Examine My Adverts Institute submitted formal feedback on October 20, 2025, difficult the Media Rating Council’s proposed Digital Advertising Auction Transparency Standards. The watchdog group warned that the framework dangers legitimizing opacity and cementing a two-tier system favoring main expertise firms.

The submission outlines elementary issues about governance, enforcement mechanisms, and preferential therapy of closed-loop auctioneers. In accordance with the feedback, the proposal would enable MRC members to craft, vote on, and probably obtain accreditation beneath the identical framework, undermining independence between the accrediting physique and accredited corporations.

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Governance issues elevate independence questions

The digital promoting business faces a belief disaster spanning over a decade. Advertisers proceed to fund unlawful and dangerous content material whereas dropping visibility into media spending. In accordance with Examine My Adverts, untold billions are misplaced to advert fraud schemes.

The group’s submission emphasizes that MRC’s recognition of the necessity for requirements needs to be applauded. Nevertheless, ambiguous, lax, or unenforced requirements would exacerbate opacity, mislead market individuals, and hurt competitors.

The composition of the Steer Crew for the transparency initiative raises questions on conflicts of curiosity. Every participant derives income from huge tech firms with vested pursuits and sources to affect requirements. These firms can subtly form technical proposals to align with industrial pursuits to the detriment of rivals and different market individuals.

MRC traditionally accredited measurement companies, which had been precluded from membership in keeping with the group’s Voluntary Code of Conduct equipped to Congress in 2009. The proposed requirements would cement MRC’s departure from this precept by increasing the apply of permitting members to craft, vote on, and probably be accredited beneath frameworks they assist create.

This dynamic undermines vital independence between MRC because the accrediting physique and corporations it accredits. As extra paying members additionally search accreditation—significantly huge tech firms with vital market leverage—MRC ought to guarantee its governance mannequin is fit-for-purpose. The group ought to search authorities assessment of its actions because it has accomplished beforehand.

Framework marks vital scope growth

The MRC’s proposal to difficulty accreditations for Public sale Transparency basically differs from its historic actions accrediting measurement companies. The Broadcast Score Council, now the Media Score Council, was established roughly sixty years in the past following the Harris Committee hearings.

The promoting market has modified drastically since that point, alongside the scope and nature of companies MRC accredits. Congress has not since re-evaluated whether or not the high-frequency advert tech market ought to nonetheless be business regulated. This consideration turns into significantly related towards the backdrop of market monopolization and large affect wielded by a small handful of dominant corporations over all features of the business, together with standard-setting organizations.

MRC beforehand sought DOJ assessment beneath the Enterprise Assessment Process for a lot narrower adjustments to its packages. The present commonplace is greater than an adjustment to MRC’s methodology or procedures. It reaches into public sale mechanics, bid-level knowledge disclosure, provide chain transparency, governance of DSPs and SSPs, and closed-loop platform algorithms.

These areas are more likely to implicate vertical restraints, market energy, anti-competitive self-preferencing, and factors of management. The focus of energy within the digital promoting market makes these concerns particularly vital.

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Enforcement mechanisms stay absent

Essentially the most obtrusive omission from MRC’s proposed requirements is the seemingly full absence of enforcement mechanisms. The time period “enforcement” seems solely thrice within the requirements doc. The place talked about, MRC vaguely references necessities for Auctioneers to implement their insurance policies and stock high quality requirements.

The doc doesn’t define particular necessities for enforcement. It doesn’t element the MRC’s personal revised enforcement posture as soon as requirements are revealed.

MRC’s requirements are voluntary. Audits for example conformity to requirements are additionally voluntary. Distributors submitting for accreditation accomplish that voluntarily. Nevertheless, the vast majority of provisions within the requirements are themselves voluntary.

If an accredited service is came upon of compliance with transparency requirements throughout an audit, the implications stay unclear. Maybe extra importantly, how might a discovering of non-adherence happen when so few provisions are denoted as necessities?

