Check My Ads Institute
Policy Platform

At present, the digital advertising supply chain is a tangled web of opaque relationships and shadowy intermediaries. Advertisers are unable to see who they are funding, and in many cases, do not know which entities are involved in delivering, serving, or profiting from their campaigns. This lack of supply chain transparency has enabled the flow of advertising dollars to child exploitation material, sanctioned foreign actors, and made-for-advertising scams—without the advertiser’s knowledge or consent.

We propose mandatory due diligence and know-your-customer (“KYC”) standards for all ad brokers. These entities must verify the beneficial owners, locations, and legitimacy of every vendor, ad network, and verification firm they transact with. This includes confirming the physical location of operations, validating domain ownership, and conducting periodic audits of supply chain partners. Adtech brokers should be required to report this information to both clients and regulators to ensure supply chain integrity.

Quarterly risk assessments must also be provided to clients, detailing any changes in vendor relationships, anomalies in transaction data, and steps taken to prevent fraud and abuse. These reports should include clear indicators of risk, supported by documentation such as beneficial ownership records and cross-verified business details. Clients must have the right to understand exactly where their money is going.

Additionally, brokers must maintain written policies outlining their due diligence protocols and ensure those policies are enforced and reviewed regularly. Just as financial institutions conduct “know your customer” checks to guard against money laundering and criminal financing, adtech companies must take responsibility for the financial risks embedded in their ecosystems. These common-sense standards are already mandatory in other industries like finance—it’s time they applied here, too.

Adtech brokers today have no obligation to act in their clients’ best interest. This is a core flaw that allows them to serve their own incentives—even when it means being careless, reckless, or downright wasting a clients’ ad spend.

We propose codifying a best interest duty for all adtech intermediaries and verification vendors who work on behalf of advertiser and publisher clients. These entities must use reasonable diligence, care, and skill to serve their clients faithfully, just as financial advisors are required to do. This includes a clear prohibition on placing their own commercial interests above the goals, needs, and reputational safety of the advertiser or publisher.

Advertiser clients must also be entitled to refunds (not just future ad credits) when vendors fail to meet agreed-upon standards. This shift will help realign incentives and restore trust in ad transactions.

Programmatic advertising is often described as a “black box” for good reason: advertisers have little visibility into where their ads appear or how much they actually cost. This lack of transparency fuels waste, fraud, and brand safety violations.

We call for mandatory log- and page URL-level data sharing. Advertisers must receive detailed reports on where, when, and to whom ads are served—including the full supply path, and compensation breakdown for every intermediary. These reports must be accessible, understandable, and retained for auditing. Publicly available routing reports should also be required each quarter to hold platforms accountable. Transparency is the first step to real accountability.

The adtech industry’s business model hinges on pervasive surveillance and unchecked data extraction that has grown into a snake-oil industry. Advertisers are sold an illusion of precision but really are buying useless data rooted in inaccurate predictions and inferences. Consumers and businesses deserve a better standard: one that prioritizes privacy while still enabling effective advertising.

Our platform calls for the adoption of privacy-enhanced advertising practices grounded in four pillars:

• Data Minimization: Data should only be collected when it is strictly necessary to deliver a service the user has explicitly requested. Profiling based on cross-site behavioral tracking must be prohibited unless clearly consented to.

• Protections for Sensitive Data: Sensitive data, like health data and precise geolocation, should not be used for targeted advertising.

• Universal Opt-Out Mechanisms (UOOMs): Users must be empowered to opt out of tracking across all platforms and services using tools like the Global Privacy Control. This signal should be binding on all adtech actors and browsers.

• First-Party Data Rules: Advertising should favor direct relationships between consumers and brands. First-party and contextual advertising offer high performance without compromising privacy, and should be the standard over third-party tracking.

With these policies, we can restore user trust, reduce systemic risk, and foster a healthier advertising ecosystem.

To make these reforms real, we need enforcement teeth. We support:

• Empowering the Department of Justice, Federal Trade Commission, and the UK’s Competition and Markets Authority with clear mandates to enforce antitrust, transparency, and consumer protection rules.

• Enabling state Attorneys General to pursue civil actions for violations.

• Providing a private right of action to harmed advertisers and publishers, with statutory damages and no class action waivers.

• Supporting enforcement by the European Commission and national-level regulators in EU member states, who can help ensure international compliance and accountability across the global digital advertising ecosystem.

These enforcement mechanisms will give stakeholders the tools they need to hold bad actors accountable and protect the integrity of the marketplace.