Input data and information sources
Advertisers supply advertisements and audience criteria; click behaviour can be deliberately falsified. The system analyses individual usage behaviour and profiles.
Also known as: Behavioural advertising, ad targeting
The system uses a person's behaviour and profile to select which advertisements they see.
Understand the use case
Meta states that it uses such models to serve advertisements. The European Data Protection Board has ruled on the permitted legal basis.
This page describes a typical system design. Actual data flows and permissions depend on your implementation.
System design and data flows
Visited pages, clicks, profile details and advertisers' criteria are combined.
Advertisers supply advertisements and audience criteria; click behaviour can be deliberately falsified. The system analyses individual usage behaviour and profiles.
A model estimates response likelihood for each suitable advertisement; an auction determines their order.
Processing links usage and contextual signals to a target audience or an estimated response to advertisements. Selection or auction logic determines which advertisement is delivered. Model estimates, bids and actual delivery each serve a distinct purpose.
The person sees selected advertisements on the website or app.
The result describes the defined model task. A match, category or forecast acquires its professional significance only in conjunction with the underlying data and intended use.
Selection determines which offers someone sees or misses, and their response feeds back into the profile.
The model supplies information for subsequent use. Selection, adoption or a professional decision in the following workflow is a separate step and should not automatically be attributed to the model.
Explore the system design: Select a component to see its task, incoming and outgoing data, and role in the use case. The guided walkthrough explains each phase. Then use Yes, Uncertain and No to represent your specific system variant.
7 review first10 clarify9 baseline threats
The diagram shows the typical architecture. Select a component to see what happens there and adapt its features to your system. Enable “Analysis guidance” to see which threats need reviewing for this architecture. The page's checklist continues to describe the typical case.
None yet. Each change will appear here.
In this system design: 7 to review first, 10 to clarify, 9 baseline threats.
External access: Depends on your system
To clarify
Input: Part of every AI system
Review first
To clarify
Baseline for every AI system
Third-party content: Present
AI model: Part of every AI system
Review first
Baseline for every AI system
Provider service: Depends on your system
To clarify
Document collection: Present
Review first
To clarify
Training and feedback: Present
Review first
Result: Part of every AI system
Baseline for every AI system
person: Part of every AI system
Baseline for every AI system
Affected person: Depends on your system
Unapproved AI services: Depends on your system
To clarify
Supply chain and technical foundations: 5 baseline threats applying to every AI system
Baseline for every AI system
Selects the service's own products or content rather than paid advertisements
Image, video and voice generation
Generates advertising creative rather than selecting existing advertisements
Advertisers supply advertisements and audience criteria; click behaviour can be deliberately falsified. The system analyses individual usage behaviour and profiles.
The model processes the inputs. Whether it runs internally or with a service provider must be established for the specific implementation.
The system retrieves advertisements from a large collection to match the person's profile. The platform trains its models on its own users' responses.
Serving advertisements through networks passes personal information to other companies.
Using a provider does not automatically determine where processing takes place. Storage location, subcontractors, deletion periods and use for training must be checked for the specific deployment.
Assess risks and determine measures
Record data, participants, interfaces and permissions. Resolve uncertain characteristics in the model.
Relate review candidates to actual data flows: what could happen, and who would be affected?
Assess impacts and likelihood in the deployment context. The number of review candidates is not a risk score.
Select appropriate controls, assign responsibilities and define effectiveness checks. Document residual risks and approvals.
A total of 26 threats from the threat catalogue may be relevant to this use case.
The model assigns someone to an audience such as debt advice or fertility based on browsing. Advertisers indirectly learn information the person never supplied through that audience selection.
The system learns that people in crisis or with gambling addiction click more and serves them more such advertisements. Click rates rise while the most vulnerable suffer harm.
Automated click fraud creates apparent interest in particular advertisements. The model learns false relationships, and advertisers pay for nonexistent reach.
Targeted Poisoning / Label Poisoning
Falsified training labels can deliberately shift model outputs.