For instance, do candidates looking for renewal however discovered non-compliant routinely lose accreditation? Is a warning issued to return into compliance? In that case, what’s the probationary interval? Is there any punitive mechanism that may incentivize compliance?

MRC’s governing paperwork seemingly comprise ambiguity round enforcement, or disciplinary procedures. Whereas the Voluntary Code of Conduct acknowledges {that a} Taking part Measurement Service can face suspension from participation, publication of non-compliance, or different Disciplinary Motion, the procedures for arriving at such selections are contained in one other personal doc.

To the extent that there’s better readability on how MRC decides to take enforcement motion, in apply MRC has traditionally seemingly didn’t persistently pursue enforcement. As an alternative, the group relied on loopholes and technicalities in its requirements to level to why such motion shouldn’t be vital.

Closed-loop auctioneers obtain preferential therapy

The Closed-Loop Advert Auctioneer framework successfully codifies a decrease commonplace of transparency for vertically built-in platforms that already possess overwhelming market energy. By excusing walled gardens from log-level auditability and permitting generalized disclosures instead of knowledge entry, the draft creates an asymmetrical compliance regime favoring the biggest and least clear actors.

OpenRTB provisions explicitly state that auctioneers and intermediaries ought to present reporting to purchaser customers. This contains disclosure of common guidelines for demand sources the place permissible, pricing and winner willpower inclusive of things that apply to and have an effect on worth. Efforts needs to be made to report OpenRTB parameters to purchaser finish customers.

Closed-Loop provisions solely stipulate that the public sale sort and technique for calculating second-price and modified second-price needs to be disclosed. Variables needs to be made identified generally and reported the place utilized.

Whereas it’s explicitly acknowledged that OpenRTB reporting ought to embody sure identifiable parameters and transaction-level elements, this seems to indicate that Closed-Loop reporting can depend on common disclosures.

OpenRTB necessities specify that each the SupplyChain object and SupplyChainNode object needs to be used to fullest extent and be full. Shopping for platforms ought to present reporting towards each the Transaction ID and RequestID object to all patrons.

No comparable requirement codifying particular fields that should be supplied to allow transaction-level traceability exists for Closed-Loop auctioneers. Whereas OpenRTB provisions theoretically would allow transaction-level traceability in OpenRTB auctions, a comparable requirement is absent from the Closed-Loop part.

The OpenRTB provisions explicitly encourage use of Open Measurement SDK, Adverts.txt 1.1, and different IAB Tech Lab instruments to facilitate third-party entry to measurement knowledge. No point out of SDKs or exterior interoperability requirements seems for Closed-Loop auctioneers.

Fairly than encourage comparable interoperability or knowledge transparency from Closed-Loop auctioneers, MRC successfully exempts them.

Requirements should align with antitrust cures

The MRC’s framework touches upon items of potential cures in each DOJ antitrust instances towards Google. These embody disclosure of fabric adjustments to advert auctions included within the Search cures determination, in addition to the DOJ’s proposal for Google to open-source DFP’s closing public sale logic.

To the extent that MRC intends to permit reference to this commonplace to by some means exhibit or assist Google’s compliance with court-ordered cures, the requirements as proposed are inadequate. MRC lacks the requisite independence. Ernst & Younger, as MRC’s chosen auditor, additionally has a point of battle, because it acts as Google’s personal auditor.

The DOJ’s proposals for public sale transparency within the context of Google’s writer advert server are much more prescriptive, lending themselves to true auditability. If MRC goals to boost the bar for the business, it also needs to require actual, substantive unbiased audits by technically certified unbiased auditors that transcend attestation and documentation.

It is usually unclear why MRC elected to exclude Prebid auctions from its transparency commonplace. The rationale for this needs to be made clear to keep away from contributing to market confusion. MRC has acknowledged up to now the place certification scope and limitations usually are not readily understood by the market.

