European regulations overview and guidance

Limited ads

Limited ads (LTD) give publishers the ability to serve ads in a limited way. Limited ads disable the collection, sharing, and use of personal data for personalization of ads. Note the following:

  • The browser’s Trust Token API may be accessed to help defend against fraud and abuse. Google does not require publishers to obtain consent for this use case.
  • Ad-serving technologies (our JavaScript tags and/or our SDK code) will still be cached or installed as part of the normal operation of users' browsers and mobile operating systems, and ad creatives will still be sent to, and in some instances cached on, devices. Data like IP addresses will still be used in the course of basic ad serving.
  • Only when Programmatic limited ads are turned on, invalid traffic detection-only cookies & local storage will be used to help defend against fraud and abuse. Google does not require publishers to obtain consent for this use case.

If a publisher uses the IAB TCF v2.2 consent framework, we will attempt to serve an eligible limited ad when there is no consent for Purpose 1. Alternatively, a publisher can manually send a signal (see Implementation) and Google will similarly attempt to serve an eligible limited ad regardless of user location.

Cookie and local identifier usage

Limited ads disable all personalization and features that require use of a local identifier. This means that some features aren't available for limited ads.

Features not available with limited ads

Line items that utilize any of these unavailable features won't be eligible for limited ads:

  • Any ads personalization
  • Audience targeting
  • Search lift measurement
  • Survey lift measurement
  • Remarketing 
  • Interest-based categories
  • Mobile carrier targeting
  • Bandwidth targeting
  • Features that rely on a local identifier, including:​​​​​
    • Conversion tracking metric
    • In-app conversion tracking
    • Unique reach measurement
    • “Mute This Ad”
    • Sequential creative rotation
    • Video creative rotation and storyboarding
    • Video session ad rules
    • Frequency capping
    • Reporting on cookie reach, unique reach, or in-app conversions
    • Some invalid traffic detection, depending on your programmatic limited ads settings
    • Certain data transfer fields, such as User ID, will be unavailable
Unless programmatic limited ads are turned on, fraud-detection capabilities may be reduced for limited ads. We recommend publishers inform advertisers that invalid traffic-filtering capabilities may be reduced on traffic where there is no user consent for cookies.

Demand eligibility

Limited ads are supported for reservations and mediation for web, app, and video in Ad Manager. Reservations and their creatives are associated with non-programmatic line items, including guaranteed (Sponsorship and Standard) and non-guaranteed (Network, Bulk, Price Priority, and House). Programmatic demand is only available for limited ads when programmatic limited ads are turned on by the publisher.

Programmatic limited ads

Programmatic bidding is available on inventory eligible for limited ads. A publisher can enable this serving mode to allow for contextual programmatic demand when serving limited ads and enables demand from Google demand, Authorized Buyers, Open Bidding, and SDK Bidding.

If publishers decide to use this serving mode, Google will make use of invalid traffic detection-only cookies & local storage on consented and un-consented traffic. Accordingly, programmatic demand will be enabled (and an invalid traffic-only cookie & local storage used) when (1) there is no certified consent management platform (CMP) present, (2) when limited ads are enabled in the ad request, or (3) a user has declined consent for Purpose 1 of IAB Europe’s Transparency and Consent Framework (TCF), and the signal for all other lawful bases required for limited ads are present in the TC string.

Where no CMP is present, publishers are reminded that they must still comply with all relevant provisions of the EU user consent policy (including, for example, the obligations to clearly identify each party that may collect, receive, or use end users’ personal data and to provide end users with prominent and easily accessible information about that party’s use of end users’ personal data.)

Programmatic limited ads are an optional feature. Publishers are legally responsible for the tools they use to gather consent, including consent for how they use cookies & local storage in online advertising. Publishers should work with their legal teams to determine for themselves whether to use this feature, taking into account relevant regulations and applicable regulator guidance.

Publishers that do not want to use invalid traffic-only cookies and local storage without user consent should opt out of this feature by turning it off in the Ad Manager user interface.

