Payment Integrity Framework

---

Responsible Advertising Coalition

Payment Integrity Framework

Version 1.0 - December 18, 2025 (original version)

Purpose

In an effort to create a more transparent and resilient digital advertising ecosystem, the Responsible Advertising Coalition (RAC) has developed this Payment Integrity Framework (“the Framework”) to guide when payment to traffic partners (e.g. agencies, media buyers, affiliates) should and should not be made. The goal of the Framework is to reward transparency and good-faith participation while eliminating incentives for systemic abuse.

The RAC hopes the Framework serves as a basis both for developing high integrity partnerships and as a neutral reference for resolving payment disputes. It is the RAC’s view that industry participants who can demonstrate adherence to pro-market principles deserve to be paid maximally and promptly, but that Partners who systematically abuse the integrity of the industry should simply not be paid at all.

The Framework below defines how Partners can and should achieve “Safe Harbor Status” and provides a non-comprehensive list of categories of abuse that in our view, should void Platform payment obligations.

The Framework  may be referenced in contracts and platform agreements as: "Subject to the Payment Integrity Framework published at getresponsible.org/payment-integrity"

Definitions: 

• Platform: A company that promotes advertisements from a Network (whether through owned and operated properties, agency partnerships, or contractors) and has a direct contractual relationship with that Network
• Partner: A third-party media buyer, an affiliate, or a web publisher who displays or promotes ads from a Platform.
• Traffic: User visits to a website or application.
• Traffic Source: An advertising network from which media can be bought to promote a Platform’s products or services by a Partner.
• Network: A large aggregator of advertising demand, such as Yahoo, Bing, Google, Taboola, or the like.
• Clawback: A significant adjustment to tracked revenue after-the-fact. The advanced nature of fraud means that Networks are continuously making adjustments to ensure that advertisers only pay for legitimate Traffic. The threshold for what constitutes a Clawback must be defined in a Platform-Partner agreement so that all parties agree in advance. 

Conditions for Safe Harbor
In order to demonstrate compliance and to earn Safe Harbor Status, a Partner must credibly and continuously meet all three of the below conditions (the “Safe Harbor Conditions” or the “Conditions”)

While the Framework provides the minimum "Safe Harbor Conditions," Platform-Partner agreements must detail specific requirements, which may include, but are not limited to, requiring programmatic access to ad accounts for verification, specific log formats, or standard login access for auditing purposes. This ensures clarity on the operational control and transparency standards expected by that specific Platform.

1. Transparent Source Attribution: All traffic must be traceable to a known and approved source.

• Traffic must only originate from Traffic from Sources (e.g. Facebook, GDN, Taboola) approved by the Platform.
• Partners must pass a set of required parameters to truthfully disclose source, placement, and click identifiers for all traffic sent to Platforms.
• Platforms may require other parameters or IDs. 
• Source does not blend with other channels unless clearly labeled and approved.

2. Compliant Creative Forensics: All creatives must be available for review and mappable to landing page experiences to validate compliance.

• All ads can be previewed in real time or captured in archived logs.
• Each click or impression maps to a specific, identifiable creative.
• Creatives comply with known platform and advertiser policies.

3. Account Control & Access: Ad accounts used to deliver traffic must be owned or contractually controlled by the buyer.

• Full access may be provided for validation (programmatic or manual).
• Buyer can demonstrate operational control over accounts and sub-contractors.
• No use of gray-market, syndicated, or third-party blended accounts that are capable of being manipulated.

Safe Harbor Status: 

In the event that a given Partner has demonstrated full and continuous compliance with the above evidentiary and behavior standards it is the RAC’s position that all such Partners be treated with good faith given the below protections:

• Proportional Adjustments for Network Clawbacks: If a Network (e.g. Google, Yahoo, Bing) claws back spend due to invalid traffic or policy violations, payment to the buyer may be adjusted in proportion to what the platform did not pay.
  
  • Adjustment must match the scope and reasoning of Platform clawbacks. 
  • The Platform must provide credible evidence that the underlying Network Clawback actually occurred. 
  • Though Network Clawbacks often lack the detailed and granular attribution real-time reporting, Platforms must ensure that any related adjustments to the Partner's payment must be a reasonable and good-faith apportionment of that total Clawback.
    
    
• Primacy of Safe Harbor for Network-Level Adjustments
  
  
  • If a Partner has maintained Safe Harbor Status, any Clawbacks, quality adjustments, or invalid traffic originating from an approved Traffic Source (e.g., Google, Facebook, Taboola) shall be governed exclusively by the "Proportional Adjustments" clause.
  • Such Network-level adjustments, regardless of their financial magnitude, shall not be used as standalone evidence to invoke the "Grounds for Non-Payment" (e.g., as "Artificial or Automated Traffic Generation").
  • A Partner's Safe Harbor Status can only be voided by evidence of a direct breach of the any of the three conditions (e.g., the Partner blended the approved source with a hidden source, or the Partner refused to cooperate with an investigation).
    
    
• Prompt Investigations / Payment Holds: It is within the rights of a Platform or Network to conduct a thorough investigation into traffic integrity, and further to hold a Partner payment for a period of time to understand the extent of a potential Clawback. In the event that a Partner has Safe Harbor Status, the RAC believes that best efforts should be made to make such payment holds and investigations as short as possible.
  
  
  • In order to delay a payment the Platform must have credible concern that a prospective payment will receive a Clawback. 
  • The RAC recommends a maximum payment delay of 90 days from the originally scheduled payment date, but prefers investigations be completed within 60 days.
    