Requirements ought to incorporate privateness protections

OpenRTB advert auctions elevate client privateness and knowledge safety issues, that are expressly prevented by MRC’s urged requirements. The potential for knowledge leakage all through the RTB course of is huge. The public sale broadcasts giant quantities of packaged, aggregated knowledge about shoppers that can be proven to probably 1000’s of advertisers, or quite their automated proxies by way of varied adtech platforms.

This course of additionally incentivizes knowledge brokers to take advantage of the RTB course of and bid on advertisements to realize entry to large quantities of client knowledge. With out transparency necessities surrounding bidding in auctions, this apply might go on unmitigated.

Within the Federal Commerce Fee’s litigation towards Mobilewalla, the Fee alleged that the corporate collected delicate location details about shoppers and bought it to 3rd events with out specific client consent. This data was later bought to advertisers to be used in focusing on shoppers with ads, contributing to the RTB course of by offering correct location knowledge within the public sale bidding course of, making it accessible to 1000’s of bidders, even when just one bidder wins.

Fairly than sidestep current regulatory necessities, MRC is able to handle this hole. The group ought to embody in its commonplace the requirement for OpenRTB Auctioneers to incorporate fields that may enable for the identification of entities merely harvesting bidstream knowledge. These embody the loss discover URL and standardized loss purpose codes to detect anomalous patterns of habits and different types of abuse.

MRC ought to require that Auctioneers, as a part of qualification necessities, prohibit the gathering, distribution, and storage of knowledge uncovered in bid responses for auctions by which Auctioneers didn’t win. Auctioneers ought to implement this prohibition. The mechanism for this could doubtless be attestation. Nevertheless, with this dedication, MRC is well-positioned to implement towards any Auctioneers discovered to have didn’t implement this prohibition.

Omissions in SDK and cellular app requirements

The MRC doesn’t point out the usage of or auditing of software program growth kits for monetization by Closed-Loop Advert Auctioneers. SDKs are considered one of a number of core mechanisms upon which auction-based app promoting for each programmatic and closed-loop techniques are constructed.

Scrutiny of those techniques is integral to correctly evaluating transparency in app advert auctions. As Closed-Loop public sale platforms akin to Meta and Google more and more comingle the strategies of shopping for on owned and operated media with third-party web sites by way of AI shopping for merchandise, advertisers will stay unable to determine for themselves whether or not truthful public sale dynamics are at play.

It might be a significant oversight to not embody requirements expressly associated to closed-loop public sale SDKs, given their significance in enabling cellular app promoting. No main enchancment to transparency of advert auctions will be made if the function of SDKs usually are not addressed on this course of.

Technical necessities want strengthening

The OpenRTB Specs have lengthy included vital or helpful parameters beneficial by MRC, akin to SupplyChain Object. However, many of those attributes haven’t been handed by public sale individuals, as MRC acknowledges in analysis undertaken to draft this framework.

MRC doesn’t state that entities should embody these attributes if they’re to be MRC accredited. Subsequently, it’s unclear why a brand new voluntary commonplace by MRC that may merely encourage the usage of sure key attributes not marked as obligatory within the OpenRTB specs would produce a distinct end result.

MRC ought to expressly require the usage of such key parameters, quite than dilute a self-regulatory commonplace that’s voluntary to start with.

Offering patrons and publishers with transparency on the common variety of nodes would not go far sufficient. A full breakdown of every node with every node’s corresponding vendor IDs needs to be included in reporting. This might enable patrons and publishers to know the entities engaged in reselling throughout the end-to-end transaction.

MRC ought to require Auctioneers to show SupplyChain Object client-side, to allow additional unbiased analysis and auditing.

Suggestions for strengthening requirements

Examine My Adverts Institute outlined a number of suggestions to strengthen the MRC’s proposed requirements and bridge gaps in governance and oversight.

