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
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:
brands, products or services performed through or by
(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).
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
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
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
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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