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European Association of Communications Agencies

EACA

The European Association of Communications Agencies represents over 2,500 advertising, media, and PR agencies across Europe.

Lobbying Activity

Meeting with Dóra Dávid (Member of the European Parliament) and 5Rights Foundation

7 Oct 2025 · Event: children’s digital safety and wellbeing

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

28 Jul 2025 · Protecting minors online

Meeting with Michael McGrath (Commissioner) and

20 May 2025 · Exchange of views on advertising and communications agencies

Meeting with Egelyn Braun (Cabinet of Commissioner Michael McGrath)

6 May 2025 · Preparatory meeting ahead of the meeting between EACA’s members and the Commissioner

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and Bureau Européen des Unions de Consommateurs and

19 Mar 2025 · Code of Conduct on Online Advertising – Workshop 4

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 Marco Giorello (Head of Unit Communications Networks, Content and Technology) and EuroCommerce and

6 Mar 2025 · Code of Conduct on Online Advertising – Workshop 2

Meeting with Marco Giorello (Head of Unit Communications Networks, Content and Technology) and EuroCommerce and

4 Mar 2025 · Code of Conduct on Online Advertising – Workshop 1

Meeting with Daniel Freund (Member of the European Parliament)

22 Jan 2025 · Exchange about sustainability in the advertising sector

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur) and ITI - The Information Technology Industry Council

15 Jan 2025 · discussions on Green Claims Directive

Meeting with Lynn Boylan (Member of the European Parliament, Shadow rapporteur)

15 Jan 2025 · Green Claims Directive

Meeting with Emma Wiesner (Member of the European Parliament, Shadow rapporteur)

14 Jan 2025 · Green Claims

EACA urges flexible EU guidelines for protecting minors online

30 Sept 2024
Topic — EU consultation on safety and privacy guidelines for minors on digital platforms.
Message — The group requests "workable definitions" of age-inappropriate content and a "tiered approach" for personalized advertising instead of bans. They urge the Commission to "continue encouraging self-regulation" and support "phased implementation" to lower costs.123
Why — These measures would "minimise the administrative burden" and avoid "significant additional compliance costs" for agencies.45
Impact — Minors may face lower privacy standards if "personalised advertising" is permitted under "flexible measures."67
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Response to Interim Evaluation of Digital Europe

20 Sept 2024

Summary of EACAs Submission to the Public Consultation on the Digital Europe Programme The European Association of Communications Agencies (EACA), representing over 2,500 agencies across Europe, appreciates the opportunity to provide feedback on the Digital Europe Programme. EACAs members are vital to Europes creative economy, driving innovation, cultural expression, and economic growth. The submission outlines how communication agencies can support Europes digital transition, with specific recommendations for digital innovation, sustainability, cross-sector collaboration, and ethical data use. 1. Driving Digital Innovation in Communications Communication agencies increasingly rely on AI, big data, and analytics to optimise campaigns and personalise content. However, to stay competitive, they require better access to advanced digital tools and skills development. EACA recommends: - Increased funding for AI and data-driven technologies tailored to the needs of communication agencies. - Training programmes to help agencies integrate these technologies into their workflows. - Enhanced collaboration with tech developers to ensure agencies have access to cutting-edge digital tools. 2. Inclusion of Commercial Communications Commercial communications, such as advertising, play a key role in shaping European culture and driving economic growth, yet they remain underrepresented in EU funding programmes. EACA recommends: - The full integration of commercial communications into the Digital Europe Programme, recognising its cultural and economic impact. - Dedicated funding for culturally significant campaigns that highlight Europes values. - Support for cross-sector collaborations with creative industries to encourage innovation and global competitiveness. 3. Support for Sustainability and Green Claims Directive Communication agencies play a crucial role in promoting sustainability and supporting the EUs Green Deal objectives. EACA emphasises the importance of transparent green messaging, particularly with the development of the Green Claims Directive. Recommendations include: - Funding for sustainability-focused campaigns that promote eco-friendly behaviours and responsible consumption. - Incorporating industry feedback into the finalisation of the Green Claims Directive, along with training for agencies to ensure compliance and transparency in sustainability communications. 4. Cross-Sector Collaboration for Innovation Collaboration between communication agencies and industries such as technology, film, and arts is essential to driving innovation. EACA recommends: - Funding for joint projects that bring communication agencies together with tech developers and creative industries. - Support for platforms that foster collaboration on emerging technologies like AI, AR, and VR to keep Europes creative sector globally competitive. 5. Ethical Use of Data The ethical use of data is critical for maintaining consumer trust in an increasingly data-driven environment. Communication agencies need guidance and tools to navigate complex data regulations. EACA suggests: - Funding for tools that help agencies implement transparent data practices. - Training on ethical data management and compliance with GDPR. - Collaboration with tech developers to balance data-driven marketing with privacy protections, ensuring agencies remain competitive while building consumer trust. Conclusion EACA supports the Digital Europe Programmes objectives to enhance Europes digital and creative sectors. Communication agencies are pivotal to Europes digital transformation and cultural economy. By providing funding, supporting innovation, and promoting skills development, the programme can ensure that Europes communication agencies remain globally competitive and culturally influential.
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EACA urges clarity on EU rules for green advertising

