1. Well aware of the booming increase of investment assigned to online advertising, the Italian Self-Regulation Organization recently felt that time had come for analyzing and addressing issues specifically linked to (or originating from) commercial communication performed in an online environment and on a broad range of new devices.
2. To the purpose, the local SRO released the Digital Chart, a document meant both, to individuate the most common forms of commercial communication in use on the Internet as well as to assess how the problem of transparency and recognition of promotional messages is being dealt with in the digital context. The background idea behind the initiative is to be found in the intent to offer – in a successive step - the Advertising Industry a set of guidelines/best practices to rely on, when allocating their commercial communication in this specific playfield.
3. The Digital Chart shares the results of this analysis with respect to a number of areas and advertising techniques currently in use for online advertising.
In detail, the Chart focuses on aspects/issues relating to marketing practices such as:
3.1 Endorsement of brands, products or services performed through or by 'celebrities', 'influencers' (such as bloggers or vloggers) and 'user communities', practices subject to strict compliance with all the requirements set by the Advertising Code with respect to the use of 'testimonials' as well as for 'transparency' (i.e. immediate and easy recognition of all forms of commercial communication).
3.2 Native Advertising, resulting in 'in-feed units', 'paid search units' or 'recommendation widgets'. Again, the promotional intent has to be clear and immediately perceivable, through specific alerts, e.g. "Advertisement", "Promoted by", "Sponsored by", "Sponsored Content", "Suggested Post", "Sponsored Post", and "Presented by". For paid search units, graphic distinctions (color, shading, etc.) may result suitable to the purpose.
3.3 Marketing performed Social Networks or Content Sharing sites is equally subject to all provisions set in the Advertising Code and, specifically, to 'transparency' / 'disclosure' requirements. For fulfilling such requirement, alerts such as "recommended post" or "sponsored" are frequently used.
3.4 A significant amount of promotional messages is diffused through In-App Advertising appearing on users' devices (just to mention some of the most common ones, via banner ads, interstitial/full screen ads, advanced overlay ads, notification ads and capture form ads). According to the local SRO all these technical means, when used for promotional purposes, have to comply with the provisions of the Advertising Code. For disclosure all means are deemed to be apt as long as they are capable of clearly revealing the promotional intent of a message.
3.5 The same goes for Advergames (where commercial communication is inserted into an electronic, interactive game). Advertisers usually deem alerts such as "Promoted" or "Sponsored by" as adequate for offering sufficient disclosure.
4. The Digital Chart also lists a number of international resources where proper guidance for digital advertising is available. The respective indications mention the ANA's "Advertising is going Native (2015)", ASA guidelines and surveys, EASA's "Digital Marketing Communication Best Practice Recommendation (2015)", the FTC's guidelines, IAB's "Native advertising Playbook (2013)", the ICC's "Advertising and Marketing Communication Practice – Consolidated ICC Code (2011)" and IAB UK's "Content & Native Disclosure Guidance Phase 1 e Phase 2 (2015)".
5. Despite all these indications, recommendations and guidelines, it seems pretty clear that the Advertising Industry would truly need some easy to understand - and to apply - internationally agreed standards in order to be able to diffuse commercial communication successfully on the Internet and without resulting in being exposed to the risk of intervention by national Regulatory Authorities with outcomes differing from country to country.
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