25  X/Twitter

X’s UGC data transparency is assessed through the X API across Brazil, the EU, and the UK, while advertising transparency relies on the X Ads Repository, available only in the EU under DSA obligations. Our request to access the X API under the DSA was submitted in October 2025 and, after multiple follow-up attempts, was definitively rejected in December without further justification, preventing effective use and assessment under these conditions. In the UGC dimension, X is placed in the Limited band across all regions. The API provides access to public post data and performs well on secondary criteria, including data format compliance, endpoint coverage, consistent data returns, and near-real-time availability. However, access is not free of charge, and no graphical interface for UGC data extraction is available. On advertising transparency, no repository is provided in Brazil or the UK. In the EU, although the X Ads Repository was introduced under DSA obligations, API access was not granted during the evaluation period, and the graphical interface consistently returned empty CSV files, rendering the repository non-functional in practice and placing it in the Negligible band. Overall, X presents moderate UGC transparency constrained by cost barriers, alongside advertising transparency that is effectively unavailable outside the EU and non-functional within it.

25.1 Transparency Assessment

User-Generated Content

BR

65

Limited

EU

65

Limited

UK

66

Limited

Advertising

BR

0

Not Available

EU

2

Negligible

UK

0

Not Available

25.2 User-Generated Content

Coverage: BR, EU, UK

25.2.1 Special Criteria

25.2.1.1 UGC_SC1: Does the platform provide an API that enables the structured extraction of public user-generated content data for independent analysis?

Region	Answer	Note
BR	✅ Yes	X/Twitter provides a longstanding API that has been extensively documented and widely used for academic research. It remains accessible to anyone with a registered developer account, although, as will be discussed further, such access is now mostly paid.
EU	✅ Yes	X/Twitter provides a longstanding API that has been extensively documented and widely used for academic research. It remains accessible to anyone with a registered developer account, although, as will be discussed further, such access is now mostly paid.
UK	✅ Yes	X/Twitter provides a longstanding API that has been extensively documented and widely used for academic research. It remains accessible to anyone with a registered developer account, although, as will be discussed further, such access is now mostly paid.

25.2.1.2 UGC_SC2: Can the full scope of public content data be extracted through the platform’s API?

Region	Answer	Note
BR	✅ Yes	Historically, X/Twitter has ensured that any public conversation published on the platform generates publicly available data that can be accessed and explored by developers through its API.
EU	✅ Yes	Historically, X/Twitter has ensured that any public conversation published on the platform generates publicly available data that can be accessed and explored by developers through its API.
UK	✅ Yes	Historically, X/Twitter has ensured that any public conversation published on the platform generates publicly available data that can be accessed and explored by developers through its API.

25.2.1.3 UGC_SC3: Is access to the platform’s API free of charge?

Region	Answer	Note
BR	❌ No	In February 2023, X/Twitter announced that it would begin charging for the use of its API, which had previously been mostly free of charge. At the time of our assessment, access to the API was divided into four levels - (i) Free, which allows retrieval of data from up to 100 posts per month; (ii) Basic, which, at a cost of USD 200 per month, allows retrieval of up to 15,000 posts; (iii) Pro, which, at a cost of USD 5,000 per month, allows retrieval of up to 1,000,000 posts; and (iv) Enterprise, for which pricing and usage limits are negotiated directly with the platform. As the free plan offered extremely limited capabilities and was presented by the platform itself as a testing tier, we did not consider it sufficient to characterize access to the platform's API as free of charge. In 2026, after our assessment, the company introduced a pay-per-use tier, which did not fundamentally change this structure and, for some use cases, might have been even more onerous.
EU	❌ No	In February 2023, X/Twitter announced that it would begin charging for the use of its API, which had previously been mostly free of charge. At the time of our assessment, access to the API was divided into four levels - (i) Free, which allows retrieval of data from up to 100 posts per month; (ii) Basic, which, at a cost of USD 200 per month, allows retrieval of up to 15,000 posts; (iii) Pro, which, at a cost of USD 5,000 per month, allows retrieval of up to 1,000,000 posts; and (iv) Enterprise, for which pricing and usage limits are negotiated directly with the platform. As the free plan offered extremely limited capabilities and was presented by the platform itself as a testing tier, we did not consider it sufficient to characterize access to the platform's API as free of charge. In 2026, after our assessment, the company introduced a pay-per-use tier, which did not fundamentally change this structure and, for some use cases, might have been even more onerous.
UK	❌ No	In February 2023, X/Twitter announced that it would begin charging for the use of its API, which had previously been mostly free of charge. At the time of our assessment, access to the API was divided into four levels - (i) Free, which allows retrieval of data from up to 100 posts per month; (ii) Basic, which, at a cost of USD 200 per month, allows retrieval of up to 15,000 posts; (iii) Pro, which, at a cost of USD 5,000 per month, allows retrieval of up to 1,000,000 posts; and (iv) Enterprise, for which pricing and usage limits are negotiated directly with the platform. As the free plan offered extremely limited capabilities and was presented by the platform itself as a testing tier, we did not consider it sufficient to characterize access to the platform's API as free of charge. In 2026, after our assessment, the company introduced a pay-per-use tier, which did not fundamentally change this structure and, for some use cases, might have been even more onerous.