13 Jul 2023
Topic — New EU rules requiring companies to prove environmental claims using footprint methods.
Message — EACA requests a clearer definition of environmental claims to include visuals and audio. They seek specific guidance for different advertising mediums and propose that EU labels exempt companies from case-by-case verification.123
Why — This would reduce compliance costs by allowing advertisers to avoid case-by-case verification.4
Impact — Consumers may be misled if broad environmental campaigns disguise a product's actual impact.5
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Response to Empowering the consumer for the green transition

27 May 2022

EACA welcomes the possibility to provide feedback on the initiative of the Proposal to amend Directive 2005/29/EC (“Unfair Commercial Practices Directive”). We strongly believe that the advertising sector plays a significant role in enabling consumers to make clear and educated choices and see the Proposal as the right approach to enhance consumer protection related to environmental claims. Aware of its responsibility, the advertising sector has for many years contributed to adopt high self-regulatory standards regarding environmental claims in advertising. While we believe that changes to the Unfair Commercial Practices Directive can foster both consumer trust and the competitiveness of the European Single Market, it is however important that these amendments consider existing self-regulatory practices and that additional legislation can be efficiently enforced by the relevant stakeholders. To this end, we would like to submit several comments on the proposed legal framework which mainly tackle : 1. the scope of environmental claims 2. examples of generic environmental claims 3. the substantiation process of green claims through labeling Please read our Position Paper attached for further information. I you have any questions, do not hesitate to reach out to: Alexis Bley Public Affairs Manager EACA – European Association of Communications Agencies +32 2740 07 18 | alexis.bley@eaca.eu
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Response to Transparency of political advertising

28 Jan 2022

We welcome the opportunity to provide feedback on the proposal for a Regulation on the transparency and targeting of political advertising, as adopted by the European Commission, ahead of the discussions in the European Parliament and in the Council. We kindly invite everyone to read our full submission in the attachment.
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Response to Requirements for Artificial Intelligence

15 Jul 2021

The European Association of Communications Agencies (EACA) represents more than 2,500 communications agencies and agency associations from nearly 30 European countries that directly employ more than 120,000 people. EACA members include advertising, media, digital, branding and PR agencies. We support the objectives of the Proposal for an AI Regulation, namely to proportionately address the risks associated with certain uses of AI and to ensure legal certainty to facilitate investment and innovation in the sector. However, we believe that some of the concepts used in the Proposal for an AI Regulation remain rather vague and would merit further clarification in order for providers to better understand what is expected from them and to ensure legal certainty. We understand that certain requirements of Proposal for an AI Regulation apply to providers of high-risk AI systems and that they will need to subject their AI systems to conformity assessments that demonstrate that the system complies with certain requirements. We believe that these requirements need to be better defined. You can find more details in the attached comment.
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Response to Guidance on tackling disinformation

