Meta will impose new restrictions on customer list custom audiences in 2025. Does this apply to you? What should you do?
Let’s get to it…
Whom Does This Apply To?
These restrictions apply to advertisers using customer list custom audiences to promote the following categories:
- Housing
- Employment
- Financial Products and Services (including Credit)
In other words, all of the Special Ad Categories other than Politics, Elections, and Social Issues. Restrictions apply to advertisers based in the US or reaching audiences in the US.
Sharing of Customer List Custom Audiences
The new restrictions apply to the sharing of customer list custom audiences for these classes of business. There are two situations considered:
1. Sharing between ad accounts within the same Business Portfolio.
You will be able to share customer list customer audiences with other ad accounts within the same Business Portfolio (the new-er name for Business Manager) as long as all people with permissions to manage ad campaigns have the same business email domain.
And no, using Gmail, Yahoo, and other generic email domains won’t get around this restriction.
It’s not clear if this is the complete list, but the assumption is that you will use email domains that prove you work for the same employer.
2. Sharing between ad accounts across different Business Portfolios.
You will not be able to share customer list custom audiences in this case, regardless of the email domain. Both ad accounts need to be within the same Business Portfolio.
Meta provides the following examples for ad accounts within the same Business Portfolio…
The first column of email addresses represents all people within an ad account that will share the customer list custom audiences who have permissions to manage ad campaigns. The final column represents those who would receive that audience.
The first example is acceptable because all people within both ad accounts have the same email domain. The second is not because one person within the sharing account who has access to manage the ad campaigns uses a Gmail domain.
Consumer Reporting Agencies
Consumer reporting agencies (CRAs) are not allowed to use any customer list custom audiences, including their own, for targeting. CRAs collect and sell financial and credit information about people.
Yeah, that would be bad in this case. Meta doesn’t want advertisers to discriminate and these lists could be used to do exactly that.
Additional Certification
Beginning in January of 2025, advertisers will begin to see a new certification requirement for customer list custom audiences.
The main points:
1. They are not a consumer reporting agency, nor did they receive the information from one.
2. The audience isn’t based on sensitive information that shouldn’t be used for targeting.
3. They will follow Meta’s advertising policies.
Enforcement Timeline
If you use customer list custom audiences in these categories, here’s the timeline of how enforcement will rollout…
January 2025
New campaigns must use customer list custom audiences that fall within the guidelines mentioned above or you may not be able to publish them. If you published campaigns prior to these new restrictions, they will continue to run, but you may not be able to edit them.
March 2025
Campaigns that were published prior to restrictions that do not follow these guidelines may be paused.
Why is This Happening?
Meta has faced a lot of heat over the years for advertising that falls within sensitive topics. This is why Special Ad Categories exist in the first place.
The Special Ad Category designation is meant to protect the advertiser (and Meta) by preventing them from using discriminatory targeting. Audience selection looks like this:
- Postal or zip code selections are unavailable
- Minimum of a 15-mile radius around a location
- 18-65+ with no ability to limit by age minimum or maximum
- No ability to limit by gender
- Some sensitive detailed targeting options are removed
Since these restrictions exist, it’s no surprise that advertisers may attempt to get around them by using custom audiences. They could assemble a list of people who are all within a certain age group or neighborhood. This would violate terms for these Special Ad Categories.
I’m actually surprised Meta doesn’t simply remove the ability to use customer list custom audiences in this case. It would be much easier. But since they haven’t, they’ll need to add more restrictions to make sure that advertisers know the rules and follow them.
The sharing of custom audiences also falls into a bit of a gray area anyway. I’ve long interpreted the rules to mean that you can only target people who have explicitly given you the right to contact them. To a point, these restrictions wouldn’t be necessary if they are interpreted that way by everyone.
What Should You Do?
First, investigate whether this applies to you. Do you run ads for a business that fall in the categories of housing, employment, or financial products and services? Are you or the client in the US?
If so, check your alerts for warnings related to these restrictions. I assume you’d see them on the Audiences page, but you may also see something on Account Overview.
Next, do you share customer list custom audiences for these businesses? If not, this isn’t really an issue.
Finally, consider whether all advertisers on an ad account utilize the same email domain. It’s quite possible they don’t since it’s surely common that advertisers would use “generic” email domains like Gmail. You’ll need to get that corrected, which would likely be a bit of a hassle.
Your Turn
Do you run ads for businesses that fall under these categories in the US? How have you prepared?
Let me know in the comments below!
