Registration of unallocation in the ORD for advertising agencies when marking online advertising

Hello, my name is Dmitry Khatin. For more than 5 years I have been actively working with paid traffic. My goals and objectives are expertise, customization, system analytics and reporting for contextual, media and targeted advertising when promoting websites and applications.
Today I want to bring to your attention a rather important material on the implementation of the law on labeling advertising. Specifically, let’s talk about how an advertising agency builds its quality relationship with the ORD (advertising data operator) when preparing reports on Acts with unallocation under contracts and creatives.

So, let’s consider how, in order to comply with the law on advertising labeling, an advertising agency needs to formalize its relations with the ORD (advertising data operator) in order to avoid claims and fines from Roskomnadzor and the FAS.

Source Rules

• Each member of the advertising chain is responsible for complying with the Advertising Labeling Law

• Each participant in the advertising chain is obliged to register agreements and acts in the RD&A, as well as draw up an unallocation (detailing) under the Initial Agreement between the Advertiser and its first Counterparty.

• By agreement of the Parties, the registration of creatives and the receipt of tokens in the ORD can be assigned to one participant in the advertising chain. In this case, he is obliged to issue an additional unallocation for creatives in the ORD with the allocation of amounts and impressions for each creative.

• According to the law, only the original Advertiser (Status Expense Agreement) can delegate the processing of data to the ORD (advertising data operator) to its nearest Counterparty

Consider the standard classic advertising chain Advertiser-Agency-Blogger*

* A blogger is a legal entity, an individual entrepreneur or an individual who has his own Internet resources for advertising distribution:

– Websites, social media accounts, YouTube channels, telegram channels and other Internet resources that can be used in any way to place advertising materials

We note right away that the step-by-step instructions for an advertising agency that will be given here for the specified chain can be projected and integrated into other (more detailed) advertising chains when placing advertising materials on the Internet.

Yes, with a certain modification and nuances, but with similar actions in essence.

Agreements between participants in the advertising chain

An agreement has been concluded between the Advertiser and the Agency, which, among other things, indicates responsibility for the fact that the Advertising Agency takes all necessary actions to comply with the law on advertising labeling (an example of documents from advertising law experts Here) and bears financial responsibility in case of claims and fines of Roskomnadzor.

A similar agreement was also concluded in the Agency-Blogger link, which spelled out the rights and obligations of the parties regarding the implementation of the labeling law.

For example, this is how the outline of the media plan in the contract looks like Advertiser-Agency.
After the placement of advertising materials, the Advertising Agency will issue an accounting (paper) Act No. 1-100-3 dated April 16, 2023 on the work performed for March 2023

The first steps of the Advertising Agency BEFORE placing advertising materials on the Internet:

1. Open an account in the ORD (hereinafter on the example of the ORD Ozone). The interface for all ORDs is almost the same, since they are all tailored to the uniform requirements of Roskomnadzor regarding advertising labeling.

2. Enter Counterparties under your Income Agreement. Why the Income Contract is important is described in detail Here

3. Draw up agreements between Counterparties (attributes of the agreement in the ORD must be similar to the real (paper) agreement)

Further, when reporting to the ORD on the part of the agency, two options are possible:

First option: Agency-Blogger assigned the design of creatives and receipt of tokens in the ORD to the agency

4. Upload creatives to the ORD and receive tokens that will be used for direct marking of advertising materials on the Internet

After the end of the placement in March 2023, the advertising agency, for its part, is obliged to report in its ORD on Acts and unlocks under the Initial Agreement and creatives by April 30, 2023. Why the Initial Agreement is important is described in detail by me Here

The upper part of the Act is the attributes of the accounting (paper) act that the Advertising Agency will issue for the Advertiser

The data in the ORD must be entered exactly as in the accounting act.

Further in the Acts there is a block about unlocking (detailing) under the Initial Agreement. Amount must be specified 90 000 rubles, since it was she who was spent on labeling advertising from a blogger

Next, the unlocking by creatives is indicated. As indicated above, the blogger posted two advertising materials on his Internet site – the Elephant banner and the Behemoth banner.

Total amount 90 000 rubles is distributed in proportion to the impressions of advertising materials. Statistics on impressions will have to be provided by the Blogger (this must be fixed in the contract)
based on site analytics systems (for example, Yandex Metrika)

As a result, all the necessary actions for the first option were completed by the advertising agency.

Second option: Agency-Blogger secured the design of creatives and receipt of tokens in the ORD for the blogger

In this case, all actions of the Advertising Agency will be similar to the instructions specified in the First Option. Only the agency will no longer submit creatives and receive tokens. And also in the Acts, the agency will unallocate only according to the Initial Agreement – without unallocating by creatives. Unallocation by creatives will be done by the Blogger in his ORD.

Here is a detailed detailed footage this article with presentation

In the video material, instructions are provided in a more detailed form, and it also describes cases of how the agency should act if the Blogger (contractor) does not know how to use the ORD and cannot fully formalize contracts, acts and creatives in the ORD despite the requirements of the law on advertising labeling, and its platform ( Internet resource) is essential for the agency to promote advertising materials on the Internet due to the presence of the target audience.

I hope that this material will be useful for you in terms of building your relationship with the ORD and forming your own advertising chains when promoting advertising materials on the Internet.