California law best practices for advertisers

California Government Code § 84504.6 (2018) creates new obligations for certain committees and online ad platforms related to California elections and ballot measures. The law’s effective date is January 1, 2020.

Google cannot advise you on whether you or your ads are in scope of the law or on your specific obligations under the law. However, we have assembled a guide to Google’s implementation of the California law requirements and some recommendations for account management in light of the requirements.

Express Notification and Verification Requirements

In accordance with California Government Code § 84504.6 and our election ads policies, Google requires advertisers to:

1. verify their identity and eligibility to run election ads via Google’s political advertiser verification process;
2. expressly notify Google when they are running “online platform disclosed advertisements” in the Google Ads Help Center here; and in the DV360 Help Center here.
3. provide information to enable Google to comply with the law’s disclosure obligations.

(1) Verification Process

To run ads in scope of this law you must first verify your identity and eligibility to run election ads in accordance with Google’s election ads policies. Apply for verification here. Please complete verification before completing express notification.

(2) Express Notification Process

Expressly notify Google when you are running “online platform disclosed advertisements”. You may not run these ads until this process is complete.

(3) Provide Google the following information:

1. AdWords Customer ID (use these instructions to find your Customer ID). If you are an agency or someone who manages multiple Google Ads accounts, please do not enter the Customer ID for your Google Ads Manager Account. Please enter the Customer ID for the individual account.
2. Official committee name
3. Committee identification number
4. Disclosure name
5. Committee address
6. Committee treasurer
7. Name of the candidate(s) and elected office(s) and/or ballot measure(s) and jurisdiction(s) to which your ads refer

NOTE: To more easily maintain your ad transparency data, we recommend creating a new account for each candidate race or ballot measure for which you wish to run ads. If you run ads for multiple candidate races and/or ballot measures in one account, you must provide the required details (candidate and elected office or ballot measure and jurisdiction) for each race or ballot measure for which you are or will be running ads.

If you decide to run ads for a new candidate race or ballot measure in the same account, you will need to complete the express notification process again. Each time you complete the express notification process, you must provide a full list of all races and ballot measures for which you have or will run ads in the account.

How Google uses the information you provide:

In-Ad Disclosure

All of your ads will be eligible for a customized “Paid for by” disclosure within the Why This Ad icon (located in the corner of the ad). Users click on this icon to learn more about the ad and advertiser. If you are running “online platform disclosed advertisements”, you may not opt-out of this icon displaying on your ads.

This disclosure will include:

1. Disclosure name (and updates to the name as they occur)
2. Additional biographical information about your committee: (1) Committee Treasurer, (2) Committee Address, (3) Committee ID number
3. A link to your advertiser page in our Political Advertising on Google Transparency Report. There may be a delay from when you begin running ads until your ads appear in the Report

Transparency Report Advertisement Records

Google will include additional disclosure information on each of your ad pages in our Political Advertising on Google Transparency Report.

This disclosure will include:

1. Committee name
2. Committee ID number
3. Name of the candidate(s) and elected office(s) and/or ballot measure(s) and jurisdiction(s) to which your ads refer

Notes and Best Practices

One committee and disclosure name per account: Only one committee name and disclosure name can be associated with each account. If you are managing ads for multiple committees, you must create a separate account for each committee and complete the express notification process for each account.

Create a new account for each race or ballot measure: We recommend creating a new account for each candidate race or ballot proposition for which you wish to run ads even if the ads are run by the same committee. This will ensure that the Transparency Report clearly indicates the candidate race or ballot proposition to which each of your ads refer. You must complete the express notification process for each account.

All ads in account eligible for disclosures: Once you complete the express notification process for an account, all of the active ads in the account are eligible to receive California-specific disclosures. If some of your ads are out-of-scope of the California law, and you do not wish them to be subject to the California requirements, we recommend putting those ads in a separate account.

Ad format restrictions: You may be restricted from using certain formats if Google is unable to apply the law’s disclosure requirements.

When information changes: If any of the information provided in the express notification process changes - such as your disclosure name or the candidate races or ballot measures to which your ads refer - you must complete the entire express notification process again. Updates to your disclosure name will appear in your ads within 5 business days.

Resources:

For more information on how to create a new stand-alone account, visit the Ads Help Center here.

For best practices on how to manage multiple accounts, visit the Ads Help Center here.

For more information on how to add a new account to your manager account, visit the Ads Help Center here (creating a new child account from your manager account) and here (linking a pre-existing child account to your manager account).