Responsible Advertising Coalition
Payment Integrity & Traffic Transparency Framework
Version 2.0 - 5/15/2026
Table of Contents
- Purpose
- Guiding Principles
- Definitions
- Conditions for Safe Harbor
4.1 Transparent Source Attribution
4.2 Compliant Creative Forensics
4.3 Account Control & Access
- Safe Harbor Status
5.1 Proportional Adjustments for Network Clawbacks
5.2 Primacy of Safe Harbor for Network-Level Adjustments
5.3 Prompt Investigations / Payment Holds
5.4 Right to Cure
- Grounds for Non-Payment
6.1 Deceptive or Obfuscated Source Activity
6.2 Artificial or Automated Traffic Generation
6.3 Incentivized or Coerced Engagement
6.4 Measurement and Visibility Manipulation
6.5 Refusal to Cooperate or Provide Evidence
6.6 Ecosystem Notification Rights
- Position on Harmful Practices
- Adoption of the Framework
- Role of the Responsible Advertising Coalition
- Versioning and Citation
1. Purpose
In an effort to create a more transparent and resilient digital advertising ecosystem, the Responsible Advertising Coalition (RAC) has developed this Payment Integrity & Traffic Transparency 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 for developing high-integrity partnerships and as a neutral reference for resolving payment disputes. Industry participants who demonstrate adherence to pro-market principles deserve to be paid maximally and promptly, while Partners who systematically abuse the integrity of the industry should not be paid.
The Framework may be referenced in contracts and platform agreements as:
“Subject to the Payment Integrity & Traffic Transparency Framework published at getresponsible.org/payment-integrity”
2. Guiding Principles
The Framework is grounded in several core principles intended to promote fairness, transparency, and long-term ecosystem health:
- Transparency: Advertising traffic should be attributable to identifiable and verifiable sources.
- Accountability: Participants controlling traffic acquisition are responsible for operational transparency and cooperating with reasonable verification requests.
- Proportionality: Invalid traffic or policy violations from approved Traffic Sources should result in payment adjustments proportionate to upstream Network adjustments.
- Good Faith Participation: Partners meeting Safe Harbor Conditions should receive prompt payment and fair treatment during investigations.
- Ecosystem Protection: Conduct that obscures traffic origin, simulates user behavior, or manipulates measurement systems undermines the ecosystem and may justify full non-payment.
3. 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.
- 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. Networks continuously make adjustments to ensure advertisers only pay for legitimate Traffic. Clawback thresholds must be defined in Platform-Partner agreements.
4. Conditions for Safe Harbor
To earn Safe Harbor Status, a Partner must credibly and continuously meet all three of the below conditions (the “Safe Harbor Conditions”):
4.1 Transparent Source Attribution
- Traffic must only originate from Traffic Sources approved by the Platform.
- Partners must pass required parameters to truthfully disclose source, placement, and click identifiers for all traffic sent to Platforms.
- Platforms may require additional parameters or IDs.
- Source does not blend with other channels unless clearly labeled and approved.
- Partners must directly control or transparently disclose any intermediaries involved in acquiring Traffic from an approved Traffic Source.
4.2 Compliant Creative Forensics
- 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.
4.3 Account Control & Access
- 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 capable of being manipulated.
5. Safe Harbor Status
Partners who demonstrate full and continuous compliance are protected as follows:
5.1 Proportional Adjustments for Network Clawbacks
- Adjustments must match the scope and reasoning of Platform clawbacks.
- Platforms must provide credible evidence that the underlying Network Clawback occurred.
- Related adjustments must be reasonable and made in good faith.
5.2 Primacy of Safe Harbor for Network-Level Adjustments
- If Safe Harbor Status is maintained, any Network-level adjustments shall be governed exclusively by the Proportional Adjustments clause.
- Network-level adjustments shall not be standalone evidence to invoke Grounds for Non-Payment.
- Safe Harbor Status can only be voided by evidence of a direct breach of the Conditions.
5.3 Prompt Investigations / Payment Holds
- Platforms may conduct investigations and hold payments temporarily to evaluate potential clawbacks.
- Platforms may rely on reasonable evidence obtained during investigations to determine whether a Partner has maintained Safe Harbor Status or engaged in conduct under Grounds for Non-Payment.
- RAC recommends a maximum payment delay of 90 days, preferably completed within 60 days.
5.4 Right to Cure
- Partners who inadvertently fall out of compliance (e.g., failing to connect a new account) have a seven (7) day period to remedy the failure.
- Platforms must monitor and promptly notify Partners of suspected failures.
- The Right to Cure applies only to administrative or operational failures and does not apply to conduct described under Grounds for Non-Payment, including suspected traffic manipulation, fraud, or intentional concealment of Traffic Sources.
6. Grounds for Non-Payment
Non-payment may occur if Partners cannot or will not maintain Safe Harbor Conditions. Categories of impermissible conduct include:
6.1 Deceptive or Obfuscated Source Activity
- Spoofed clicks, masked referrers
- Traffic blended from non-approved sources
- Use of proxies, anonymizers, or untraceable networks
6.2 Artificial or Automated Traffic Generation
- Bots, click farms, emulated browsers
- Non-browser user agents, headless traffic, automated clicks
- Paid human click fraud or repeated high-frequency traffic inconsistent with human behavior
6.3 Incentivized or Coerced Engagement
- Click-to-earn or reward-based schemes
- Misleading UI placements
- Navigation traps or falsely labeled exit buttons
6.4 Measurement and Visibility Manipulation
- Impression logs without visual display
- Click logs without corresponding impressions
- Cookie stuffing or fabricated user agents
- Systematically manipulating conversion pixels
6.5 Refusal to Cooperate or Provide Evidence
- No access to ad accounts, logs, or campaign metadata
- Delay or obstruction in providing requested data
- Inability to demonstrate traffic was properly sourced
6.6 Ecosystem Notification Rights
If a Partner is found to not fulfill Safe Harbor Conditions upon investigation, the Platform may report to the RAC, all impacted Source Providers, and other reasonable third parties:
- Partner name, address, and other identifying information (including officer and director names and emails)
- Description of the violation or breach
- Partner traffic sources
- Specific acts or omissions constituting the violation or breach
7. Position on Harmful Practices
Traffic containing material contributions from artificial click mechanisms, engagement simulation, spoofing, or impression laundering not attributable to an approved Traffic Source shall receive no payment. Such abuses threaten the integrity of the advertising ecosystem.
8. Adoption of the Framework
- RAC encourages Platforms and Partners to incorporate this Framework by reference.
- Protections and obligations of Safe Harbor Status must be explicitly agreed upon.
- This Framework is intended to complement, not replace, the policies, enforcement mechanisms, and traffic quality determinations of Networks. Nothing herein limits a Network’s independent right to investigate, enforce policies, or adjust advertiser charges.
9. Role of the Responsible Advertising Coalition
- The RAC publishes the Framework as a voluntary industry reference.
- The RAC does not investigate individual disputes, adjudicate claims, or determine compliance.
- Enforcement and payment determinations remain the responsibility of participating Platforms, Networks, and contractual parties.
- RAC may publish guidance, research, or insights but does not certify compliance or maintain enforcement authority.
10. Versioning and Citation
- Version 1.0 — December 18, 2025
- Version 2.0 — May 15, 2026
- Updates may be published periodically; unless otherwise specified, references to the Framework refer to the version in effect at the time an agreement was executed.
- Standard citation format:
“Responsible Advertising Coalition Payment Integrity & Traffic Transparency Framework (Version 2.0), available at getresponsible.org/payment-integrity”