ISFED Recommendations for Running Political Ads on Social Media Platforms
Within its social media monitoring program, ISFED has monitoring political advertising on Facebook and Instagram for the second year, which includes monitoring compliance of political ads with national legislation and mandatory rules of Facebook. Within the monitoring, the organization has identified many political ads that were run on social media platforms in gross violation of applicable regulations. Some of them were run without labeling, while others were labeled with inaccurate or incomplete information, making it impossible to identify the source.
For example, from September 1 to November 21, 2021, ISFED discovered 405 political ads on Facebook and Instagram not labeled as such. Majority of these ads contained messages in support of and/or against a political subject. Among them, 174 were published by parties and candidates, and 231 were sponsored by discrediting, supporting or fake media pages that operate anonymously and it was impossible to identify their source.
ISFED believes that transparency of political ads is crucial for conducting free and fair elections. The organization has therefore prepared recommendations for the monitoring authority – State Audit Office (SAO), for social media platforms, election subjects and other political advertisers. ISFED hopes that the present document will encourage transparency of political and election ads, disclosure of campaign expenditures and elimination of illegal donations .
The Facebook Ad Library that offers a collection of sponsored posts about political and social issues has been available in Georgia since August 4, 2020. The purpose of the Ad Library is to allow the platform users and other stakeholders to search for advertisers and disseminators of ads with political and social content.
Notably, Facebook has established a high standard of transparency for political and social ads (sponsored posts); the platform believes that users and other stakeholders are entitled to know who is trying to influence them and political and election processes. According to the platform rules, the following ad types require authorization:
- ads made by, on behalf of or about a political actor, party, candidate or campaign, aiming to influence the outcome of an election;
- ads about any election, referendum or ballot initiative, including voter mobilization or information campaigns;
- ads about a social issue;
- ads that are regulated by national laws as political advertising.
According to the Facebook rules, a page that publishes ads with political content is required to label these ads as such. The page is also required to submit to the platform a document of authorization. Information about the person responsible for the ad, submitted by the advertiser, will appear on a Facebook ad for the entire duration of the ad and will be stored in the archive of political ads for seven years after the ad stops running.
Notably, ads published by election subjects on Facebook and Instagram without labeling (declaring) them as political will not be archived in the library after they stop running. This makes it impossible to register such ads, identify their funding sources and the amount spent. As a result, campaign expenses disclosed by an election subject before the State Audit Office cannot be verified.
Political ads in Georgia
The major cause of problems related to transparency of political ads in Georgia is the absence of adequate national regulations for online political advertising. Definition of political advertising is incomplete, as Election Code defines it as a commercial broadcast by mass media and the definition does not include ads published online. 
Requirements related to disclosure of campaign expenditures are also incomplete. The financial disclosure template provided by the SAO is meant for recording expenditures related to online advertising and it is not responsive to peculiarities of ads run on social media platforms. National legislation does not provide a definition on online advertising, prompting election subjects to decide themselves what is online advertising and record such ads at their own discretion. This is a serious challenge for recording and disclosing expenditures for running political ads across different websites and social media platforms.
In addition to the fact that some ads run by political actors are not disclosed before the SAO at all, ads that are disclosed according to Facebook’s requirements but the information provided is too scarce to determine the person or the entity responsible for these ads are also problematic. This method is most often used by anonymous pages with political goals. These pages are not officially affiliated with any of the public figures, organizations or political parties. They nevertheless disseminate ads with political and election content – mostly with the aim of discrediting opponents, critical media, civil activists and NGOs.
Usually, these pages provide names and last names of unidentified individuals to prove ad transparency to Facebook. However, details provided by them are not accompanied with any other information to prove authenticity. This way anonymous pages are formally able to meet the disclosure requirements, while in reality these ads are not transparent. Ads are not disclosed as donations before the State Audit Office either.Therefore, identity of a person or an organization trying to influence will of voters and their spending to that end are unknown. This may seriously undermine election processes.
In view of trends identified during and after the 2020 parliamentary elections, the organization has prepared recommendations for the 2021 local self-government elections regarding transparency of advertising on social media platforms. More specifically:
Political parties and candidates should:
- Label ads run on their official pages as containing political content;
- Identify the party or the candidate in the Facebook ad disclaimer;
- Disclose expenditures in SAO financial disclosure report form based on the invoice for each ad;
- In the information about each political ad, they should specify the ad ID address available in the Ad Library. The ID address is unique for each ad run on Facebook;
- Submit information about ads run on Facebook in a comprehensive and timely manner, including during election and non-election periods;
- Political leaders that are running ads individually, using their personal pages, should disclose expenditures as donations made in favor of the political party concerned.