25.2.1.4 UGC_SC4: Does the platform offer a graphical interface for extracting data?

Region	Answer	Note
BR	❌ No	The platform does not provide a graphical interface for accessing or extracting public user-generated content data.
EU	❌ No	The platform does not provide a graphical interface for accessing or extracting public user-generated content data.
UK	❌ No	The platform does not provide a graphical interface for accessing or extracting public user-generated content data.

25.2.2 Accessibility

25.2.2.1 UGC_OC1: Can the requested data be extracted directly from the platform’s API response?

Region	Answer	Note
BR	✅ Yes	Responses to requests to the platform API provide the expected data in an appropriate format, without requiring redirection.
EU	✅ Yes	Responses to requests to the platform API provide the expected data in an appropriate format, without requiring redirection.
UK	✅ Yes	Responses to requests to the platform API provide the expected data in an appropriate format, without requiring redirection.

25.2.2.2 UGC_OC2: Does the platform’s API support renewable authentication mechanisms without risk of data loss?

Region	Answer	Note
BR	✅ Yes	If we consider only the limits of each tier, then tokens can be renewed without fear of data loss during extraction or monitoring. However, if we take into account the restrictions of the Basic Access tier—such as the 100-tweet monthly cap, the rate limit of 1 request every 15 minutes on the main tweet retrieval endpoint, and limited access to certain endpoints (e.g., GET /2/tweets/search/all is not available for Basic Access tier users)—, then the answer is no. Even if tokens are renewed, these tier-based restrictions tied to the app/user prevent continuous and comprehensive data collection.
EU	✅ Yes	If we consider only the limits of each tier, then tokens can be renewed without fear of data loss during extraction or monitoring. However, if we take into account the restrictions of the Basic Access tier—such as the 100-tweet monthly cap, the rate limit of 1 request every 15 minutes on the main tweet retrieval endpoint, and limited access to certain endpoints (e.g., GET /2/tweets/search/all is not available for Basic Access tier users)—, then the answer is no. Even if tokens are renewed, these tier-based restrictions tied to the app/user prevent continuous and comprehensive data collection.
UK	✅ Yes	If we consider only the limits of each tier, then tokens can be renewed without fear of data loss during extraction or monitoring. However, if we take into account the restrictions of the Basic Access tier—such as the 100-tweet monthly cap, the rate limit of 1 request every 15 minutes on the main tweet retrieval endpoint, and limited access to certain endpoints (e.g., GET /2/tweets/search/all is not available for Basic Access tier users)—, then the answer is no. Even if tokens are renewed, these tier-based restrictions tied to the app/user prevent continuous and comprehensive data collection.

25.2.2.3 UGC_OC3: Does the platform’s API offer an endpoint for extracting data from an individual publication?

Region	Answer	Note
BR	✅ Yes	The GET /2/tweets/:id endpoint enables the retrieval of comprehensive information about a single tweet, as identified by the provided ID.
EU	✅ Yes	The GET /2/tweets/:id endpoint enables the retrieval of comprehensive information about a single tweet, as identified by the provided ID.
UK	✅ Yes	The GET /2/tweets/:id endpoint enables the retrieval of comprehensive information about a single tweet, as identified by the provided ID.

25.2.2.4 UGC_OC4: Does the platform’s API offer an endpoint for extracting data from an individual author?

Region	Answer	Note
BR	✅ Yes	The GET /2/users/:id/tweets endpoint enables the retrieval of comprehensive information about tweets made by a specific user, as identified by the provided ID.
EU	✅ Yes	The GET /2/users/:id/tweets endpoint enables the retrieval of comprehensive information about tweets made by a specific user, as identified by the provided ID.
UK	✅ Yes	The GET /2/users/:id/tweets endpoint enables the retrieval of comprehensive information about tweets made by a specific user, as identified by the provided ID.