First, MRC ought to undertake and publicly publish amendments to MRC By-laws, Code of Conduct, and different related charters to strengthen insurance policies and procedures that mitigate conflicts of curiosity and stop hurt to competitors. Examine My Adverts Institute has sought to know these insurance policies and procedures up to now, however MRC has declined to supply them.

MRC’s robust non-disclosure agreements additional guarantee these paperwork usually are not accessible to the general public. These agreements successfully preclude sure organizations from becoming a member of MRC as members, provided that duties as unbiased business watchdogs require discussing these points publicly and with authorities.

Second, MRC ought to search a Enterprise Assessment Letter or Antitrust Advisory Opinion from DOJ or FTC earlier than finalizing the usual. MRC also needs to submit for assessment the aforementioned updates to its governance construction and codes of conduct to accompany the usual.

Third, MRC ought to be sure that requirements aren’t any much less stringent than analogous transparency necessities sought by DOJ in its instances towards Google. MRC itself should resolve its personal structural conflicts such that it satisfies DOJ’s acknowledged standards for a impartial business physique.

For instance, in choosing an Open-Supply Public sale Administrator, DOJ is looking for a impartial business physique that’s unbiased of and unconnected to Google. The physique should have the intent and functionality—together with vital managerial, operational, technical, and monetary functionality—to manage the Open-Supply Public sale.

Whereas MRC’s public sale requirements are extra broadly relevant, and whereas MRC is the accreditation entity and never the administrator, this serves as a helpful analogy for standards that MRC ought to fulfill if it needs to advance transparency in digital promoting auctions.

Fourth, MRC ought to present details about the audit methodology that can be utilized to distributors looking for accreditation beneath these requirements. For these requirements to be helpful and stop confusion within the market, it should be clear what MRC, by way of its third-party auditor, is and isn’t auditing, and the way knowledge is sourced for OpenRTB Advert Auctioneers and Closed-Loop Auctioneers.

Fifth, MRC ought to embody in these requirements an in depth enforcement process for accredited companies discovered to not be adhering to requirements. This could embody clear definition of what constitutes a violation and repeated violation of the requirements. To this finish, MRC ought to specify which parts of the usual are required for accreditation.

Sixth, MRC ought to formalize a course of whereby non-MRC members are in a position to report suspected non-compliance and obtain updates on decision of such studies. The opacity of MRC’s processes, significantly concerning enforcement, stands in stark distinction to its acknowledged ambitions to advance transparency. Such a reporting mechanism would take away current boundaries, carry it according to different self-regulatory initiatives, and assist to mitigate, to an extent, the conflicts of curiosity in MRC’s mannequin.

Disclosure necessities should handle conflicts

The MRC doesn’t embody any disclosure necessities associated to take-rates or different industrial features of Public sale Transparency. Industrial incentives are on the middle of opacity and ensuing waste within the programmatic ecosystem.

At a minimal, these requirements ought to require Auctioneers to declare and disclose whether or not they derive income from each the buy-side and the sell-side of promoting transactions.

To mitigate opaque conflicts of curiosity that undermine advertiser belief, MRC ought to, in partnership with IAB Tech Lab, develop a typical the place Auctioneers are required to take care of a web page that lists all entities they’ve any possession stake in or profit-sharing association with. This web page can be required beneath the MRC transparency commonplace. Failure to reveal these preparations can be grounds for disciplinary motion.

MRC also needs to discover together with in its requirements extra exact disclosure of take-rate element. For instance, in partnership with IAB Tech Lab, MRC would possibly incorporate a requirement for sell-side Auctioneers to append their income shares to bid responses. Comparable mechanisms needs to be contemplated for buy-side Auctioneers, and Closed-Loop platforms to supply comparable transparency.

Why this issues for advertising and marketing

The MRC’s proposed auction transparency standards arrive as the digital advertising industry faces unprecedented scrutiny from regulators and courts worldwide. Federal judges have ordered Google to reveal materials adjustments to advert auctions to advertise better transparency in search textual content advertisements pricing.