Turn off programmatic limited ads

Programmatic limited ads are turned on by default and can be turned off at any time. Complete the following steps to turn off programmatic limited ads:

  1. Sign in to Google Ad Manager.
  2. Navigate to Admin and then Global settings and then Network settings.
  3. Turn off Programmatic limited ads.
  4. Scroll to the bottom of the page and click Save.
If you manage an app in both AdMob and Ad Manager, this setting will turn off programmatic limited ads regardless of the setting in AdMob.

Turn on programmatic limited ads

Complete the following steps to turn on programmatic bidding for limited ads if it was previously turned off:

  1. Sign in to Google Ad Manager.
  2. Navigate to Admin and then Global settings and then Network settings.
  3. Turn on Programmatic limited ads.
  4. Scroll to the bottom of the page and click Save.

Creative eligibility

Reservations

For publishers using the "Check reservation creatives for consent" feature, creative eligibility varies based on the following scenarios:

  1. Creatives are eligible for limited ads requests if the publisher hasn't declared any ad technology providers and Google hasn't detected any.
  2. Under TCF v2.2, creatives are only filtered if an unknown ad technology provider is detected or an ad technology provider is known to violate Google’s policy or lacks any legal basis under the framework.
When not using the “Check reservation creatives for consent” feature, all reservation creatives are eligible for serving. It is your responsibility as a publisher to ensure that your reservations have the necessary user consent to serve if consent is required.

Under TCF v2.2, creative serving may pass along the consent string to third-party ad technology providers if the consent macros are used. Third-party ad technology providers are expected to respect consent signals, including whether the use of cookies or local identifiers is allowed.

Mediation

For mediation, there is no creative enforcement when non-personalized ads are enabled using Google’s EU User Consent tools and that same policy will be extended for LTD creatives served through mediation. Under TCF v2.2, all creatives in general are eligible, but similar to reservations, we check that ad technology providers and other programmatic demand sources don’t violate Google policy and have at least one legal basis for processing data.

Implementation

There are no new user interface controls to implement limited ads. Publishers can indicate whether limited ads treatment should be applied.
  • GPT for Web: Publishers can specify on the ad tag whether to explicitly trigger a limited ads request.
  • IMA SDK for Web and App: Publishers can explicitly trigger a limited ads request by adding ltd=1 to the ad tag URL.
  • GMA SDK: Publishers can use the gad_has_consent_for_cookies key in platform shared-storage to enable limited ads on Android and iOS.
For publishers using the IAB TCF v2.2, we will respect the cookie or ID consent signal (Purpose 1) contained in the TC string. Limited ads will be requested when consent for Purpose 1 is missing but legitimate interest or consent has been obtained for Purposes 2, 7, 9, and 10.
For limited ads requests, reporting will be unavailable for cookie reach, unique reach, and in-app conversions. Forecasting won’t recognize limited ads as a distinct serving mode and will provide a forecast that aggregates LTD traffic with NPA/Basic ads.
 
Reporting on impressions for limited ads are available using the Serving restriction dimension in Ad Manager reporting.
 

Action required for consent management platforms

Publishers using Privacy & messaging can create and traffic consent messages using the IAB TCF v2.2.

Other IAB TCF v2.2 certified consent management platforms (CMPs) shouldn't need to take any action to support limited ads. The existing TC string contains all of the relevant signals required to select the correct serving mode. If the following conditions are met for Google as an ad technology provider, we will serve limited ads:

  • No consent for Purpose 1
  • Legitimate interest or consent for Purposes 2, 7, 9, and 10

Currently, LTD on apps will only be supported with the IAB TCF v2.2 consent framework. If a publisher is utilizing a custom consent tool and a user declines consent for the use of device identifiers, the publisher should not make an ad request.

The following ad serving modes will be available for publishers:

Ad serving mode Personalized ads Non-personalized ads Limited ads
Programmatic Non-programmatic
Invalid traffic and fraud protection Supported Supported Supported Not supported
Programmatic demand from Google Supported Supported Supported Not supported
Programmatic demand from third-party buyers Supported Supported Supported Not supported

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