25.2.2.5 UGC_OC5: Does the platform’s API provide an endpoint for extracting data based on search terms?

Region	Answer	Note
BR	✅ Yes	The GET /2/tweets/search/recent endpoint enables the retrieval of comprehensive information about tweets published in the past seven days that match specific search terms, while the GET /2/tweets/search/all endpoint, available only to Pro and Enterprise API users, allows querying historical tweets dating back to the launch of the platform.
EU	✅ Yes	The GET /2/tweets/search/recent endpoint enables the retrieval of comprehensive information about tweets published in the past seven days that match specific search terms, while the GET /2/tweets/search/all endpoint, available only to Pro and Enterprise API users, allows querying historical tweets dating back to the launch of the platform.
UK	✅ Yes	The GET /2/tweets/search/recent endpoint enables the retrieval of comprehensive information about tweets published in the past seven days that match specific search terms, while the GET /2/tweets/search/all endpoint, available only to Pro and Enterprise API users, allows querying historical tweets dating back to the launch of the platform.

25.2.2.6 UGC_OC6: Does the API use locale-neutral data representations?

Region	Answer	Note
BR	✅ Yes	Based on a review of the X/Twitter API v2 documentation, the API employs largely locale-neutral representations for non-content metadata. Its structure and use of standardized formats ensure significant neutrality—for example, all timestamps (such as created_at) adhere to the ISO 8601 format and are returned in Coordinated Universal Time (UTC). Similarly, the lang field uses ISO 639-1 language codes, and country or regional codes follow standard ISO 3166-1 Alpha-2 conventions.
EU	✅ Yes	Based on a review of the X/Twitter API v2 documentation, the API employs largely locale-neutral representations for non-content metadata. Its structure and use of standardized formats ensure significant neutrality—for example, all timestamps (such as created_at) adhere to the ISO 8601 format and are returned in Coordinated Universal Time (UTC). Similarly, the lang field uses ISO 639-1 language codes, and country or regional codes follow standard ISO 3166-1 Alpha-2 conventions.
UK	✅ Yes	Based on a review of the X/Twitter API v2 documentation, the API employs largely locale-neutral representations for non-content metadata. Its structure and use of standardized formats ensure significant neutrality—for example, all timestamps (such as created_at) adhere to the ISO 8601 format and are returned in Coordinated Universal Time (UTC). Similarly, the lang field uses ISO 639-1 language codes, and country or regional codes follow standard ISO 3166-1 Alpha-2 conventions.

25.2.3 Compliance

25.2.3.1 UGC_OC7: Does the platform implement a proper deprecation strategy to avoid breaking client applications while rolling out major changes in the API?

Region	Answer	Note
BR	✅ Yes	The X/Twitter API documentation includes a dedicated section on migrating from API v1.1 to v2, outlining the key differences and new features. Although no deprecation timeline is provided, it states that v1.1 endpoints will remain functional but will no longer receive new features or updates.
EU	✅ Yes	The X/Twitter API documentation includes a dedicated section on migrating from API v1.1 to v2, outlining the key differences and new features. Although no deprecation timeline is provided, it states that v1.1 endpoints will remain functional but will no longer receive new features or updates.
UK	✅ Yes	The X/Twitter API documentation includes a dedicated section on migrating from API v1.1 to v2, outlining the key differences and new features. Although no deprecation timeline is provided, it states that v1.1 endpoints will remain functional but will no longer receive new features or updates.

25.2.3.2 UGC_OC8: Is the platform’s API documentation published in open access?

Region	Answer	Note
BR	✅ Yes	Any user can access the X/Twitter API documentation](https://developer.x.com/en/docs/x-api).
EU	✅ Yes	Any user can access the X/Twitter API documentation](https://developer.x.com/en/docs/x-api).
UK	✅ Yes	Any user can access the X/Twitter API documentation](https://developer.x.com/en/docs/x-api).

25.2.3.3 UGC_OC9: Is the platform’s API documentation clearly written and exemplified?

Region	Answer	Note
BR	✅ Yes	The X/Twitter API documentation is comprehensive and includes all the necessary information, such as account-level limitations, permissions, detailed endpoint descriptions, and both current and upcoming features. It also provides a well-structured migration guide from the previous version to the current one.
EU	✅ Yes	The X/Twitter API documentation is comprehensive and includes all the necessary information, such as account-level limitations, permissions, detailed endpoint descriptions, and both current and upcoming features. It also provides a well-structured migration guide from the previous version to the current one.
UK	✅ Yes	The X/Twitter API documentation is comprehensive and includes all the necessary information, such as account-level limitations, permissions, detailed endpoint descriptions, and both current and upcoming features. It also provides a well-structured migration guide from the previous version to the current one.