Listed because of this characteristic
Training data or an adopted base model can introduce hidden triggers for misbehaviour.
Listed because of this characteristic
Sensitive Information Disclosure
Confidential content can appear in answers, supplied context or logs.
Listed because of this characteristic
RAG-Specific Attacks (Document Poisoning)
Content entering the retrievable knowledge collection can influence answers and subsequent steps.
Listed because of this characteristic
Up to 10 further threats may apply, depending on your system design. Nine threats need to be reviewed for every AI system.
Each Yes adds further threats to your checklist, up to 10 in total. If you cannot yet answer a question, include its threats in your review.
How your system is built
How you operate the system
Advertising platforms hold many advertisers' customer lists and audiences in one system.
If yes, add
Interests and visited pages can reveal health, religion or political views.
If yes, add
If yes, add
These questions arise for almost every AI system.
If yes, add
If yes, add
If yes, add
Serving advertisements through networks passes personal information to other companies.
If yes, add
If yes, add
Outside advertisers book advertisements and define their own audiences on advertising platforms.
If yes, add
If yes, add
Measures for the priority review areas are expanded. Each linked measure explains how to implement it.
Controls for the remaining threats are available on their pages in the threat catalogue.
For every AI system Applies since 2 February 2025.
Depending on use Review trigger since 2 February 2025.
Depending on use Review trigger from 2 December 2027.
Applies if staff or appointed representatives operate or use AI systems.
Applies since 2 February 2025.
Detailed obligations
Applies if advertisement targeting deliberately exploits vulnerabilities due to age, disability or economic distress in a way that risks significant harm.
Applies since 2 February 2025.
Detailed obligations
Applies if the system targets political advertisements to influence an election's outcome or voting behaviour.
Applies from 2 December 2027.
Detailed obligations
Articles 26 and 28 DSA
Platforms must identify advertisements and explain the main selection criteria. They must not show minors profiling-based advertisements.
Articles 21 and 22 GDPR
People may object to profiling for advertising at any time. Solely automated decisions with significant effects are permitted only under limited conditions.
Classify your system with the quick checker All obligations in the obligations compass
Review these threats for every AI system, whatever its purpose.
If any of these features does apply to your system, add the listed threats.
Does the system generate its own text, such as answers, drafts or summaries?
If yes, add
Does the system generate or edit images, sounds, voices or videos?
The system selects existing advertisements and does not generate its own creative material.
If yes, add
Does the system create new content from open-ended requests that people read, see or hear directly? Translation, reading aloud and transcription do not count.
If yes, add
Can users give the system natural language tasks that it then performs?
If yes, add
Does the system formulate answers from retrieved documents?
If yes, add
Does the system remember content from earlier conversations or tasks and reuse it later?
If yes, add
Does the system call other programs, interfaces or search services itself, even if only to read?
If yes, add
Can the system change things itself, such as storing data, sending messages, initiating transactions or granting permissions?
If yes, add
Does the system determine its next steps itself based on earlier results?
If yes, add
Does the system delegate tasks to other AI agents or incorporate their results?
If yes, add
Is the system connected to tools or data sources through the Model Context Protocol (MCP)?
If yes, add
Does the system directly move or control something physical, such as motors, valves, vehicles or temperatures?
If yes, add
Does the system generate code, scripts or database queries for further use?
If yes, add
Does the system execute programs, scripts or commands itself?
If yes, add
The Board issued a binding decision on the legal basis for behavioural advertising on Facebook.
Meta, Expanding GenAI Transparency for Meta’s Ads Products, February 2025 According to the deployer
Meta states that it uses machine learning models to serve advertisements.
Digital Services Act (DSA), Articles 26 and 28 (dejure.org)
Online platform advertising must be identifiable, and minors must not receive profiling-based advertisements.
Updated: 30 September 2026. Review checklist rules version 0.3.2, threat catalogue version 2026.10.24.2. How these pages are structured