Commissioner for Democracy, Justice, the Rule of Law and Consumer Protection,
Michael McGrath
Minister for Culture
Ministry of Culture
2 Nybrogade
DK-1203 Copenhagen K
Tel
: +45 33 92 33 70
E-mail : [email protected]
Web
: www.kum.dk
Dear Commissioner McGrath,
The date of the entry into force of the Regulation on the transparency and targeting of
political advertising is approaching. This is a cause for concern in Denmark.
Our concerns relate to our upcoming municipal elections and other upcoming elections
across Europe taking place in the immediate aftermath of the regulation taking effect.
The Danish municipality elections will take place on 18 November 2025, just after the
regulation enters into force (10 October 2025).
In this context, I would like to highlight that we still await the implementing acts con-
cerning Article 11 on labelling and transparency requirements and Article 12 on trans-
parency notices. I understand that the Commission will adopt these on 10 July 2025.
Furthermore, the application of Article 13 remains unclear, considering that the imple-
menting act for this article still needs to be adopted.
This creates legal uncertainty for all parties involved, as preparations for the municipal
elections have been well underway at the local level for quite some time. I therefore fear
that it will be difficult to comply with the rules at such short notice. In practice, this
means that the municipal elections have been planned without the stakeholders having
full certainty of the legal framework. It has become clear to me that the stakeholders
are concerned that their current preparations may unintentionally result in breaches of
these rules.
Another consideration in this regard is that given the size of the 98 municipalities, the
politicians running in the local elections rarely have the financial resources to change
their campaign advertising with short notice.
I therefore request your assistance in finding a manageable transition solution for mem-
ber states that are conducting elections in the immediate aftermath of the Regulation
taking effect. Especially considering that the rules will only be defined and applied af-
ter local actors have prepared, created and placed orders for the political advertising for
the elections in question.
Dok. nr. 215889