25.2.3.4 UGC_OC10: Does the platform’s documentation include or link to the API or data access terms of use?

Region	Answer	Note
BR	✅ Yes	The X/Twitter API documentation includes an extensive set of developer terms, collectively referred to as the “Developer Agreement and Policy”.
EU	✅ Yes	The X/Twitter API documentation includes an extensive set of developer terms, collectively referred to as the “Developer Agreement and Policy”.
UK	✅ Yes	The X/Twitter API documentation includes an extensive set of developer terms, collectively referred to as the “Developer Agreement and Policy”.

25.2.3.5 UGC_OC11: Does the platform’s API documentation detail the response format of each endpoint?

Region	Answer	Note
BR	✅ Yes	For each endpoint, the X/Twitter API documentation clearly describes the response format, specifying the structure of the returned JSON, the possible fields, their data types, and when they may or may not appear.
EU	✅ Yes	For each endpoint, the X/Twitter API documentation clearly describes the response format, specifying the structure of the returned JSON, the possible fields, their data types, and when they may or may not appear.
UK	✅ Yes	For each endpoint, the X/Twitter API documentation clearly describes the response format, specifying the structure of the returned JSON, the possible fields, their data types, and when they may or may not appear.

25.2.3.6 UGC_OC12: Does the platform provide its API documentation in the official languages of the assessed region?

Region	Answer	Note
BR	❌ No	The X/Twitter API documentation is available only in English.
EU	❌ No	The X/Twitter API documentation is available only in English.
UK	✅ Yes	The X/Twitter API documentation is available in English.

25.2.3.7 UGC_OC13: Does the platform’s API documentation detail the quota or rate limits applicable to each available endpoint?

Region	Answer	Note
BR	✅ Yes	The X/Twitter API documentation clearly outlines the rate limits and quotas for each access tier, specifying how many requests can be made, within what time frame, and which resources or endpoints are affected.
EU	✅ Yes	The X/Twitter API documentation clearly outlines the rate limits and quotas for each access tier, specifying how many requests can be made, within what time frame, and which resources or endpoints are affected.
UK	✅ Yes	The X/Twitter API documentation clearly outlines the rate limits and quotas for each access tier, specifying how many requests can be made, within what time frame, and which resources or endpoints are affected.

25.2.3.8 UGC_OC14: Does the platform provide a way to label content that has been generated with artificial intelligence?

Region	Answer	Note
BR	❌ No	X/Twitter does not allow content generated with the assistance of artificial intelligence to be labeled. Consequently, this type of information cannot be retrieved via the API.
EU	❌ No	X/Twitter does not allow content generated with the assistance of artificial intelligence to be labeled. Consequently, this type of information cannot be retrieved via the API.
UK	❌ No	X/Twitter does not allow content generated with the assistance of artificial intelligence to be labeled. Consequently, this type of information cannot be retrieved via the API.

25.2.4 Completeness

25.2.4.1 UGC_OC15: Can data from a publication’s comments be extracted using the platform’s API?

Region	Answer	Note
BR	➖ Not applicable	Although it could be argued that replies and quotes serve this function, X/Twitter does not have dedicated comment features like other social media platforms analyzed in this study.
EU	➖ Not applicable	Although it could be argued that replies and quotes serve this function, X/Twitter does not have dedicated comment features like other social media platforms analyzed in this study.
UK	➖ Not applicable	Although it could be argued that replies and quotes serve this function, X/Twitter does not have dedicated comment features like other social media platforms analyzed in this study.

25.2.4.2 UGC_OC16: Can data from temporary content be extracted through the platform’s API?

Region	Answer	Note
BR	✅ Yes	The X/Twitter API allows the retrieval of Spaces, live audio conversations that remain available for a limited period of time, through specific endpoints, either by known identifiers or by keywords.
EU	✅ Yes	The X/Twitter API allows the retrieval of Spaces, live audio conversations that remain available for a limited period of time, through specific endpoints, either by known identifiers or by keywords.
UK	✅ Yes	The X/Twitter API allows the retrieval of Spaces, live audio conversations that remain available for a limited period of time, through specific endpoints, either by known identifiers or by keywords.

25.2.4.3 UGC_OC17: Can historical data be extracted through the platform’s API?

Region	Answer	Note
BR	❌ No	Although the GET /2/tweets/search/all endpoint allows querying historical tweets dating back to the launch of the platform, it is only available to Pro and Enterprise API users.
EU	❌ No	Although the GET /2/tweets/search/all endpoint allows querying historical tweets dating back to the launch of the platform, it is only available to Pro and Enterprise API users.
UK	❌ No	Although the GET /2/tweets/search/all endpoint allows querying historical tweets dating back to the launch of the platform, it is only available to Pro and Enterprise API users.

