Using documents obtained from the European Commission, I have sought to understand how the European Union is spending taxpayers’ money on online political ad spending and ask whether campaign spending to date has been sufficiently transparent, if it could have fallen foul of Britain’s election laws and whether it may constitute foreign election interference. What constitutes election interference? There are many forms in which foreign electoral interference may take. Information manipulation, or disinformation, is a common method whereby a foreign actor may fabricate or distort news content in a way that could present inaccurate or misleading information to people who will vote in an election. Cyber disruption is another method which may take the form of hacking and leaking, or even identity falsification. For the purpose of my research, however, we must consider the established precedent of Western governments recognising foreign interference in the form of political advertising and elite co-optation. Elite co-optation is a form of soft interference that doesn’t necessarily manipulate data or publish outright lies. Instead, this form of foreign election interference uses positive relationships between public and private-sector elites. It uses strong relationships with big businesses or institutions to sway influence. In at least three recent incidents, social media advertising has been called into question in Western elections. In 2017, during the German federal elections, Facebook CEO Mark Zuckerberg promised he would ensure the integrity of the online campaign. He didn’t. Ads of a completely unknown origin appeared weeks before the end of the campaign, focusing on some of the progressive social policies proposed by the Green Party. The ads came from an organisation that called itself Greenwatch, which allegedly provided false contact information on its public page. The ads were not taken down and their origins were never investigated by Facebook. At the end of the campaign, the page disappeared and the only trace of the organisation left behind were the nine ads they paid for (see here). EU political ads targeted to the UK Facebook’s own Ad Library shows a wealth of advertisements made by Brussels over the years, allowing users to filter ads between general content, and electoral content. Some 1,700 results appear on the Facebook Ad Library from the European Commission, specifically related to issues, electoral matters or politics. Facebook advertisements posted by the European Parliament that were specifically targeted at the United Kingdom totalled 55, with total spending between October 2018 and 2019 amounting to £99,387. A researcher discovered that documents obtained from the European Commission show multiple ad campaigns commissioned by a page named “European Youth”. Many of those campaigns specifically targeted Irish Facebook users during the run-up to the March 29th 2019 Brexit deadline. In those documents, our researcher says that many of those advertisements were not appropriately flagged as political content, despite Facebook’s new rules requiring it. According to Facebook’s Page Transparency system, the “European Youth” page was targeting users in the United Kingdom in the run-up to the latest Brexit deadline. According to Facebook’s Ad Library, the European Youth Facebook page has been targeting social media advertisements towards UK users which are run without labels indicating they relate to “issue, electoral or political”. Facebook Pages and Campaigns from the European Union European Youth is a Facebook page that was launched in September 2010. As of October 2019, it has over 240,000 “likes”. The page is used as a hub for European campaigns that might appeal to young people, from social issues to internships and vocational training. It regularly reposts content from another EU page, Social Europe, which represents the EU Commission’s Directorate-General for Employment, Social Affairs and Inclusion. The Erasmus+ Facebook page represents the EU’s programme for education, training, youth and sport. It is a seven-year project, launched in 2014, that will provide €14.7 billion in resources to fund education and training for over 4 million young people. As of October 2019, it has over 569,000 “likes”. Creative Europe is the EU’s programme for cultural and creative sectors. It will spend €1.46 billion between 2014 and 2020. This page has been one of the driving forces of the European Parliament’s social media campaigns, as slide decks obtained by our researcher shows. Between 2016 and 2019, slide decks show Creative Europe being used to promote films and other media material produced with European Union funding. Is the EU hiding campaign funding? The European Commission does not have a formal Freedom of Information procedure, though does provide “access to documents” upon request. On 18th July 2019, a researcher obtained four slide decks detailing campaigns run by Creative Europe. The name of the third-party digital marketing agency used for the campaign was redacted in every slide, citing “protection of commercial interests”. No further information was provided. Could EU social media campaigns break UK election law? The Representation of the People Act 1983 outlines what constitutes bribery in Section 113. It offers three important clarifications on the definition of bribery: (i) references to giving money include references to giving, lending, agreeing to give or lend, offering, promising, or promising to procure or endeavour to procure any money or valuable consideration; and (ii) references to procuring any office include references to giving, procuring, agreeing to give or procure, offering, promising, or promising to procure or to endeavour to procure any office, place or employment [and (iii) references to procuring the return of any person at an election include, in the case of an election of the London members of the London Assembly at an ordinary election, references to procuring the return of candidates on a list of candidates submitted by a registered political party for the purposes of that election] Under Electoral Commission guidelines, non-party campaigners (including those who run social media campaigns) can only spend up to £20,000 in England and £10,000 in Scotland, Wales, or Northern Ireland before being required to register as a non-party campaigner. The information outlined above raises a multitude of other questions for the European Commission and Parliament: Why is social media campaign spending so difficult to obtain? Why doesn’t the British government respond consistently? Is the European Union “one political space”?