27 Apr 2021

The European Association of Communications Agencies (EACA) welcomes the opportunity to provide feedback on the guidance on strengthening the Code of Practice on Disinformation. Please find our feedback attached.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

23 Feb 2021

EACA, the European Association of Communications Agencies, welcome the European Commission’s intention to maintain the core principles of the e-commerce Directive, including its conditional intermediary liability regime, the absence of a general monitoring obligations, and the country-of-origin principle. These principles enabled the growth of the digital economy in Europe and expanded access to information. Maintaining the principles and improving them by adding protections for voluntary efforts to moderate content, will further foster innovation, allow also SMEs to thrive and protect fundamental rights. We welcome and support the Commission’s objective to improve the safety of users online and to make sure that they have access to a wide choice of safe products and services. You will find our detailed comments attached.
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Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

23 Feb 2021

EACA, the European Association of Communications Agencies, and its members welcome the Commission’s intentions to make sure that businesses operating and competing in the digital sector can do so freely and fairly. We are pleased to note that one of the major concerns we raised in relation to the platform-to-business regulation has eventually been integrated into the present proposal. We explained that agencies rely on platforms’ transparency to assess the success of campaigns and decide on investments. Therefore, it is crucial that platforms allow so-called third-party verification companies access to relevant data in order to measure the success of campaigns against a standardised set of criteria. With regards to the present proposal, we would like to share the attached comments with the Commission.
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Response to Transparency of political advertising

23 Feb 2021

EACA welcomes the possibility to provide feedback on the European Commission’s roadmap on political advertising . EACA fully supports the overall objective of the initiative, which has also been laid out in the political guidelines of Commission President Ursula von der Leyen, notably to “ensure greater transparency on paid political advertising” . This is particularly true now that political campaigning increasingly moves online. A common set of rules in this field is not only essential to ensure the digital single market, i.e. making it possible and easier to advertise across EU borders. Having the right to express and disseminate one’s political views and messages – which includes advertising them - is a building block of democratic participation and European society. We have to be absolutely clear about the objective of this initiative, namely to regulate, i.e. increase transparency, and not to regulate, i.e. restrict the freedom of speech. With this in mind, we would like to share the following comments regarding the Commission’s inception impact assessment, which you can find attached.
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Response to Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

10 Dec 2020

EACA welcomes the opportunity to provide feedback on the Draft Implementing Decision (Ref: Ares(2020)6654686) and Annex (Ref: Ares(2020)665468) on standard contractual clauses for the transfer of personal data to third countries pursuant to the General Data Protection Regulation (GDPR). EACA represents more than 2,500 communications agencies and agency associations from nearly 30 European countries that directly employ more than 120,000 people. EACA members include advertising, media, digital, branding and PR agencies. We would like to share the attached concerns and suggestions for improvement on behalf of our membership.
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Meeting with Maria Elena Scoppio (Cabinet of Commissioner Paolo Gentiloni)