25.2.4.4 UGC_OC18: Is the number of requests allowed by the API sufficient for monitoring more than 10,000 publications in 24 hours?

Region	Answer	Note
BR	❌ No	Although it is technically possible to monitor more than 10,000 posts in 24 hours using the X/Twitter API, the cost makes this impractical. The Basic Access tier, priced at USD 200 per month, allows retrieval of only 15,000 posts per month, which severely restricts large-scale monitoring, unless users opt for the Pro Access tier, which costs USD 5,000 per month.
EU	❌ No	Although it is technically possible to monitor more than 10,000 posts in 24 hours using the X/Twitter API, the cost makes this impractical. The Basic Access tier, priced at USD 200 per month, allows retrieval of only 15,000 posts per month, which severely restricts large-scale monitoring, unless users opt for the Pro Access tier, which costs USD 5,000 per month.
UK	❌ No	Although it is technically possible to monitor more than 10,000 posts in 24 hours using the X/Twitter API, the cost makes this impractical. The Basic Access tier, priced at USD 200 per month, allows retrieval of only 15,000 posts per month, which severely restricts large-scale monitoring, unless users opt for the Pro Access tier, which costs USD 5,000 per month.

25.2.5 Consistency

25.2.5.1 UGC_OC19: Are the results returned by the API consistently reproducible?

Region	Answer	Note
BR	✅ Yes	Excluding the seven-day limitation of the GET /2/tweets/search/recent endpoint, data acquisitions using the X/Twitter API are consistently reproducible over time.
EU	✅ Yes	Excluding the seven-day limitation of the GET /2/tweets/search/recent endpoint, data acquisitions using the X/Twitter API are consistently reproducible over time.
UK	✅ Yes	Excluding the seven-day limitation of the GET /2/tweets/search/recent endpoint, data acquisitions using the X/Twitter API are consistently reproducible over time.

25.2.5.2 UGC_OC20: Is the data returned by the platform’s API consistent with the parameters and filters used in the request?

Region	Answer	Note
BR	✅ Yes	The X/Twitter API returns data which matches the parameters and filters applied.
EU	✅ Yes	The X/Twitter API returns data which matches the parameters and filters applied.
UK	✅ Yes	The X/Twitter API returns data which matches the parameters and filters applied.

25.2.6 Relevance

25.2.6.1 UGC_OC21: Does the data extracted by the platform’s API reflect what is displayed on its user interface?

Region	Answer	Note
BR	✅ Yes	The data extracted through the platform’s API reflects what is displayed on the user interface at the moment it is collected, meaning that key elements such as authorship, full content, interaction metrics, and referenced content are consistent with what users see on the interface.
EU	✅ Yes	The data extracted through the platform’s API reflects what is displayed on the user interface at the moment it is collected, meaning that key elements such as authorship, full content, interaction metrics, and referenced content are consistent with what users see on the interface.
UK	✅ Yes	The data extracted through the platform’s API reflects what is displayed on the user interface at the moment it is collected, meaning that key elements such as authorship, full content, interaction metrics, and referenced content are consistent with what users see on the interface.

25.2.6.2 UGC_OC22: Does the platform’s API allow for filtering data based on content or its author location?

Region	Answer	Note
BR	❌ No	The X/Twitter API v2 documentation indicates that it is possible to filter data by publisher location using the profile_region field. However, this filter is not available to users or developers on the Basic Access tier. Therefore, we were unable to test or validate this functionality.
EU	❌ No	The X/Twitter API v2 documentation indicates that it is possible to filter data by publisher location using the profile_region field. However, this filter is not available to users or developers on the Basic Access tier. Therefore, we were unable to test or validate this functionality.
UK	❌ No	The X/Twitter API v2 documentation indicates that it is possible to filter data by publisher location using the profile_region field. However, this filter is not available to users or developers on the Basic Access tier. Therefore, we were unable to test or validate this functionality.

25.2.6.3 UGC_OC23: Does the platform’s API allow for filtering data based on content language?

Region	Answer	Note
BR	✅ Yes	The GET /2/tweets/search/recent and GET /2/tweets/search/all endpoints enable filtering of tweets according to content language through the use of the lang parameter.
EU	✅ Yes	The GET /2/tweets/search/recent and GET /2/tweets/search/all endpoints enable filtering of tweets according to content language through the use of the lang parameter.
UK	✅ Yes	The GET /2/tweets/search/recent and GET /2/tweets/search/all endpoints enable filtering of tweets according to content language through the use of the lang parameter.

