ANA Media Transparency: 10 Years On, What Now?

CMOs, Procurement Directors, and Global Heads of Media have been talking about the ANA media transparency report for a decade. Yet the latest data shows confidence in media agency transparency has barely moved.

This episode of #MediaSnack with Tom Denford and David Indo is your friendly but frank reminder that the problem is still real, and the opportunity is still huge.

In this breakdown we unpack:

• What has actually changed since 2016?

• Why principal media and programmatic complexity still put your budget at risk?

• The FOUR practical steps you can take in the next quarter

Think of it as a coach’s gameplan for finally turning the ANA’s work into competitive advantage in media.

Why the ANA media transparency report still matters for CMOs

The ANA media transparency report remains essential because it exposed systemic, non‑transparent media buying practices and gave advertisers a clear playbook to respond. Ten years later, new ANA data shows concerns are almost unchanged, which means money is still leaking from budgets and governance gaps are still putting brands and careers at risk.

In 2016, the ANA and K2 Intelligence found that non‑transparent practices, including undisclosed rebates and arbitrage, were pervasive in the US media ecosystem. The follow‑up guidance with Ebiquity outlined very specific fixes around contracts, audit rights, and principal media. That work gave CMOs unprecedented visibility into how their money really flows.

Fast‑forward to today and the industry is even more complex. Programmatic supply chains, principal media, and platform incentives mean many marketers still cannot confidently answer a simple board question: where does our media money actually go? That is not a theoretical issue. It is a direct threat to effectiveness, brand safety, and personal accountability.

One example highlighted in recent coverage is that concerns about transparency have barely shifted, despite all the noise. Instead of treating that as a depressing headline, treat it as a competitive opening. Advertisers who fix governance now gain a structural media advantage over peers who stay in the too‑difficult box.

Key transparency stats and risks CMOs need to understand now

Fresh ANA survey data of 108 client‑side marketers shows that 43 percent still have serious concerns about media agency transparency. Back in 2014 the figure was 46 percent, which means the needle has barely moved in a decade. Among those who are concerned, 49 percent say their worries increased over the last year, driven heavily by principal media.

Perhaps the most alarming single data point is that around 46 percent of advertisers do not know whether their contracts even contain transparency clauses. Almost half of the market is effectively flying blind on its most important protection mechanism. That chimes exactly with what Tom Denford and David Indo hear every week from senior marketers.

The ANA’s original K2 study described non‑transparent practices as pervasive in the US media ad‑buying ecosystem and documented undisclosed rebates and heavily marked‑up principal transactions. The anniversary discussion, covered recently by Campaign US, confirmed that many of the same issues remain today. You can still read the ANA summary and recommendations here: ANA K2 media transparency report and the 10‑year conference overview here: ANA Media Transparency Report: 10 Years Later.

For CMOs, the risk is not only wasted budget. It is also the widening asymmetry of power and knowledge. Agencies, ad tech vendors, and platforms understand the economics of principal and programmatic models in microscopic detail. Most client organizations do not. That imbalance naturally pushes decisions toward what is profitable for intermediaries rather than what is optimal for advertisers.

The ID Comms Breakdown: what, so what, and now what

What's going on?

On this episode of #MediaSnack, Tom Denford in New York and David Indo in London reflect on a three‑hour ANA webinar marking ten years since the original transparency report. The ANA brought back the 'Fab Four' of transparency:  Jon Mandel, Rich Plansky, Keri Bruce, and Nick Manning, alongside ANA leader Bill Duggan.

The conversation reinforced a simple truth. Despite a landmark report and years of guidance, many advertisers have not turned recommendations into action. Complexity in programmatic and principal media has grown, governance has not kept pace, and too many brands still treat media transparency as a specialist side issue rather than a board‑level concern.

What are the implications?

For advertisers without strong internal media leadership, the implications are stark. A trillion‑dollar global media industry operates with far less independent oversight than sectors like banking or pharma. Where governance is weak, non‑transparent commercial models flourish. As Jon Mandel reminded the audience, extreme complexity is a perfect breeding ground for abuse.

