The EU's ad-transparency rule names the payer, not the presenter

The persona

The obligation here attaches to a platform interface, not to any account's presenter. Regulation (EU) 2022/2065, the Digital Services Act, dated 19 October 2022, requires online platforms to let recipients identify each advertisement as such, in real time, with no distinction drawn between an ad fronted by a person, a brand, or an operator-run virtual character. The European Commission's own policy overview summarizes the requirement plainly: ads 'must be clearly labelled' and must show 'who is placing them and why you are seeing them.'

What the documents establish

Article 26 of the regulation's own text, retrieved via an archived copy of the official EUR-Lex record after the live page returned a bot-blocking response, requires platforms presenting advertisements to ensure recipients can identify, 'in a clear, concise and unambiguous manner,' that content is an advertisement, the natural or legal person on whose behalf it is presented, and, if different, the person who paid for it. This obligation applies from 17 February 2024, while additional systemic-risk duties fall specifically on platforms exceeding 45 million monthly EU users, per the Commission's overview. Neither document conditions the disclosure duty on whether the advertisement's presenter is a human endorser or a synthetic one.

Character versus company

A virtual influencer's sponsored post displayed inside a covered platform's advertising system would, under Article 26, still need to show who paid for it and on whose behalf it runs, independent of the persona's own framing of the post as a personal recommendation. The text names 'the natural or legal person on whose behalf the advertisement is presented' as the identified party, which points to the operator or advertiser rather than to a fictional character with no legal personality of its own.

What to watch

Because the live EUR-Lex page returned a bot-blocking response during retrieval, this entry relies on an archived snapshot of the official text rather than the current live page; a reader should confirm no consolidating amendment has since altered Article 26 before citing it precisely. It is also worth tracking how national Digital Services Coordinators apply this article to advertising fronted by synthetic personas specifically, since neither document addresses that scenario directly.

• Does the platform's ad-transparency interface name the operator behind a virtual-influencer account as the party the advertisement is presented on behalf of?
• Has a national Digital Services Coordinator issued guidance applying Article 26 to synthetic-persona advertising specifically?
• What has changed in the regulation's consolidated text since this note's archived retrieval?

Article 26 is written around the advertisement as a transaction visible to a platform's systems, which is why its identification duties reach a virtual persona's sponsored content the same way they reach any other paid placement.