Airbnb has targeted council employees with online adverts. Does that count as lobbying?

When Green Party Councillor Feljin Jose – who represents an area of north inner-city Dublin – saw an advert on his LinkedIn feed for Airbnb’s Rural Tourism Fund, earlier this month he kinda wondered why, he says.

At the end of April, he had also been served on the same platform with another post promoted by Airbnb, and written by one of its lobbyists, the former Labour TD Derek Nolan.

Jose clicked into the posts’ analytics. 

Those showed that the posts had been targeted at him as someone who works in “government administration” and at “Dublin City Council”.

Does that count as lobbying? said Jose, earlier this week. “It’s targeting decision-makers and everyone around them.”

Could it also be political advertising? But LinkedIn doesn’t allow political advertising, he said. “And there’s no transparency around it and how much is spent.”

Microtargeting of political and social-issues adverts online, and the transparency around that, has been a live issue in European countries for almost a decade now, since the Brexit referendum in the UK.

In March 2024, the European Union passed regulations that lay out new definitions of political advertising, and will – once it all comes into force – also bring added responsibilities for platforms to bring more transparency around such adverts. 

But it remains to be seen how it will play out in practice, says Niamh Kirk, an associate professor at the University of Limerick who has written about the possibilities of lobbying and digital adverts.

“I think there is this thing of constant grey areas and reactivity,” she says.

Nolan didn’t respond directly to queries. But a spokesperson for Airbnb said that it, like many organisations which it pointed to, uses Linkedin “as a public platform to openly share corporate news with those who could be interested”.

That includes the launch of its Rural Tourism Fund, which is of huge interest given it is grant funding being made available to private businesses and community organisations, they said.

Is it lobbying?

One of Nolan’s posts – promoted by Airbnb – was a reshare of an article in the Irish Times about an ESRI research paper. 

The newspaper article was headlined “Airbnb not to blame for State’s rental crisis, report finds”. 

In his comment above the link, Nolan congratulated ESRI “for bringing much-needed fact and objectivity to the discussion on housing and short-term rentals in Ireland”. 

In their paper, the subject of the news report, ESRI’s researchers had said that they didn’t find a link between the rise of short-term lets and the fall in registered tenancies. 

But “this does not mean short-term let activity has not had a detrimental impact on the private rental sector in specific local markets”, said the key findings.

“It does, however, suggest short-term let activity is not the primary cause of falling new rental commencements or the lack of available rental accommodation nationwide,” they said.

Jose, the Green Party councillor, said that it seemed possible to him that the adverts could be considered lobbying. “Bombarding people in local government [...] with a very soft image of Airbnb.”

A spokesperson for Airbnb said that its lobbying in Ireland is a matter of public record on the lobbying register, in compliance with Irish law.

A spokesperson for the Standards in Public Office Commission (SIPO) didn’t specifically assess or address whether the adverts were lobbying.

Instead, they pointed to the “three-step test” to determine if something is lobbying. 

If for example, a company is an employer with more than 10 employees and communications are made on its behalf, or a third-party paid to communicate for such a company, or anyone is communicating about development or land zoning. 

And, the communication is about a “relevant matter” such as “the initiation, development, or modification of any public policy or of any public programme”. 

And, if they are communicating directly, or indirectly, with a “designated public official” – which generally includes politicians and higher-up bureaucrats.

Kirk, the academic, said that at the moment, lobbying regulations don’t explicitly refer to digital advertising, but targeting by job could have a bearing on lobbying legislation. 

“Just because it’s digital, and not over coffee, doesn’t mean it’s not,” she said.

One challenge is that, without clear guidelines on what is direct or indirect communication, those running the adverts would have to judge for themselves, she says. 

“Because lobbying is self-declaration, people are supposed to know themselves that micro-targeting could be lobbying,” she says.

Is it political advertising?

Meanwhile, what is defined as political advertising – and so subject to certain transparency requirements – has also been changing in the law, says Kirk.

In October 2018, platforms signed up to a voluntary code of conduct, which committed them to greater transparency around political and issue-based adverts, which was updated four years later. 

But, as Kirk’s research has shown, there has been a “lack of clarity in definitions of what constitutes an ‘issue’ and the process of categorising content as issue-based or not”. The same is true of political content, the research says.

Then, in March last year, the European Union brought in new regulations to cover transparency and the targeting of political advertising.

In that, the definitions of political advertising include the promotion of a message that is liable and designed to influence, among other things, the outcome of a legislative or regulatory process, the regulations say. 

But it’s unclear if the Airbnb posts would be caught by that. 

Jennifer Waters, a PhD researcher at the UCD Centre for Digital Policy who works in this area, said that she thinks that they wouldn’t fall under political adverts as they aren’t coming from a political actor. 

“I don’t think this one qualifies,” she said. 

For adverts that are found to qualify, the new EU regulations include new transparency requirements for platforms that host them – although many of its provisions aren’t activated yet. 

From October 2025, platforms will have to ensure that each political advert has a transparency label, and notice, that identifies an advert as political, and includes key information such as their sponsor, how much was spent on the advert, and any targeting techniques used. 

Also, platforms will have to make sure that each political advert is available in a European repository for online advertisements. 

LinkedIn’s response to regulations – and Google’s plan in the future – has been to set, in its policies, that political adverts aren’t allowed at all on the platform. For LinkedIn, that includes adverts “exploiting a sensitive political issue”.

A LinkedIn spokesperson said that it has clear standards which it applies. And “when ads violate those standards, we remove them,” they said.

At the moment, under the EU Digital Services Act, digital services which are designated as “Very Large Online Platforms and Search Engines” have had to create their own ad libraries for greater transparency around who is pushing what.

Facebook, LinkedIn and many others have set up public “ad libraries” – but with varying levels of detail about the reach, rough spend, and targeting of adverts.

Nolan’s two adverts appear in LinkedIn’s ad library. But the two entries in the library do not show in any detail who the ads were targeted at.

Jose, the Green Party councillor, says that LinkedIn’s library doesn’t contain enough detail on spend and targeting. 

And for him, “it’s not enough to say we don’t run political ads”, he said. “Show me the transparency.”