DCMS Call for Evidence on Online Advertising - Which? response

Which? welcomes DCMS’s Online Advertising Call for Evidence. Which?'s mission is to tackle consumer detriment by making individuals as powerful as the organisations they have to deal with in their daily lives. When it comes to global online advertising platforms, there is clear asymmetry between platforms and consumers. We therefore welcome the government's work in this important area. Our own work on this is continuing to evolve and we would value ongoing engagement with DCMS as our respective thinking develops. 

In your Call for Evidence, you set out the government's overarching aim to:

• ensure standards about the placement and content of advertising can be effectively applied and enforced online so that consumers have limited exposure to harmful or misleading advertising;
• promote a competitive and fair online advertising market for businesses so that all businesses can compete on merit; and 
• drive transparent and ethical targeting practices for advertising online so that consumers are informed, empowered and can have trust in online advertising.

We note that the call for evidence is focused on the first point above. However, we are also involved in the CMA’s market study into online platforms and digital advertising (second point), so we have included an overview of our current position on that as part of this response for your information. Our full response to the CMA’s online platforms and digital advertising market study interim report is also attached for completeness. 

In relation to the placement and content of advertising, our work and the evidence we have provided particularly relates to fake and fraudulent ads that lead to consumers being misled, scammed or defrauded. We call this ‘fake and fraudulent content that enables scams’. We believe this is a key issue for consumers and an area of harm that is currently falling through regulatory gaps. We have therefore focused our response on this issue, its contribution to the scams landscape, and its link to the work on Online Harms regulation.

We also note that fake and fraudulent content online and on social media platforms has been a recent focus in light of the increasing number of coronavirus-related scams we are seeing. Our work in this area is in early stages and we are now starting to gather evidence of how scammers are seeking to profit from the pandemic.