29 Sep 2026 Search

previously: fix liability and ad libraries: anti-fraud policy ideas from Canada

Check My Ads has a model bill called the SAFE Platforms Act, intended to address the Big Tech scam ads problem.

A good start—especially the part about unambiguously identifying an advertiser—but because of how the ad targeting ML works, there is one big loophole.

Platforms shall provide users with access to basic information about advertisers whose content they view

Emphasis added.

The problem here is that ad personalization ML “learns” to target ads not to the people who might report a scam, such as the holders of a trademark that the ad infringes, but to people who might fall for the scam.

A transparency requirement that only affects ads that the ML already decided to show you is inadequate. In general, transparency must apply to all ads on the platform, not just the ads pre-selected as those a particular individual is likely to click.

This bill needs an ad library section.

Update 3 Oct 2026: The SCAM Act has similar problems. Also missing some key transparency provisions which means Big Tech already has the workaround. The following ad library provisions would be needed in both bills.

(See page 27 of the Canadian Anti-Monopoly Project “World of Scams” PDF.) Right now, the platform ad libraries, such as Google Ads Transparency Center and Meta Ad Library, are designed with some fraud-friendly features that make it easier for deceptive sellers to hide. Some technically straightforward but high-impact fixes include:

  • Ad libraries should not block crawling by independent image search sites and trademark monitoring companies.

  • An ad should not serve to regular people until after it had been available in the platform ad library for a time period to be set by regulations.

  • All substantial ad variations should be available.

  • Index all text in the ad (using OCR if needed), not just “search by advertiser or website name.”

  • Show, and allow searching by, intermediary companies involved in placing an ad, not just the advertiser.

  • For each ad creative, link to all accounts running the same or substantially similar ads.

  • Cross-link accounts that are using the same domains in landing pages.

  • Ads shouldn’t disappear from the ad library when they’re not actively serving. (This makes it way too easy for fakes to hide from the real brand by running when employees of the real brand and their service providers are asleep.)

Legit advertisers have several incentives to check platform ad libraries. The biggest is to protect their customers from fakes, especially fakes that are bad enough not to work, but good enough to make customers think they’re real and try to get support from a real manufacturer or retailer.

Legit advertisers can also keep their own ad costs down by getting the scams kicked off. Scammers act as shill bidders to drive up platform ad revenue, so platforms are disincentivized to remove them without outside attention.

Other public interest organizations also have an interest in protecting people from deceptively sold goods. Platform ad libraries must be designed to facilitate that help, not make it harder.

The Canadian Anti-Monopoly Project recommends an archival requirement for platform ads, which is a good start. But IMHO it’s important to consider the information needs of would-be scam fighters and the scam protection features of platform ad libraries when legislating in this area.