25.2.6.4 UGC_OC24: Does the platform’s API allow for filtering data by specific time periods?

Region	Answer	Note
BR	✅ Yes	The GET /2/tweets/search/recent, though limited to the last seven days, and GET /2/tweets/search/all endpoints allow filtering of tweets based on specific timeframes.
EU	✅ Yes	The GET /2/tweets/search/recent, though limited to the last seven days, and GET /2/tweets/search/all endpoints allow filtering of tweets based on specific timeframes.
UK	✅ Yes	The GET /2/tweets/search/recent, though limited to the last seven days, and GET /2/tweets/search/all endpoints allow filtering of tweets based on specific timeframes.

25.2.7 Timeliness

25.2.7.1 UGC_OC25: Can data from newly published content be extracted from the platform’s API in near real time?

Region	Answer	Note
BR	✅ Yes	In our tests, we found that the delay between content appearing on the user interface and being accessible through the API was minimal, typically less than one hour.
EU	✅ Yes	In our tests, we found that the delay between content appearing on the user interface and being accessible through the API was minimal, typically less than one hour.
UK	✅ Yes	In our tests, we found that the delay between content appearing on the user interface and being accessible through the API was minimal, typically less than one hour.

25.3 Advertising

Coverage: BR, EU, UK

25.3.1 Special Criteria

25.3.1.1 AD_SC1: Does the platform provide an API to access its ad repository and extract data on advertising content for independent analysis?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	According to X/Twitter, access to data on ads delivered in the European Union under Article 40 of the Digital Services Act (DSA) is available through the X API for researchers. However, at the time of the assessment, access had not been granted. Our application remained pending without any response from the platform within a reasonable timeframe, and no reasons for non-approval were provided.
UK	❌ No	-

25.3.1.2 AD_SC2: Does the platform provide a graphical user interface to its ad repository for extracting advertising content data?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	The X Ads Repository was launched in 2023 to comply with the requirements of the European Union’s Digital Services Act (DSA). For advertisements served in the EU, the repository is intended to provide key information on funding, targeting, and reach through downloadable comma-separated values (CSV) files. This constitutes the only available access point for ad data, as X does not display this information directly in the graphical user interface. Despite multiple attempts, we were unable to extract any substantive data, even though the documentation indicates that such extraction should be technically possible. We tested several prominent advertisers—including Amazon, Apple, and Netflix—across multiple EU countries (France, Germany, and Belgium) and across a range of time filters (custom dates, today, yesterday, past 7 days, current quarter, previous quarter, and past year). In all cases, the downloads produced CSV files containing only headers and no records. These findings are consistent with recent conclusions by the European Commission, which fined X for non-compliance with the DSA, including excessive delays in processing data requests from its Ad Repository, thereby undermining its intended transparency function.
UK	❌ No	-

25.3.1.3 AD_SC3: Can data from both active and inactive ads be extracted?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	This could not be verified due to the lack of API access at the time of the assessment, as well as repeated failures to extract any data from the graphical interface despite multiple attempts.
UK	❌ No	-

25.3.2 Accessibility

25.3.2.1 AD_OC1: Does the platform provide a GUI for accessing and visualizing its ad repository?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	In principle, this item could be met through the CSV files generated in the graphical interface. However, the feature was not functioning correctly at the time of the assessment (December 2025), as all searches returned empty files containing only headers. It could also theoretically be met via the API, but this could not be verified because access had not been granted.
UK	❌ No	-

25.3.2.2 AD_OC2: Is access to the platform’s ad repository free of charge?

Region	Answer	Note
BR	❌ No	-
EU	✅ Free API and GUI access	The X Ads Repository GUI is free and limited to ads delivered in the EU, while the API access is free and subject to approval from X under article 40 of the DSA.
UK	❌ No	-

25.3.2.3 AD_OC3: Can the requested data be extracted directly from the ad repository response?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	In principle, this item could be met through the CSV files generated in the graphical interface. However, the feature was not functioning correctly at the time of the assessment (December 2025), as all searches returned empty files containing only headers. It could also theoretically be met via the API, but this could not be verified because access had not been granted.
UK	❌ No	-

25.3.2.4 AD_OC4: Does the platform’s ad repository API provide a form of authentication that allows for renewal without the risk of data loss?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	This could not be verified due to the lack of API access at the time of the assessment and the inability to extract any data from the graphical interface despite multiple attempts.
UK	❌ No	-

