ACCC Digital Advertising Services Inquiry Interim Report – Questions for stakeholders

Posted by Jonas Jaanimagi On January 28, 2021 accc report, ad tech, digital advertising services

ACCC – Questions for Stakeholders

The questions for stakeholders are distributed throughout today’s released ACCC’s Digital advertising services inquiry interim report and fall into several key areas, as highlighted below.

Written submissions in response to this interim report should be emailed to by Friday 26th February 2021.

We have also prepared a summary of the Proposals For Consultation

Questions for stakeholders (Google, anti-competitive)

The ACCC invites further stakeholder views regarding the impact of Google’s restrictions on market participants’ ability to access data required for ad targeting and ad attribution functions, including:

  • Google blocking advertisers’ ability to access its DoubleClick ID.
  • Google removing the ability for publishers to link bidding data from Google’s SSP (Google Ad Exchange) to the impression-level data from Google’s publisher ad server.
  • Google’s proposals to replace third-party cookies on Chrome.



Questions for stakeholders (AdTech Fees)

  • The ACCC is seeking stakeholder views on the extent to which ad tech providers are able to charge undisclosed fees, as well as the extent to which this impacts on competition and potential benefits from improved transparency.


Questions for stakeholders (General & Google)

  1. How important is access to YouTube ad inventory to advertisers in Australia?
  2. Do advertisers consider that multi-homing is a viable option for DSP services?
  3. Do advertisers consider that they must have access to Google’s DSP service?
  4. Apart from YouTube ad inventory, is access to other exclusive ad inventory sold through the ad tech supply chain essential?
  5. Does selling ad inventory through multiple DSPs create privacy or technical problems for publishers?
  6. How easily are advertisers able to purchase YouTube inventory directly, or through YouTube partners? Is this a viable option for all advertisers? Are there advantages purchasing from YouTube ad inventory via the ad tech supply chain, rather than directly?
  7. How important is access to Google Ads demand to publishers?
  8. Do publishers consider that Google Ads demand is accessible through non-Google SSPs?
  9. For what reasons may a DSP block SSP access to demand available through its service?
  10. How important is access to Display & Video 360 demand to publishers?
  11. Do publishers consider that Display & Video 360 demand is accessible through non-Google DSPs?
  12. Can bids from Google’s SSP, or demand from Google Ads be accessed from non-Google publisher ad servers?
  13. Are there any impediments or disadvantages to using a third-party publisher ad server, due to the way that Google’s SSP interacts with it?
  14. Why might an SSP decide not to participate in header bidding? Do any other SSPs refrain from participating in header bidding auctions (or similar auctions)?


Questions for stakeholders (RTB & AdTech)

The ACCC is seeking submissions from stakeholders on the following questions to help it assess whether advertisers and publishers receive sufficient information to make informed choices about the services and providers they will use. Specifically, we are seeking responses to the following questions:

  1. What information do you need about auctions used by an ad tech provider to assess and compare their services to others in the supply chain?

(a) Why do you need this information and how do/would you use it?

(b) Do you receive this information?

(c) If you do not receive this information, have you sought to obtain this information?


  1. What information do you require, and what do you receive, on the following:

(a) the factors which are used by an auction’s algorithms to select the winning bidder?

(b) the factors used by a bidding algorithm to determine a bid price?

(c) Post-auction information?


  1. Are there differences in the auction information provided by ad tech providers? If so please explain these differences?
  2. Do publishers currently receive sufficient information from SSPs to verify the accuracy of the fees charged?
  3. Does the availability of such information vary between SSPs?
  4. What information about fees charged across the supply chain is available to advertisers and publishers?

(a) Why do you need this information and how do/would you use it?

(b) Do you receive this information?

(c) If you do not receive this information, have you sought to obtain this information?


  1. What additional information about fees or take rates to advertisers and publishers require?
  2. How does a lack of information about fees or take rates impact the ability of advertisers and publishers to make informed choices about how they will use services in the ad tech supply chain?
  3. Are you satisfied with the services provided by verification and attribution providers? If not, what are you not satisfied with regarding their service?
  4. Do you consider that the metrics you received from your verification and attribution provider are accurate?
  5. Would you be able to switch measurement and verification providers if you wanted to? What are the largest obstacles to you switching, if any?
  6. Are advertisers able to independently verify the performance of ads served on YouTube?
  7. Can third party verification and attribution providers access sufficient data through the Google Data Ads Hub to independently verify the performance of ads served on YouTube? If not, what data do verification and attribution providers require access to in order to perform this function?
  8. Does providing third party verification providers with access to raw data, or allowing them to place verification tags (or pixels) on ads, create privacy concerns?
  9. Are advertisers currently able to conduct effective and independent attribution of their ad campaigns?
  10. Will upcoming changes Google is making to the data it shares and Google Chrome affect advertisers’ ability to conduct multi-touch attribution? If so, what will this impact be?
  11. Will access to the data via the Google Ads Data Hub allow advertisers to conduct full and independent attribution of Google’s DSP services?
  12. Does the use of user IDs and cookies in providing attribution services create privacy concerns?
  13. Do stakeholders consider there are any other issues with the ability to conduct attribution of ad tech services?
  14. Do you have to access the data you need to conduct verification of Google’s ad tech services? If not, what data do you require that is not available?
  15. How does the ability to verify the performance of Google’s DSP services compare to other DSPs?
  16. What measures would be most effective to ensure that all DSP services can be fully and independently verified?
  17. What are the risks to user privacy from third parties providing full verification services? Could such measures promoting this be implemented in a way that would protect the privacy of consumers?
  18. Would a common transaction ID assist in making pricing and auctions more transparent?
  19. What risks does a common transaction ID pose to user privacy?
  20. How could a common transaction ID be implemented in a way which mitigates any risks to consumers’ privacy?
  21. How should such a recommendation be implemented?
  22. Would a common user ID be an effective way to improve transparency in the ad tech supply chain?
  23. Could this proposal be implemented practically and is it justified?
  24. Could this proposal be implemented in a way which protects consumers’ privacy? If so, how?
  25. What challenges do publishers face in their inventory being blocked due to brand safety issues?
  26. Do publishers experience any problems in dealing with or negotiating terms with measurement and verification providers?
  27. Are measures, such as standardised taxonomies, or requirements on verification providers to provide publishers with information about changes to their processes, required to address issues with verification providers blocking legitimate publisher websites?
  28. What is the scale of the problem posed by the publication of scam ads on publisher websites?
  29. What are the risks to publishers when scam ads are displayed on their properties?
  30. What measures do ad tech providers take to prevent the delivery of scam ads?
  31. What measures are available to publishers to stop the delivery of scam ads once they are identified?
  32. Are there difficulties experienced by publishers in stopping scam ads being delivered to their properties? If so, what are they?


Questions for stakeholders (Advertisers & Agencies)

The ACCC has mainly heard from large advertisers and does not have sufficient information to determine whether other advertisers who may have less bargaining power hold similar views about their ability to obtain information about the ad tech services they receive from ad agencies.

  • The ACCC invites smaller and medium advertisers to contact the ACCC about any concerns they may have in relation to the performance and fee information they receive from their agencies.

Questions for stakeholders (Agencies & AdTech)

  • The ACCC encourages stakeholders to come forward if they have concerns with ad agencies’ activities in relation to the provision of digital advertising services facilitated by the ad tech supply chain.