    
• Right to Cure: In the event that a Partner inadvertently falls out of compliance by failing to abide by one or more of the Safe Harbor Conditions (for example, by adding a new TikTok account but failing to connect it) the Partner shall have a seven (7) day right to cure such failure.
  
  
  • In order to be deemed out of compliance with the Safe Harbor Conditions, Platforms are expected to monitor and promptly notify a Partner of any suspected such failure. 
  • If a Platform has granted Safe Harbor Status to a Partner but fails to monitor or validate such status, it shall treat inadvertent or immaterial failures to comply (such as failed account connections) fairly and in good faith, and not as grounds for unilateral non-payment of all revenues.

Grounds for Non-Payment
Given the negative ecosystem effects of non-compliant and invalid traffic, Platforms are generally within their rights to withhold all payments to Partners who cannot or will not maintain all of the Safe Harbor Conditions.

In addition to failing to proactively maintain such Conditions, the following categories of behavior describe conduct that is categorically impermissible and reflective of ill-intent, and that, as a result, void Safe Harbor Status, irrespective of past status. If a material volume of Traffic (as determined by advertiser or platform partner) exhibits one or more of these traits and can be attributed to the Partner or its subcontractors, that traffic may be disqualified from ALL payment - even if some or even a majority of it was paid for by a Network.

If a Partner lacks Safe Harbor Status, the appearance of traffic matching the below descriptions creates a rebuttable presumption of a breach. That is, if the offending traffic originated from an approved Traffic Source, but the Partner had not established or maintained Safe Harbor Status, the burden of proof is on the Partner to demonstrate that they did not, in fact, originate, encourage, or blend the non-compliant traffic. In the absence of such evidence, Platforms are within their rights to presume complicitness or even active participation in the fraud and withhold all payment.

Such a punitive framework is required because the marginal cost of illegitimate traffic is often a tiny fraction of legitimate Safe Harbor Traffic, so a bad faith actor could theoretically generate large profits even if they experienced a Clawback of over 50%.

Furthermore, the RAC believes that “bad money drives out all good,” and that the abuses below threaten the integrity of the entire online advertising ecosystem just as counterfeit money threatens a currency. 

1. Deceptive or Obfuscated Source Activity: When traffic origin is hidden, falsified, or disguised.

• Spoofed clicks or masked referrers.
• Traffic blended from non-approved sources.
• Use of proxies, anonymizers, or traffic networks that prevent traceability.

2. Artificial or Automated Traffic Generation: When user behavior is simulated or induced by non-human means.

• Bots, click farms, or emulated browsers.
• Non-browser user agents, headless traffic, or automated click tools.
• Paid human click fraud.
• Repeated or high-frequency traffic inconsistent with human interaction.

3. Incentivized or Coerced Engagement: When users are offered compensation or tricked into engaging.

• Click-to-earn schemes or reward-based traffic.
• Misleading UI placements (stacked, hidden, or hijacked ads).
• Navigation traps or falsely labeled exit buttons.

4. Measurement and Visibility Manipulation: When impression or engagement data is falsified or misrepresented.

• Impression logs without visual display.
• Click logs without corresponding impression logs.
• Cookie stuffing or fabricated user agent strings.
• Systematically firing or triggering conversion pixels so as to manipulate quality measurement systems.

5. Refusal to Cooperate or Provide Evidence: When the Partner fails to provide sufficient logs or transparency for investigation.

• No access to ad accounts, referrer logs, or campaign metadata.
• Delay or obstruction in providing requested data.
• Inability to demonstrate that traffic was sourced properly.

Ecosystem Notification Rights

Where a Platform conducts a reasonable investigation and determines that a Partner has materially failed to satisfy one or more of the Safe Harbor Conditions, or has engaged in conduct described under the Grounds for Non-Payment, the Platform may, in its sole and reasonable discretion, notify relevant ecosystem participants of the violation.

Such notification may include, without obligation of confidentiality, disclosure to the Responsible Advertising Coalition (RAC), impacted Traffic Sources or Source Providers, Networks, and other parties reasonably necessary to protect the integrity of the advertising ecosystem.

Information disclosed may include:

• Partner legal name and business address
• Corporate or operational identifying information, including officer or director names and associated business contact information
• A description of the conduct constituting the violation or breach
• Traffic Sources or advertising channels used in connection with the non-compliant activity
• A summary of the acts or omissions giving rise to the determination

The purpose of such disclosure is to enable ecosystem participants to take appropriate protective measures and to discourage systemic abuse of advertising platforms.
 

Position on Harmful Practices
The use of artificial click mechanisms, engagement simulation, spoofing of network identifiers, or impression laundering causes irreparable harm to both the advertiser and the industry at large. The RAC takes the position that any traffic proven to contain a material contribution from such elements that are not attributable to an approved Traffic Source should receive no payment, regardless of the extent of upstream Clawbacks.

Without such a deterrent good faith actors are continually placed at a disadvantage and the advertising ecosystem is harmed.

We encourage all Networks, Platforms, and Partners to adopt this framework as a baseline for good-faith participation and fair compensation.

Adoption of the Framework

The RAC encourages Platforms and Partners to incorporate this Framework into their service agreements by reference. The protections and obligations of "Safe Harbor Status" are not automatic and must be explicitly agreed upon by both parties.

A Platform's agreement may define its own "Safe Harbor" criteria. However, if an agreement states that a Partner "has Safe Harbor Status" or is "in compliance with the RAC Payment Integrity Framework," the definitions and protections herein are intended to apply.