30 Sept 2020 · Digital Tax Services

Response to Requirements for Artificial Intelligence

4 Aug 2020

EACA welcomes the opportunity to give feedback on this roadmap where we would like to reiterate the points made during the Commission’s public consultation on its White Paper on Artificial Intelligence: On the trustworthy use of Artificial Intelligence From our industry’s point of view, concerns with AI are an extension of concerns with data use overall. AI exacerbates the risks involved in data use because of opaque decisioning, opaque use or opaque responsibility. However, the risks that are often associated with AI can be mitigated. For example, in the case of fundamental rights, through compliance with regulations, adherence to data processing standards for robustness, accuracy and security, or ethics guidelines and policies for data sets, goals and algorithms, application of decisions. Discriminatory outcomes can be mitigated through the use of bias detection software on data sets, goals and algorithms as standard. To be able to explain the rationale, record keeping for data sets, goals, algorithms is important, as well as recording decision making at the same time as decisions taking, and testing outcomes with different input data. The risk of low AI accuracy can be mitigated through the adherence to data processing standards; explicit statements of accuracy expectations; explicit statements of responsibility for accuracy (at company/team/individual level). On the consideration of different policy options We think that the concerns expressed by the Commission or the High Level Expert Group can be fully addressed through applicable EU legislation. The challenge is the definition of high-risk sectors or industries. It is the purpose of the AI model use that is key, not the industry. It is impossible to predict the long term impact of behaviour, therefore it is highly difficult to assume that we can know which industries are or will be high-risk in the future. If new compulsory requirements had to be introduced, these should be limited to high-risk applications whereas a proper definition of high risk needs to be agreed. The challenge is the definition of high-risk sectors or industries. It is the purpose of the AI model use that is key, not the industry. It is impossible to predict the long term impact of behaviour, therefore it is highly difficult to assume that we can know which industries are or will be high-risk in the future. Regarding the possibility of a voluntary labelling system, we would not be opposed to such a system. However, we believe that is unlikely to work Any of the requirements suggested in the White Paper and in this consultation will add cost, effort and paperwork without providing a competitive advantage – thereby lacking an incentive.
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Response to Fairness in platform-to-business relations

21 Jun 2018

EACA welcomes the opportunity to provide comments on the European Commission’s proposal for a Regulation on promoting fairness and transparency for business users of online intermediation services (COM(2018)238/974102). EACA already submitted a response to the Inception Impact Assessment in November 2017. Advertising and media agencies work closely with platforms, such as Google and Facebook, and must be able to rely on fair, transparent and balanced trading practices. EACA therefore endorses the proposed rules on terms and conditions, ranking and redress. According to the proposal, however, platforms would still be able to deny access to certain metrics to business partners, which would allow businesses to objectively assess the effectiveness of campaigns and consider investment decisions. Instead, agencies are forced to accept platforms’ own self-declared numbers, which is contrary to the way in which media delivery is verified on any other media channel. EACA therefore calls on the European Commission to include a provision which would allow businesses to employ third party auditors to verify platforms’ metrics.
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Response to Fair taxation of the digital economy

15 May 2018

The European Association of Communications Agencies (EACA) welcomes the opportunity to provide comments and clarifications on the Commission’s proposals related to the “Fair taxation of the digital economy” (COM (2018) 147 & 148). 1. General remarks on taxation EACA's members are incorporated or have a physical presence in the EU. Their services are subject to national tax. We understand that the Commission’s primary intention is to fairly and efficiently tax “digital activities” of companies that do not have a physical presence in the EU but still have large audiences in those countries. We do not believe that the draft Directives aim to cover agencies. Nevertheless, the Commission’s proposals risk - agencies to be taxed multiple times for providing one and the same service to their clients, i.e. advertisers (e.g. buying ad space on behalf of their clients) - agencies to be taxed for services that they do not provide (e.g. placing an ad) - agencies and advertisers to suffer from an increase of media prices, as platforms are likely to pass on the additional taxation costs to them. This will distort competition and counter the initial intention of the proposed measures, namely to tax a digital interface and not the businesses using their services. - offsetting the current tax system, which would create an uneven level playing field of entities with a physical presence in the EU and those that have a ‘digital presence’, while threatening to double tax the entities that might fall into both categories - substantially intruding into users’ privacy in order to determine the place of taxation, which is likely to be in conflict with the GDPR and appears disproportionate regarding the additional tax income expected by the Commission. 2. Comments on the Digital Services Tax The current draft of the Digital Services Tax Directive (DST) seems to suggest that, with regard to digital advertising, it applies to intermediaries in the supply chain rather than digital media owners. As a result, the DST would be levied on companies which already have a taxable presence in a country by virtue of their business activity (a significant number of employees, office space and associated infrastructure) and already pay full corporate taxes on their profits. Should the Council agree to move forward with the Commission’s proposal, we believe that such a tax should only apply where there is a misalignment between the place where the profits are taxed and the place where value is created. Articles 2 and 3 should then be amended to make clear that the DST only applies to companies - that carry out a digital activity in countries where they do not have a physical presence - where they can conduct activities remotely by virtue of being a digital business - or where a company has a permanent establishment in the jurisdiction where the users are located; the value created by user participation is not taken into account when deciding how much tax should be paid in each country. 3. Clarifications on placing of advertising We also feel that the concept of the “placing on a digital interface of advertising” needs clarification. It is our understanding that the Commission aims to capture the act of selling of ad space by a platform, rather than the placing of an advertisement, which covers buying ad space (from a platform). Platforms provide the opportunity for ads to be delivered/placed/seen on their sites and are paid for the advertising space, i.e. the service of providing that space. Platforms own ad space and sell it to agencies (who buy the space on behalf of their clients), advertisers or other third parties. We would assume that, when referring to “placing advertising”, the Commission refers to the selling of ad space. Accordingly, an agency’s purchase of advertising space from platforms on behalf of their clients would not fall under the draft proposal’s definition of “placing on a digital interface of advertising”.
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Response to Fair taxation of the digital economy