The company was found to have secretly fine-tuned its ad auctions to raise prices incrementally, escaping advertiser discover. These surreptitious pricing practices left advertisers in darkness and facilitated incomes of monopoly earnings.

Publishers and advertisers can now proceed directly to calculating financial harm from Google’s proven monopolizationwith out having to show once more that the corporate broke the legislation. The courtroom already determined that Google illegally managed the market and used unfair techniques to pressure publishers to make use of its techniques.

Programmatic advertising infrastructure has fractured over transparency standards. Demand-side platforms misplaced a vital software for detecting public sale manipulation when Prebid.org disabled cross-exchange performance of transaction IDs. The change eliminates advertisers’ capability to establish after they obtain a number of bid requests for a similar promoting alternative throughout completely different supply-side platforms.

MRC previously updated its Invalid Traffic Detection and Filtration Standards to modernize pointers initially issued in October 2015. The additions and revisions had been supposed to extra absolutely account for the vary of invalid visitors threats and associated points that exist in at the moment’s on-line setting.

After years of advertisers paying for brand safety that only checked keywords, the Media Score Council issued coverage requiring precise content material evaluation. The implementation hole between commonplace publication and enforcement displays challenges of voluntary compliance in a aggressive market.

The public sale transparency requirements might both advance significant transparency or legitimize current opacity. In accordance with Arielle Garcia, Chief Working Officer at Examine My Adverts Institute, the proposal dangers making opacity the usual. By implicitly legitimizing much less transparency from main platforms whereas permitting their commerce affiliation companions to put in writing the principles, this framework deepens the very harms it claims to unravel.

Iesha White, Director of Intelligence at Examine My Adverts Institute, emphasised that when these being accredited are writing the principles, independence is a fiction.

The final word take a look at of those requirements can be whether or not they restore belief by way of obligatory, independently audited, publicly disclosed, and persistently enforced necessities. Or whether or not they merely present cowl for continued opacity beneath the guise of voluntary self-regulation.

Time and time once more, self-regulation has confirmed inadequate to resolve challenges within the complicated and concentrated digital promoting market. Transparency requirements can solely restore belief if they’re obligatory, independently audited, publicly disclosed, and persistently enforced. With out these parts, even calling these unenforced, voluntary recommendations requirements is deceptive. If all the things is non-compulsory, then nothing is a typical.

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Abstract

Who: Examine My Adverts Institute, a digital promoting watchdog group, submitted feedback difficult the Media Score Council’s proposed public sale transparency requirements.

What: The 15-page submission warns that MRC’s proposed Digital Promoting Public sale Transparency Requirements danger codifying unequal transparency necessities that favor closed-loop platforms whereas creating conflicts of curiosity by way of permitting members to craft, vote on, and probably be accredited beneath frameworks they assist create.

When: Examine My Adverts Institute submitted formal feedback on October 20, 2025, through the public remark interval for the MRC requirements.

The place: The requirements would apply globally to advert auctioneers together with each closed-loop platforms akin to Google, Meta, and Amazon, in addition to open programmatic intermediaries together with DSPs and SSPs.

Why: The advertising and marketing neighborhood ought to care as a result of these requirements might both advance significant transparency that restores belief in digital promoting auctions, or legitimize current opacity whereas offering cowl for continued lack of accountability. In accordance with Examine My Adverts, industrial incentives are on the middle of opacity and ensuing waste within the programmatic ecosystem. With out obligatory, independently audited, publicly disclosed, and persistently enforced necessities, the requirements danger exacerbating the very issues they declare to unravel. The focus of energy in digital promoting markets, mixed with ongoing antitrust scrutiny and court-ordered cures requiring public sale transparency, makes the MRC’s strategy to standard-setting significantly consequential for aggressive dynamics and advertiser safety.


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