The State Audit Office should:
- Prepare detailed instructions for filling out a disclosure form for social media ads and design a methodology for verification of information;
- Request disclosure of expenditures for social media ads run beyond election campaign, within annual financial disclosure reports;
- The SAO should request that political parties/election subjects submit in their financial disclosure reports detailed information about ads run on social media platforms, including:
- Individual ID address of the political ad;
- Start and end dates for sponsoring a political ad/post;
- Amount spent on the political ad;
- Proof of the payment.
Other actors that are running ads on social media platforms:
- When running ads in favor of or against political parties, non-profit/non-commercial legal entities should understand that this is a donation, which is prohibited for them under the national legislation;
- Any individual that will finance or run a political ad is required to disclose it as a donation before the SAO. Ads run in the non-election period should also be subject to disclosure requirements;
- When running a political ad, they should provide information that will allow any interested individual – platform users, voters, observer organizations and monitoring authorities to identify the advertiser;
- Refrain from running ads anonymously, and refrain from using anonymous name, fake address and contact information in order to avoid mandatory rules of social media platforms.
Social media platforms should:
- Not allow running of political ads if contact information of the advertiser is not specified or is incomplete;
- Remove political ads without disclaimers in a timely manner, including based on reports of individual users;
- If a user reports an ad, the platform should ask what is the aim of reporting – informing the platform about a political ad running without a disclaimer or avoid seeing the ad in the future. The platform should give this option to users individually;
- All ads run by a page marked as a political advertiser during the election period should be considered as political ads;
- Rules for running ads should be tightened, which should include imposing the requirement for submitting additional information on pages that violate rules for running political ads;
- Running a political ad financed by a foreign advertiser should not be allowed during the election period;
- Access to the Ad Library archives should be improved to ensure that users are able to search for any particular information in a quick and easy manner.
More specifically, users should be able to view information about the number of ads running in a specific period of time and the exact amount spent on these ads, according to a number of different parameters. Currently information in the archive of political ads is accessible through reports and Ad Library API. Users can also use a range of filters to refine their search. However, none of these methods are effective when users are searching for a particular data. For example, reports can be viewed and downloaded only for a specific period of time determined by the platform and users cannot to choose the period themselves. In addition, certain quantitative restrictions are put on receiving information from the Ad Library API and if the amount spent is less than 100 U.S. dollars, the extent of information available does not allow to determine the exact amount spent by a particular page.
Social media monitoring program is implemented with the support of the Institute for Foreign Cultural Relations (IFA) of Federal Foreign Office of the Federative Republic of Germany. The sole responsibility for the content of this article lies with the International Society for Fair Elections and Democracy (ISFED) and the views expressed herein do not necessarily reflect the donor’s position.
 Donations represent a part of the party property. The following is considered to be a donation: funds transferred to the party’s bank account; tangible or intangible assets and services received by a party from a natural or legal person free of charge, at a discounted price or on concessionary terms; funds contributed to support a party; tangible or intangible assets or services provided free of charge, at a discounted price or on concessionary terms (except for voluntary), whether or not the beneficiary of these funds is identifiable. The Law of Georgia on Political Associations of Citizens, Chapter III, Article 25.
 Facebook’s advertising policies; Chapter 9: https://www.facebook.com/policies/ads/restricted_content/political
 political/pre-election advertising – commercial broadcast by mass media (‘media’) aimed at promoting/hindering the election of an electoral subject, where the electoral subject and/or its sequence number are displayed and which contains the signs of election campaign or appeals for or against the issue put forward for referendum/plebiscite. Election Code of Georgia, Article 2(z6).
 The State Audit Office is the state institution that controls spending of political finances. It monitors electoral subjects’ spending on advertising (including online), as well as ads by third parties in favor of or against any electoral subject, which should be disclosed as a donation
 For example, at least 3 coordinated fake media pages are operating for political purposes, and they are sponsoring messages in favor of the authorities in a selective manner. Their activities display elements of coordinated inauthentic behavior. For all three pages -„არჩევნები 2021 / Elections 2021“, „საინფორმაციო ბლოგი - Informative Blog“, and „პოზიტიური სიახლეები / Positive News“, „Manana Kaxidze” was specified as an advertiser, whose contact details (address, phone number) were fake. It was impossible to identify the person as the Ad Library didn’t contain a link to her personal account and according to the SAO data, she has not made a donation in favor of any of the parties.