The practical implication is that brands without robust contracts, audit rights, and in‑house or external expertise are disproportionately exposed. They may be overpaying for inventory, accepting hidden arbitrage, or buying media that prioritizes agency margin over brand outcomes. That is money that could be funding better reach, better creative, or better first‑party data.

How should marketers be thinking?

David Indo encourages CMOs to reframe transparency as governance, not as conflict. The goal is not to 'go to war' with agencies, but to re‑establish advertiser primacy: you own the gold, so you set the rules. That means asking so‑called stupid questions, demanding clarity on the digital supply chain, and refusing to sign contracts you do not fully understand.

They also argue that this is a moment to lean in, not to wait. The ANA, ISBA and others have already done the heavy lifting on contract templates and best practice. Advertisers who act now can secure cleaner commercial models, stronger protections, and more aligned incentive structures. Those who delay risk being left with legacy deals that silently erode performance.

Four practical actions to reset your media governance this quarter

If you are a CMO, Procurement Director, or Global Head of Media, you do not need another abstract lecture on transparency. You need a simple gameplan you can start on Monday.

Drawing on the episode, here are four moves you can make in the next quarter that will materially improve your media governance.

• First, find and read your current media agency contract. It is surprising how often leadership teams cannot locate the latest signed version. Check whether it includes clear transparency clauses, audit rights over all buying entities, explicit treatment of principal media, and obligations around data, rebates, and inventory reselling. If these are missing, you have identified a concrete risk, not an academic concern.

• Second, benchmark your contract against best‑practice templates from the ANA or ISBA and plan an update cycle at least annually. In the ANA survey, 56 percent of members updated contracts in the last 12 months, but only 61 percent of those contracts addressed principal media. If your spend is significant, schedule a structured re‑negotiation that tightens definitions and closes loopholes.

• Third, verify your digital supply chain. Commission an independent review or audit that traces where every programmatic dollar goes, including ad tech fees, non‑human traffic, and media quality. Many advertisers spend tens of millions of dollars through programmatic pipes they have never independently examined.

• Fourth, get expert support. If you spend more than roughly 50 million dollars a year on media, you should have an internal media leader or specialist. If you cannot justify that headcount, work with an experienced external partner like ID Comms to design governance frameworks, pitch processes, and incentive models that reward transparency and performance. The fee for good advice is tiny compared with the value at stake.

Finally, remember to treat this as an opportunity, not a crisis.

Better governance increases effectiveness, protects your reputation, and frees up budget for growth. If you want a confidential review of your current media 'gameplan' and the options to protect your competitive advantage in media, get in touch with ID Comms and we will happily walk you through it.

Frequently Asked Questions on media transparency and the ANA report

Q1. What was the original ANA media transparency report about?
It was a 2016 study by the ANA and K2 Intelligence that found non‑transparent practices, including undisclosed rebates and arbitrage, to be pervasive in the US media buying ecosystem.

Q2. Has media transparency improved in the last 10 years?
Not much. ANA survey data shows that 43 percent of advertisers still have serious concerns, compared with 46 percent in 2014. Among those concerned, almost half say the situation has worsened.

Q3. Why is principal media such a concern for advertisers?
Because agencies can buy inventory in bulk and resell it to clients on different terms. This can create strong incentives to prioritize agency margin over advertiser value, especially when contracts do not clearly regulate the practice.

Q4. Do all agencies use opaque arbitrage models?
No. As Tom Denford notes, there are meaningful differences between agency groups and even between local agency brands. Some are leaning hard into reselling models, others are actively rejecting them. The key is to understand each partner’s model in detail.

Q5. What is the single most important first step for a CMO?
Locate and review your media agency contract. Confirm that it covers transparency, audit rights, principal media, data ownership, and rebates. If you are unsure, get specialist legal or consulting support.

Q6. How often should we update our media contracts?
At least annually. The ANA data shows that even among advertisers who updated contracts in the last year, a large minority still failed to address principal media, so this should be a standing agenda item.

Q7. Is this just a US issue, or global?
While the K2 report focused on the US, similar incentives and practices exist globally. In some markets principal trading is more established and can be managed transparently, but the same governance principles apply everywhere.

