UK Trends and Developments Contributed by: Huw Morris, Dominic Bray, Nick Swimer and Rebecca Coleman, Lee & Thompson LLP
• Due process and oversight: an independent Integ - rity Council of legal and ethical experts will handle escalated cases, with entrants having the right to respond and appeal. • Transparency and governance: Cannes Lions will publish an annual Integrity Audit documenting an overview of concerns. Hyper-personalisation expected to drive programmatic advertising In recent years, audience segmentation – where data is leveraged to divide a target audience into small - er groups based on shared characteristics such as browsing behaviour, purchase history and even exter - nal factors like weather patterns – has enabled the advertising industry to achieve new levels of precision. Hyper-personalisation, however, is now widely viewed as the next stage in the evolution of programmatic ad targeting. Techniques such as Dynamic Creative Optimisation (which allows ad creatives to adapt in real time to meet a user’s specific needs) and the use of advanced contextual intelligence to understand the intent behind the content consumption have shown remarkable capabilities for hyper-targeted ad place - ments. Hyper-personalisation techniques are expected to become even more sophisticated over 2026, with pro - grammatic systems increasingly able to identify the critical moments when a purchase decision is most likely and integrate relevant advertising at precisely the right time. In the absence of any further cookie consent exemptions under the DUAA and PECR, it is key that advertisers ensure that the use of any new technology remains compliant with the GDPR, and that appropriate consents for any cookies used for hyper-personalisation have been obtained. UK creative decisions tighten for EU political advertising campaigns The European Union’s Regulation (EU) 2024/900 on the transparency and targeting of political advertising, which entered into force in April 2024, will apply in full from October 2025. This framework introduces key obligations for political advertisers and service pro - viders, requiring clear identification of sponsors and public disclosure of funding, and imposing strict limits
on algorithmic targeting, including a prohibition on the use of sensitive personal data. Publishers of political advertisements will take on additional responsibilities, such as explicit labelling and contributing to European online repositories. Plat - forms including Meta have already announced they will stop accepting political, electoral and social issue ads on their EU platforms from early October 2025, citing the impracticality of the new requirements. Breaches of the regulation can result in penalties of Online platforms have changed their systems and interfaces to meet the requirements of the UK Online Safety Act (OSA) and EU Digital Services Act (DSA). In 2026, deadlines for implementation of the new rules will continue to pass, so there is likely to be tougher scrutiny, stricter controls and greater downstream contractual requirements and demands on advertis - ers, as online platforms continue to evolve and change to meet the requirements of the Acts, and as regula - tors in the UK and across the EU use their enforce - ment powers to clamp down on non-compliance. The UK’s regulator, Ofcom, recently published an update on its implementation plans and set out some key milestones for 2026, including the launch of the super-complaint regime and the publication of statu - tory reports on important issues, such as highly effec - tive age assurance, content harmful to children and app stores. Regime against fraudulent advertising under OSA will begin to take effect Phase 3 of the Online Safety Act 2023 (OSA) is expect - ed to roll out in 2026, with the enforcement of duties to prevent fraudulent paid-for advertising likely from early 2027. Phases 1 and 2 – addressing illegal harms and child protection – concluded in 2025. Secondary legisla - tion passed earlier in 2025 defined the thresholds for Category 1, 2A and 2B services (based primarily on user numbers and the use of a content “recommender up to 6% of annual income or turnover. Digital services and markets ramp up normalisation across ad stacks
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