Advertising Information Group
AIG
The Advertising Information Group is a European tripartite information, monitoring and analysis body shaped by the common principles and policies of its founding members.
ID: 11220347045-31
Lobbying Activity
Response to Update of EU rules on audiovisual media services
19 Dec 2025
The Advertising Information Group (AIG) welcomes the opportunity to respond to the European Commissions Call for Evidence on the Evaluation and Update of the AVMSD Rules. 2. The European audiovisual media environment has undergone significant change since the 2018 revision, including the rise of non-linear services, video-sharing platforms (VSPs), and influencer marketing. Despite these developments, we believe that the AVMSD continues to provide a fit-for-purpose, legally coherent, and technologically neutral framework that addresses these developments effectively. 3. Although the AVMSD does not explicitly define the term influencer, many influencer activities are caught by the definition of audiovisual media services (AVMS) in Article 1(1)(a), as recognised in Council Conclusions and explicitly defined in some Member States such as Spain and France. Most Member States have transposed this article verbatim or substantially, meaning influencers may qualify as AVMS providers across the EU if they meet core AVMS criteria. 4. Introducing new AVMSD obligations for influencers would risk duplication and legal uncertainty. Complementary rules for influencers already exist under the Unfair Commercial Practices Directive (UCPD), Digital Services Act (DSA), European Media Freedom Act (EMFA), and Transparency and Targeting of Political Advertising Regulation (TTPA) which address risks relating to specific activities. 5. Instead, AIG encourages the Commission to prioritise consistent enforcement of the current framework, avoid regulatory overlap, and support self-regulation as an essential complement to statutory rules. 6. We therefore support Option 1 in the Call for Evidence, maintaining the status quo, as the most proportionate, coherent, clear, and future-proof path forward. Please read attached submission for further details.
Read full responseResponse to Digital Fairness Act
24 Oct 2025
AIG welcomes the Commissions focus on digital fairness but believes that the EUs existing consumer protection framework is comprehensive and fit for purpose. The primary challenge is a better enforcement coordination, practical guidance, and clarity about how overlapping legal instruments interact. Rather than introducing new binding legislation that would further fragment an already complex regulatory landscape, the Commission should prioritise strengthening enforcement mechanisms, providing practical guidance, and supporting self-regulatory initiatives. Please see attached paper for more detail.
Read full responseResponse to Digital package – digital omnibus
14 Oct 2025
AIG's response to the European Commission's Digital Omnibus consultation advocates for risk-based regulatory reforms in two areas: Cookie regulation - Replace blanket consent requirements with risk-proportionate rules that exempt low-risk activities (fraud prevention, measurement, contextual advertising). AI Act transparency - Avoid universal AI content labelling that could cause "labelling fatigue"; instead adopt risk-based disclosure focusing on genuinely deceptive applications like synthetic testimonials, not routine creative enhancements. The core argument is that current rules create compliance burdens and user fatigue without effectively protecting consumers, and that focusing regulation on actual consumer harm would be more effective. Please see attached submission for more details.
Read full responseMeeting with Thomas Schmitz (Cabinet of Executive Vice-President Henna Virkkunen)
25 Jun 2025 · Advertising
Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and Apple Inc. and
13 Mar 2025 · Code of Conduct on Online Advertising – Workshop 3
Meeting with Gabriela Firea (Member of the European Parliament)
3 Mar 2025 · AIG Director's Informal Lunch
Meeting with Giuseppe Abbamonte (Director Communications Networks, Content and Technology)
3 Mar 2025 · Upcoming evaluation of the Audiovisual Media Services Directive (AVMSD) and other media files such as the ePrivacy Directive and the proposed new law on green claims.
Response to Car labelling evaluation
15 Apr 2024
Please find attached AIG's feedback and perspective regarding the Car labelling directive.