25.3.2.5 AD_OC5: Can data from an individual ad be retrieved from the platform?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	The X Ads Repository GUI does not allow searches for specific ads using a unique identifier. This functionality also does not appear to be supported by the Ad Repository API. In addition, this could not be independently verified due to the lack of API access at the time of the assessment and the repeated inability to extract any data from the GUI.
UK	❌ No	-

25.3.2.6 AD_OC6: Can data from ads served by a specific advertiser be retrieved from the platform?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	In principle, this item could be met through the CSV files generated in the graphical interface. However, the feature was not functioning correctly at the time of the assessment (December 2025), as all searches returned empty files containing only headers. It could also theoretically be met via the API, but this could not be verified because access had not been granted.
UK	❌ No	-

25.3.2.7 AD_OC7: Can ad data be retrieved from the platform using search terms?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	The X Ads Repository GUI does not allow searches for specific ads using search terms. This functionality also does not appear to be supported by the Ad Repository API. In addition, this could not be independently verified due to the lack of API access at the time of the assessment and the repeated inability to extract any data from the GUI.
UK	❌ No	-

25.3.2.8 AD_OC8: Does the platform use locale-neutral data representations?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	Official documentation does not explicitly confirm that the X Ads Repository uses locale-neutral data representation. In addition, this could not be independently verified due to the lack of API access at the time of the assessment and the repeated inability to extract any data from the GUI.
UK	❌ No	-

25.3.3 Completeness

25.3.3.1 AD_OC9: Does the platform provide data that allows the identification of advertisers who ran ads?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	According to the official documentation, the X Ads Repository “includes the following: advertiser, funding entity, the advertiser’s main targeting parameters, impressions, and reach,” with the aim of providing transparency around advertisements on the platform. In principle, this item could be met through the CSV files generated in the graphical interface. However, the feature was not functioning correctly at the time of the assessment (December 2025), as all searches returned empty files containing only headers. It could also theoretically be met via the API, but this could not be verified because access had not been granted.
UK	❌ No	-

25.3.3.2 AD_OC10: Does the platform provide data on the funders who paid for ads?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	According to the official documentation, the X Ads Repository “includes the following: advertiser, funding entity, the advertiser’s main targeting parameters, impressions, and reach”, with the aim of providing transparency around advertisements on the platform. In principle, this item could be met through the CSV files generated in the graphical interface. However, the feature was not functioning correctly at the time of the assessment (December 2025), as all searches returned empty files containing only headers. It could also theoretically be met via the API, but this could not be verified because access had not been granted.
UK	❌ No	-

25.3.3.3 AD_OC11: Does the platform provide data on the period during which ads were served?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	In principle, this item could be met through the CSV files generated in the graphical interface. However, the feature was not functioning correctly at the time of the assessment (December 2025), as all searches returned empty files containing only headers. It could also theoretically be met via the API, but this could not be verified because access had not been granted.
UK	❌ No	-

25.3.3.4 AD_OC12: Does the platform provide data on user engagement with ads?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	In principle, this item could be met through the CSV files generated in the graphical interface. However, the feature was not functioning correctly at the time of the assessment (December 2025), as all searches returned empty files containing only headers. It could also theoretically be met via the API, but this could not be verified because access had not been granted.
UK	❌ No	-

25.3.3.5 AD_OC13: Does the platform indicate whether ads were placed by verified or unverified advertisers?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	Neither the X Ads Repository GUI nor the API documentation indicates whether advertisers were verified at the time their ads were served. This could not be independently verified due to the lack of API access at the time of the assessment and the repeated inability to extract any data from the graphical interface. More broadly, X departs from common online verification-labelling practices by treating verification as a paid feature, which limits its reliability as an indicator of authenticity on the platform.
UK	❌ No	-

25.3.4 Compliance

25.3.4.1 AD_OC14: Does the platform flag ads that were removed due to violations of its guidelines or relevant legislation?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	In principle, this information should be available through the X Ads Repository GUI, as the headers “Facts and Circumstances of Removal”, “Enforcement Action”, and “Statement of Reasons” are present. However, no underlying data could be retrieved. The same information should theoretically be accessible via the API, but this could not be confirmed due to the lack of access at the time of the assessment.
UK	❌ No	-

25.3.4.2 AD_OC15: Does the platform indicate whether ad content was generated using artificial intelligence?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	Neither the X Ads Repository GUI nor the API documentation indicates whether advertisement content was generated using artificial intelligence. This could not be independently verified due to the lack of API access at the time of the assessment and the repeated inability to extract any data from the graphical interface.
UK	❌ No	-

