are already underway, or could be expanded or improved, that have the potential to make a difference in preventing in-scope harms, grouped under three broad principles: improving awareness, increasing compliance with regulations, and raising industry standards.

Principle 1: The Taskforce will improve awareness and promote best practice to tackle in-scope harms

Taskforce members will promote best practice and relevant industry initiatives that can help to minimise in-scope harms through their communications and where appropriate public messaging.

All members are encouraged to signpost the work of the Taskforce and relevant initiatives and promote broader adoption through marketing or communications materials, with a view of increasing uptake and effectiveness of the initiatives.

The Taskforce will publish a progress report on the initiatives taken forward in the action plan.

Principle 2: The Taskforce will look to increase compliance with regulations to minimise the occurrence of in-scope harmful ads in the paid-for space online.

DBT will update the Consumer Protection Regulations (CPRs) covering misleading advertising in primary legislation through the Digital Markets, Competition and Consumer (DMCC) Bill.

The CPRs are in scope of retained EU law and will be rewritten in primary legislation via the DMCC Bill. They set out the broad rules for regulating misleading advertising and include a general ban on misleading practices. The Protection from Unfair Trading Chapter of the DMCC Bill largely recreates the legal effect (with minor amendments) of the Consumer Protection from Unfair Trading Regulations 2008 and has the same core objective of protecting consumers in respect of unfair commercial practices. Alongside the legislation, DBT is consulting on improving price transparency and product information for consumers.

DSIT will require all services likely to be accessed by children to provide additional safety measures to protect children from inappropriate and harmful content online through the Online Safety Act.

The Act explicitly requires user-to-user services, which allow primary priority content on their service, and publishers of pornographic content to use highly effective age-verification and age estimation tools. This means that these providers will need to ensure that the age verification or age estimation they use is highly effective in determining whether a particular user is a child or not, which will provide a foundation for the future Online Advertising Programme regulatory structure.

The ASA system will evaluate the Intermediary and Platform Principles (IPP) Pilot with a view to determining next steps.

Platforms and intermediaries recognise the benefits of working with the ASA to support raising awareness of and enforcing the CAP Code. The evaluation and any development process that follows it will determine whether and, if so, how to formalise IPP into the ASA system regulatory framework. It is noted that existing Principles already engage in-scope Platforms and Intermediaries to drive compliance with media placement and audience targeting restrictions on ads for products that are illegal to be sold to under-18s.

Principle 3: The Taskforce will raise existing industry standards and improve diligence in the ecosystem

IAB UK and other relevant Taskforce members (including ISBA, the IPA and the AA) will work together to increase adoption of the Gold Standard certification.

This will help to improve adoption and use of technical tools and standards such as Demand Chain Object (a technical open-source standard provided to the market by the IAB Tech Lab) that capture information about the supply path of individual ads, to support the provision and sharing of information to trace the source of bad ads. ISBA and the IAB will work together to encourage advertisers to adopt relevant Gold Standard requirements that aid the identification and elimination of bad actors in the advertising supply chain.

ISBA will increase adoption of better standards for influencer advertising through considerations of the fourth iteration of its Influencer Marketing Code of Conduct, to prevent paid-for advertising of products and services involving in-scope harms.

This will raise standards of conduct in influencer advertising, including affiliate marketing, by ensuring increased influencer advertising compliance with the complementary regulatory frameworks set out by the Advertising Standards Authority (ASA)/CAP Code and the Competition and Markets Authority (CMA). This will also ensure advertising is legitimate and clearly labelled as such.

Taskforce members, including in particular ISBA and the ASA, will promote compliance with existing standards for the targeting of age-sensitive advertising.

ISBA will also take action to increase standards of age assurance by reconvening the International Alliance for Responsible Drinking (IARD), the Age Verification Providers Association (AVPA), and World Federation of Advertisers. As an example of additional longer-term work in this space, through continuing the development of its Project Origin, ISBA will work to quantify where advertising for age-restricted products is landing in the wrong place.

Next steps

This plan represents a collaborative effort between government and industry stakeholders. As we gain more insight into the issues and the effectiveness of proposed solutions, the plan will evolve through ongoing review and revision.

The government commits to regularly engaging stakeholders to evaluate advancement on all actions. The Online Advertising Taskforce will maintain open and continuous communication with members to ensure accountability from every group making a commitment under this plan. Progress will be evaluated formally at the Taskforce meetings, in addition to continual day-to-day engagement with the sector.

Summary tables of actions

Objective 1: Improve evidence of in-scope harms

Principle 1: Improving evidence and building up evidence

	Commitment	Led by
1.	Publish a further consultation on the Online Advertising Programme, including a more detailed taxonomy of the in-scope harms	DCMS, All on taxonomy
2.	Undertake research on online users’ experiences of advertising harms	DCMS
3.	Publish case-study research identifying the online supplier pathway relating to age-restricted ads appearing on websites and other online environments disproportionately popular with under 18s	ASA
4.	Explore how to build up and share evidence on scam adverts	Stop Scams UK

Principle 2: Facilitate information gathering and sharing

	Commitment	Led by
5.	Consider how information could be shared between members to increase the understanding of the prevalence and origin of in-scope harms and facilitate the ASA’s independent monitoring of in-scope harm ads.	All
6.	New Ofcom information-gathering powers to support enforcement of the regulatory framework, which includes the duties on relevant regulated service providers relating to fraudulent advertising	DSIT, through the Online Safety Act
7.	Share information available about fraudulent advertising	HO / Fraud Charter

Objective 2: Enhance initiatives to tackle in-scope harms

Principle 1: Improving awareness and promoting best practice

	Commitment	Led by
1.	Promote best practice and relevant industry initiatives that can help to minimise in-scope harms through communications and where appropriate public messaging	All
2.	Publish a progress report on the initiatives taken forward in the action plan to assess progress and suggest further improvements	All

Principle 2: Increase compliance

	Commitment	Led by
3.	Update the Consumer Protection Regulations (introducing a duty for misleading advertising) in primary legislation	DBT
4.	Age-verification and age-estimation requirements for in-scope services to protect children from primary priority content on their service	DSIT, through the Online Safety Act
5.	Evaluate Intermediary and Platform Principles Pilot with a view to determining whether and, if so, how to formalise IPP into the ASA system regulatory framework.	ASA system, IAB, participating platforms and intermediaries

Principle 3: Raise existing industry standards and improve diligence

	Commitment	Led by
6.	Increase adoption of the Gold Standard certification	IAB, ISBA, IPA, AA
7.	Introduce higher standards on age-restricted product ads for influencer marketing	ISBA through its Influencer Code of Conduct
8.	Increase standards of age assurance for age-restricted advertising online	ISBA

1. Source: Advertising Association, UK ad spend grew 8.8% in 2022 to reach £34.8bn ↩

2. Members of the Online Advertising Taskforce, including the Internet Advertising Bureau (IAB UK), the Incorporated Society of British Advertisers (ISBA) and the Institute of Practitioners in Advertising (IPA), sit on the TAG Leadership Council. ↩