Read full responseResponse to Retail Investment Package
25 Aug 2023
1. The Advertising Information Group (AIG) (transparency number: 11220347045-31) welcomes the opportunity to respond to the European Commissions proposal for a Directive amending Directives (EU) 2009/65/EC, 2009/138/EC, 2011/61/EU, 2014/65/EU and (EU) 2016/97 as regards the Union retail investor protection rules published in May 2023. The AIG is an informal network of European advertising and media associations that brings together various parts of the advertising industry, and this submission comments on points contained in the proposal that are relevant to the advertising industry. 2. First and foremost, the AIG supports the EU Commission's core aim to prevent misleading advertising and marketing communications Secondly, we support the goal to strengthen consumer protection against unfair practices and to ensure that consumers can make informed decisions. 3. The proposal directive itself notes that it introduces several new provisions to address this issue. We therefore want to highlight that through the Unfair Commercial Practices Directive (2005/29/EC, UCPD), regulations have existed within the EU for decades that cover unfair commercial practices (Article 4 of the UCPD). There is also a well-established system of industry self-regulatory organisations across Europe that have ensured that commercial communications remain compliant with those regulations. 4. Article 24c of the MiFID2 Directive (Directive 2014/65), Article 17 and Article 26a of the IDD (Directive 2016/97) introduce detailed sector-specific rules that apply to advertising in the area of financial services and investment. The proposed definition of "marketing communication" in Art. 4 para. 1 (66) MiFID 2-draft and Article 2 (20) of the IDD is too broad and therefore the wording should be urgently revised, in particular neutral information should not be covered. The same applies to the planned definition of "marketing practice" in Art. 4 para. 1 (67) MiFID 2-draft and Article 2 (21) of the IDD. If the scope of the definition is too broad, it means de facto any behaviour could be sanctioned. 5. Moreover, the suggested changes in Article 24c Par. 8 MiFID2 Directive and Article 26a Par. 8 of the IDD create a very profound authorisation for the Commission to adopt delegated acts on important matters. The proposal should be more specific to begin with, so that delegated acts are not needed at this point. Delegated acts are non-legislative acts adopted by the European Commission under Article 290 of the TFEU to amend or supplement non-essential elements of legislative acts. However, delegated acts may not add, amend, delete or replace essential provisions of the legislative act. Essential changes to the content of a directive must be made by way of a revision of a directive, not by delegated acts. In any case, the criteria specified in Art. 26a (8) a) IDD, Art. 24c (8) a) MiFID2 Directive are already covered by the UCPD and case law and are therefore redundant. This also applies to Art. 26a (8) b) IDD and Art. 24c (8) b) MiFID2 Directive, as they allow delegated acts on the conditions that products have to meet in order to be fair, clear, not misleading and balanced in terms of the presentation of the advantages and risks. 6. To conclude, the UCPD already specifies what misleading marketing is and hence we believe that there is no need for further clarification for investment products as it would be covered under the same definition. UCPD is both comprehensive and well established and underpins self-regulatory rules across Europe. Furthermore, UCPD case law and self-regulation continues to develop on this subject which makes it fit for purpose and responsive to market changes. The introduction of delegated powers through this regime would make the regulatory framework less certain and the business environment in general less predictable. Advertising Information Group 25 August 2023 Contact: Konrad Shek Email: konrad@aig-europe.eu
Read full responseResponse to Environmental claims based on environmental footprint methods
19 Jul 2023
AIG response to the EU Commissions call for evidence on the Green Claims Directive SUMMARY 1. The Advertising Information Group (AIG) (transparency number: 11220347045-31) welcomes the opportunity to respond to the European Commissions call for evidence on the Directive on substantiation and communication of explicit environmental claims (Green Claims directive) published in March 2023. 2. First and foremost, AIG supports the EU Commission's overarching goal of strengthening consumer protection against unfair practices and ensuring that they can make informed decisions about their purchases. It is in the interest of both consumers and businesses to prevent misleading claims and promote the exchange of credible information. 3. Secondly, AIG supports sensible and proportionate regulations to the extent that they are intended to prevent misleading environmental claims ("greenwashing"). However, we would be against any regulations that lead to bona fide environmental product improvements not being advertised anymore or so-called "green hushing". Green hushing describes the phenomenon whereby companies shy away from communicating genuine green claims because the requirements are bureaucratic, complex or cost prohibitive. This would likely inhibit innovation as it would reduce incentives and competitive advantages. We would advocate for rules that make it easier for reputable companies to promote their products and services especially if they have credible and evidenced environmental claims. 4. Finally, we think it is worth bearing in mind the challenging economic circumstances that companies are experiencing across Europe, with inflationary pressures and tight labour markets. These challenges should not be underestimated when designing a compliance regime. Our detail feedback is attached.