25.3.4.3 AD_OC16: Is the platform’s ad repository documentation published in open access?

Region	Answer	Note
BR	❌ No	-
EU	✅ Yes, both API and GUI documentation	The X Ads Repository GUI and the API documentation are publicly available, although the level of detail provided is limited.
UK	❌ No	-

25.3.4.4 AD_OC17: Is the platform’s ad repository documentation clearly written and exemplified?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	The X Ads Repository GUI and the API documentation are very limited and provide neither examples nor clear explanations of the available data fields.
UK	❌ No	-

25.3.4.5 AD_OC18: Does the platform’s ad repository documentation include or link to its terms of use?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	The X Ad Repository documentation does not include or link to its terms of service.
UK	❌ No	-

25.3.4.6 AD_OC19: Does the platform provide its ad repository documentation in the official languages of the assessed region?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	The X Ad Repository documentation is only available in English.
UK	❌ No	-

25.3.4.7 AD_OC20: Does the platform implement a proper deprecation strategy to avoid breaking client applications while rolling out major changes in the API?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	The X Ads Repository API documentation does not describe any deprecation strategies nor any changelogs or migration instructions.
UK	❌ No	-

25.3.4.8 AD_OC21: Does the platform’s ad repository API documentation detail the response format of each endpoint?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	The X Ads Repository API documentation does not detail any response formats.
UK	❌ No	-

25.3.4.9 AD_OC22: Does the platform’s ad repository API documentation detail the quota or rate limits applicable to each available endpoint?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	The X Ads Repository API documentation does not detail any applicable rate or daily limits.
UK	❌ No	-

25.3.5 Consistency

25.3.5.1 AD_OC23: Does the data retrieved by the API reflect what is displayed on the platform’s ad repository GUI?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	This could not be verified due to the lack of API access at the time of the assessment and the inability to extract any data from the graphical interface despite multiple attempts.
UK	❌ No	-

25.3.5.2 AD_OC24: Are the results returned by the platform consistently reproducible?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	This could not be verified due to the lack of API access at the time of the assessment and the inability to extract any data from the graphical interface despite multiple attempts.
UK	❌ No	-

25.3.5.3 AD_OC25: Is the data returned by the platform consistent with the parameters and filters used in the request?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	This could not be verified due to the lack of API access at the time of the assessment and the inability to extract any data from the graphical interface despite multiple attempts.
UK	❌ No	-

25.3.6 Relevance

25.3.6.1 AD_OC26: Does the platform allow the use of temporal filters to retrieve data on ads?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	In principle, the X Ads Repository GUI allows the use of temporal filters. However, no data could be retrieved at the time of the assessment. The same functionality should theoretically be available via the API, but this could not be confirmed due to the lack of access.
UK	❌ No	-

25.3.6.2 AD_OC27: Does the platform allow filtering advertising data by ad category?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	This could not be verified due to the lack of API access at the time of the assessment and the inability to extract any data from the graphical interface despite multiple attempts.
UK	❌ No	-

25.3.6.3 AD_OC28: Does the platform allow filtering advertising data by geographic location?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	The X Ad Repository does not support filtering by subnational geographic locations, as geographic filtering is limited to the country level. This could not be independently verified via the API due to the lack of access at the time of the assessment and the repeated inability to extract any data from the graphical interface.
UK	❌ No	-

25.3.7 Accuracy

25.3.7.1 AD_OC29: Does the platform provide age and gender data on the audiences of ads?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	This could not be verified due to the lack of API access at the time of the assessment and the inability to extract any data from the graphical interface despite multiple attempts.
UK	❌ No	-

25.3.7.2 AD_OC30: Does the platform provide subnational geographic data on the audience reached by ads?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	This could not be verified due to the lack of API access at the time of the assessment and the inability to extract any data from the graphical interface despite multiple attempts.
UK	❌ No	-

25.3.7.3 AD_OC31: Does the platform include data on audience targeting criteria defined by advertisers?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	This could not be verified due to the lack of API access at the time of the assessment and the inability to extract any data from the graphical interface despite multiple attempts.
UK	❌ No	-

25.3.7.4 AD_OC32: Does the platform provide granular volume ranges for ad impressions?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	This could not be verified due to the lack of API access at the time of the assessment and the inability to extract any data from the graphical interface despite multiple attempts.
UK	❌ No	-

25.3.7.5 AD_OC33: Does the platform provide granular investment ranges for ad spending?

Region	Answer	Note
BR	❌ No	-
EU	❌ No	Funding amounts are not reported in either the X Ads Repository GUI or API. This could not be independently verified via the API due to the lack of access at the time of the assessment and the repeated inability to extract any data from the graphical interface.
UK	❌ No	-