15 May 2018

The European Association of Communications Agencies (EACA) welcomes the opportunity to provide comments and clarifications on the Commission’s proposals related to the “Fair taxation of the digital economy” (COM (2018) 147 & 148). 1. General remarks on taxation EACA's members are incorporated or have a physical presence in the EU. Their services are subject to national tax. We understand that the Commission’s primary intention is to fairly and efficiently tax “digital activities” of companies that do not have a physical presence in the EU but still have large audiences in those countries. We do not believe that the draft Directives aim to cover agencies. Nevertheless, the Commission’s proposals risk - agencies to be taxed multiple times for providing one and the same service to their clients, i.e. advertisers (e.g. buying ad space on behalf of their clients) - agencies to be taxed for services that they do not provide (e.g. placing an ad) - agencies and advertisers to suffer from an increase of media prices, as platforms are likely to pass on the additional taxation costs to them. This will distort competition and counter the initial intention of the proposed measures, namely to tax a digital interface and not the businesses using their services. - offsetting the current tax system, which would create an uneven level playing field of entities with a physical presence in the EU and those that have a ‘digital presence’, while threatening to double tax the entities that might fall into both categories - substantially intruding into users’ privacy in order to determine the place of taxation, which is likely to be in conflict with the GDPR and appears disproportionate regarding the additional tax income expected by the Commission. 2. Comments on the Digital Services Tax The current draft of the Digital Services Tax Directive (DST) seems to suggest that, with regard to digital advertising, it applies to intermediaries in the supply chain rather than digital media owners. As a result, the DST would be levied on companies which already have a taxable presence in a country by virtue of their business activity (a significant number of employees, office space and associated infrastructure) and already pay full corporate taxes on their profits. Should the Council agree to move forward with the Commission’s proposal, we believe that such a tax should only apply where there is a misalignment between the place where the profits are taxed and the place where value is created. Articles 2 and 3 should then be amended to make clear that the DST only applies to companies - that carry out a digital activity in countries where they do not have a physical presence - where they can conduct activities remotely by virtue of being a digital business - or where a company has a permanent establishment in the jurisdiction where the users are located; the value created by user participation is not taken into account when deciding how much tax should be paid in each country. 3. Clarifications on placing of advertising We also feel that the concept of the “placing on a digital interface of advertising” needs clarification. It is our understanding that the Commission aims to capture the act of selling of ad space by a platform, rather than the placing of an advertisement, which covers buying ad space (from a platform). Platforms provide the opportunity for ads to be delivered/placed/seen on their sites and are paid for the advertising space, i.e. the service of providing that space. Platforms own ad space and sell it to agencies (who buy the space on behalf of their clients), advertisers or other third parties. We would assume that, when referring to “placing advertising”, the Commission refers to the selling of ad space. Accordingly, an agency’s purchase of advertising space from platforms on behalf of their clients would not fall under the draft proposal’s definition of “placing on a digital interface of advertising”.
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