Read full responseResponse to Measures addressing the environmental impact of imaging equipment including consumables
20 Feb 2023
On behalf of the European advertising and media associations we represent, the Advertising Information Group (AIG) (transparency number: 11220347045-31), we welcome the opportunity to respond to the European Commissions call for evidence on Environmental impact of imaging equipment, including consumables. We broadly agree with the initiatives principal goals of explore how to make imaging equipment more material- and energy-efficient. We also agree with an approach designed to give an appropriate level of consumer protection. Whilst advertising is not within the scope of this call for evidence, we wanted to take this opportunity to highlight the role of advertising during the purchasing journey and the positive effect it can have on behavioural change and nudging consumers towards more sustainable purchasing decisions. However, we would counsel against any initiatives that would impose important and complex mandatory information requirements in the advertising itself. Such information is better delivered at point of sale, as this is generally the point when a consumer makes the purchase decision. Given the restrictions of advertisement size and or segment length it is extremely difficult to convey complex information and may be counterproductive. Consumer research has shown that mandatory information in advertising is not impactful and is often ignored , as consumers struggle to absorb or retain long and detailed additional information and figures. Advertising primarily serves to convey the availability of a product or service. It is not intended or designed to deliver complex information. Additionally, there are well established self-regulatory advertising Codes of Practice which set stringent standards, including on environmental issues. The self/co-regulation of advertising has been designed to complement the comprehensive legal framework for consumer protection that already exists, such as the Unfair Commercial Practices Directive (UCPD), which contains rules on misleading environmental claims. Promoting the circular economy is an important objective for the EU and it is critical for Europe to meet its climate and environmental targets. We are not advocating for advertising to be included in the scope of this legislation, merely to highlight the positive role that advertising can play in encouraging behaviour change and promoting sustainable choices. Advertising also has an important contribution to the European economy. Not only is it critical to the funding of a free and independent media, it also drives competition and innovation. It is via a clear legislative framework and competitive effects that manufacturers will be driven to develop more efficient and recyclable materials for longer lasting products. To that end we think that advertising can accelerate consumer take up of such products and hence provide the incentivise for manufacturers to invest more in innovation thereby creating a virtuous circle.
Read full responseResponse to European Media Freedom Act
23 Jan 2023
On behalf of the European advertising and media associations we represent, the Advertising Information Group (AIG) (transparency number: 11220347045-31), writes to respond to the European Commissions consultation on new rules to safeguarding media freedom in the EU. Advertising makes an important contribution to the European economy, and it is critical to the funding of a free and independent media. AIG supports the EUs overarching objective to protect media pluralism and independence in the EU and note that a free and well-funded media is a key pillar of democracy and economy. Audience measurement is an important component of advertising, and this is well recognised within the recitals. It measures how many people are in radio listenership, publication readership, television and online video viewership. Systems that measure audiences are an important tool to evaluate the effectiveness of advertising, its reach and provide other insights. It is also an important factor in setting media pricing and for forecasting future advertising spend. It is crucial that audience measurement systems are as transparent and verifiable as possible, to promote and foster a fair and competitive market. AIG supports all efforts to make the methods of audience measurement transparent, as these can be interpreted differently by individual market participants due to different standards. Whilst Article 23 addresses audience measurement, we doubt that it will achieve the objectives set out in Recitals 9 and 45 as it is currently drafted. The current scope might not reach out to the "new actors" mentioned in the recitals. Audience measurement is a complex topic, and we would welcome engagement by the Commission with industry on this issue to identify market failures and information asymmetries that cannot be resolved by industry participants themselves. For example, we are aware of industry initiatives such as Project Origin, which is a collaboration between the Incorporated Society of British Advertisers and the World Federation of Advertisers to develop a standardised approach, with advertisers at front of mind, to video and display measurement or a common measurement approach across media, particularly across digital platforms and between digital platforms and broadcaster TV. This system is still under development, but it is not the same as a Joint Industry Committee (JIC) nor is it restricted to certain online players. It is important therefore that the European Media Freedom Act does not inadvertently stymie ongoing or future innovation in this area. Fundamentally, we support the broad objective of transparency and fair competition in the marketplace. Any new requirements should of course reflect similar standards upheld for television broadcasters and existing JICs ensuring a common baselines for robust and reliable audience measurement to the benefit of the broader media ecosystem.
