Problem
The current spec stops at "publisher reads render_guidance and renders accordingly." But Art 50(5) is about what the user actually saw at first exposure, not what the supply chain intended to show them. Without a post-serve receipt:
- A publisher can demonstrate pre-serve intent but not actual served disclosure.
- An advertiser/agency who is the deployer under Art 50 has no machine-readable evidence to wave at counsel proving the disclosure happened.
- A governance agent auditing delivery can audit the manifest but not the rendered impression.
The regulator's question is post-serve. Currently nothing on the wire answers it.
Proposed wire shape
A new served_disclosure object written back into the impression/event record by the publisher's ad server, carried in delivery reports / validate_content_delivery responses / wherever post-serve event evidence already flows:
rendered: false is a valid value, paired with a not_rendered_reason enum (format_unsupported, creative_self_renders, disclosure_not_required_by_publisher_analysis, error). A missing served_disclosure on an impression where disclosure.required: true was declared upstream is itself an audit signal.
Composition rules
- One
served_disclosure per (impression × jurisdiction) — multi-jurisdictional impressions can carry multiple, keyed by jurisdiction.
most-restrictive-wins precedence from render_guidance already covers what should have been rendered; served_disclosure records what was. Discrepancy detection (declared persistence: continuous, rendered_duration_ms < impression duration) is the audit primitive.- For self-rendering creatives (MRAID, VPAID),
rendering_surface: creative_sandbox plus evidence.type: governance_agent_observation — i.e., the publisher couldn't observe directly and a governance agent's post-hoc get_creative_features rendering is the evidence.
Where it lives in protocol surfaces
- Delivery reports (
get_media_buy_delivery, get_creative_delivery) — primary surface for advertiser/agency to retrieve.
validate_content_delivery response — when buyer agents proactively audit a delivery window.- Webhook event payloads — optionally, when the publisher pushes impression-level events.
This is additive across all three surfaces; existing consumers ignore the field.
Out of scope
- Sampling vs full population. Whether every impression carries
served_disclosure or a representative sample is a publisher-side policy decision (cost vs evidentiary completeness). Spec should permit both, recommend full population for creative cohorts known to carry disclosure.required: true.
- Cryptographic binding to the impression. Sufficient that
served_disclosure is co-located with the impression record the publisher already attests to; signing comes for free if the delivery report is itself signed (separate issue).
- PII.
served_disclosure is about the label, not the user; nothing in this object touches user identity.
Refs
Priority
Pre-GA candidate. Pairs with #TBD (signed provenance claims) as the two highest-leverage legal-gap closures called out in GA-readiness review.
Problem
The current spec stops at "publisher reads
render_guidanceand renders accordingly." But Art 50(5) is about what the user actually saw at first exposure, not what the supply chain intended to show them. Without a post-serve receipt:The regulator's question is post-serve. Currently nothing on the wire answers it.
Proposed wire shape
A new
served_disclosureobject written back into the impression/event record by the publisher's ad server, carried in delivery reports /validate_content_deliveryresponses / wherever post-serve event evidence already flows:{ "impression_id": "imp_4f9a2c...", "served_at": "2026-05-12T14:30:01Z", "served_disclosure": { "rendered": true, "regulation": "eu_ai_act_article_50", "jurisdiction": { "country": "DE" }, "label_text": "KI-generiert", "label_language": "de", "position": "overlay", "persistence": "continuous", "rendered_duration_ms": 15000, "viewport_coverage_pct": 4.2, "first_exposure_ms": 0, "rendering_surface": "publisher_ad_server", "evidence": { "type": "screenshot_hash", "value": "sha256:..." } } }rendered: falseis a valid value, paired with anot_rendered_reasonenum (format_unsupported,creative_self_renders,disclosure_not_required_by_publisher_analysis,error). A missingserved_disclosureon an impression wheredisclosure.required: truewas declared upstream is itself an audit signal.Composition rules
served_disclosureper (impression × jurisdiction) — multi-jurisdictional impressions can carry multiple, keyed by jurisdiction.most-restrictive-winsprecedence fromrender_guidancealready covers what should have been rendered;served_disclosurerecords what was. Discrepancy detection (declared persistence: continuous, rendered_duration_ms < impression duration) is the audit primitive.rendering_surface: creative_sandboxplusevidence.type: governance_agent_observation— i.e., the publisher couldn't observe directly and a governance agent's post-hocget_creative_featuresrendering is the evidence.Where it lives in protocol surfaces
get_media_buy_delivery,get_creative_delivery) — primary surface for advertiser/agency to retrieve.validate_content_deliveryresponse — when buyer agents proactively audit a delivery window.This is additive across all three surfaces; existing consumers ignore the field.
Out of scope
served_disclosureor a representative sample is a publisher-side policy decision (cost vs evidentiary completeness). Spec should permit both, recommend full population for creative cohorts known to carrydisclosure.required: true.served_disclosureis co-located with the impression record the publisher already attests to; signing comes for free if the delivery report is itself signed (separate issue).served_disclosureis about the label, not the user; nothing in this object touches user identity.Refs
Priority
Pre-GA candidate. Pairs with #TBD (signed provenance claims) as the two highest-leverage legal-gap closures called out in GA-readiness review.