Read full responseResponse to Transparency of political advertising
31 Jan 2022
Please see attached file - a response from the Advertising Information Group (AIG).
Read full responseResponse to Environmental impact of mobile phones and tablets - Energy Labelling
25 Jan 2021
AIG comments on inception impact assessment: Energy labelling of mobile phones and tablets – informing consumers about environmental impact - Ares(2020)7893117
Please find full response attached.
On behalf of the European advertising and media associations we represent, the Advertising Information Group (AIG) writes with concern over the European Commission’s energy labelling proposals included in the ‘Environmental impact of mobile phones’ inception impact assessment.
Whilst we agree with the Commission's aim to meet consumer demand for sustainable products using an appropriate level of consumer protection, it is, however, important not to burden the consumer with complicated labelling information nor is it appropriate to include such information in advertisements. This would be ineffective and counterproductive.
We believe that informing consumers at the point of sale is the most appropriate way to provide them with the necessary consumer protection information, including the environmental impact of a particular product. It is at this point that the decision to buy a particular product is made.
We encourage the Commission to focus on improving the information at the point of sale only to improve the effectiveness of the energy labelling information. This would complement the significant role already played by the free media and advertising industry in promoting sustainable consumption. Moreover, it would avoid additional and unnecessary costs which would jeopardise the press and media financing, which has already been severely affected by the COVID-19 pandemic.
Read full responseResponse to Empowering the consumer for the green transition
6 Aug 2020
On behalf of the European advertising and media associations it represents, the Advertising Information Group (AIG) welcomes the Commission's aim to meet consumer demand for sustainable products and services in the future through better and more uniform information. The provision of accurate, reliable, comprehensible and consumer-friendly information with regard to criteria such as reparability, shelf life, etc. can make an important contribution to a more sustainable society which we all support.
We agree with an approach designed to give an appropriate level of consumer protection. Existing advertising Codes of Practice, which already set stringent standards, recognise this with rules on environmental claims. However, care must be taken not to burden the consumer with over-complicated information in advertisements as this would be counter-productive.
This consumer legislative initiative, which was first announced in the Circular Economy Action Plan, proposes various regulatory approaches. Despite the multi-dimensional proposal, we will limit our contribution on the information aspect.
We believe that informing consumers at the point of sale is the most appropriate way to provide them with the necessary consumer protection information, as it is at this point that the decision to buy a particular product is made.
By contrast, advertising, as a commercial communication, has a different function: it draws consumers' attention to a product or group of products and often encourages them to look more closely at relevant investments. A concrete purchase decision, for which the aspects of sustainability can be an important element, is not yet made here.
It is also important to note that consumer research has shown that mandatory information in advertising is not very impactful and often ignored, as consumers struggle to absorb or retain long and complex additional information and figures. Moreover, mandatory information requirements with regard to advertising would lead to this form of communication becoming less attractive for advertisers in the future due to higher costs and, by reducing the time period of the freely designable sequences, the information content on sustainability aspects would also decline.
Improving information requirements at the point of sale would also be in line with the reasonable compromise found at EU level in the past decade between mandatory product information for all consumers and the advertising freedom, as well as the financing of the free press and media.
Advertising primarily serves to advocate for a business or product, not necessarily to increase overall consumption, but to encourage a consumer to choose one product over a competitor’s. With environmental impact becoming an increasingly important factor for consumers, advertising already informs the public on how ‘green’ a product is, and drive companies to improve their ecological practices.
For the reasons above, we encourage the Commission to focus on improving the information at the point of sale only. As this has been identified as a main weakness in the current situation, addressing this aspect will already substantially improve the status quo and complement the already significant role played by the free media and advertising industry. At the same time, any advertising restriction would disproportionately hurt sectors which have been severely affected by the COVID-19 pandemic, and further jeopardize press and media financing, potentially putting the existence of the sector at risk. Hence, it would even be counterproductive for providing information about environmental issues to consumers.
With regard to better enforcement of consumer protection rules, we would point to the new deal for consumer proposals, which have been adopted over the past year, and which have not been transposed yet. It would therefore be advisable to assess the effectiveness of the new rules first.
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