Q8. Do I need a dedicated media leader in‑house?
If you are spending tens of millions annually, having a Chief Media Officer or equivalent is usually worth it. Bill Duggan suggested that in the US, 50 million dollars in spend is a sensible threshold.

Q9. How should I talk to my agency about transparency without damaging the relationship?
Frame it as governance, not accusation. Share your responsibility to your board and shareholders, ask clear questions, and be explicit that you want commercial models that reward performance and long‑term partnership.

Q10. Where can I get help building a better media governance framework?
Trade bodies such as the ANA and ISBA publish contract guidance and checklists. Firms like ID Comms work directly with CMOs, procurement, and global media leaders to design and implement practical governance that unlocks better media value.

Episode Transcript: #MediaSnack on 10 years of ANA transparency

Hello, I'm Tom Denford in New York. And I'm David Indo from London. Welcome to Media Snack Live. It's our weekly roundup of all the important news and stories and trends you need to know about the global media and marketing industry. In every show we ask what is going on, what are the implications for advertisers, and what should marketers be thinking about next? Thanks for joining us. Let's get into this week's show.

There we go. Hello. Hello. I've just realized our names are not coming up, but anyway. Hello. You've just tuned. Well, welcome to Media Snack. I'm Tom Denford. I'm in New York. And I'm David Indo in London.

Excellent. Good. Right. This is an interesting one. On Monday, David and I were invited to join a three‑hour webinar, not our usual Monday morning investment of time, but a really good one hosted by the Association of National Advertisers, the ANA, which is the big trade body based in the US, but impacting globally. The largest advertiser trade body in the world.

They were acknowledging that it's been 10 years, believe it or not, since they first published their media transparency report, which came out on 1 June 2016. They gathered together lots of people who were there at the time, including many advertisers and ANA members, to discuss what was behind it, what they were trying to do, and what the impact has or has not been.

There are areas where there is genuine excitement that the report has made a huge difference, and there are areas where we collectively all say, 'Why are we not doing more here?' I thought it was a really good session, a brilliant session in fact.

And kudos to Bill Duggan, one of the leaders at the ANA, who managed to bring together the 'Fab Four', as he described it. On the call summarizing the report findings and providing a perspective on where the industry has got to over the last 10 years were some brilliant characters. We had the legend that is John Mandel, who some people could argue initiated the whole process and shone a light on the issue.

For those that don't know John, he was a very senior member of the WPP leadership team. He stood on an ANA platform in March 2015 and announced to the world that there were transparency issues and that rebates within the US marketplace were commonplace. That triggered the whole ANA involvement in this process.

We also had Rich Plansky, who was part of the K2 auditing firm that conducted the original work, Keri Bruce from Reed Smith, and Nick Manning, a very well‑regarded consultant. These were four key stakeholders who delivered a strong summary of what the report delivered and where we have got to.

Tom and I were looking forward to hearing the report at the time 10 years ago. We had participated in the tendering process to be part of the consulting team that worked on it and had followed the journey closely. When the report came out, we were extremely excited because it was a landmark piece of work.

It was a watershed moment within an industry that, frankly, still operates with very little regulatory oversight despite being a trillion‑dollar business. If you look at other industries that operate at that scale, such as banking, telecommunications, insurance, or pharmaceuticals, there is governance and independent oversight that ensures transparency and enforces protocols. Media does not have that, so it relies on trade bodies like the ANA to provide leadership. In this instance, they certainly did.

In this episode, we want to reflect on why and what to do next. The ANA is generous in making this kind of research public, providing it to members and inviting people like us along. We work with many of those advertisers, and they often say, 'Okay, fine, that was really interesting, and now what?'

So the theme of this episode is, 'And now what?' We will talk about what has happened since, what the implications are, and what you are going to do. Before that, Tom shares a treat: a clip from ten years ago when ID Comms joined one of the original ANA briefing calls as the report was launched. It reminded us how big a moment it felt even then.

Ten years on, we ask for an update. We do not need to re‑explain the whole report. If you have never seen it, you are probably in a minority, but an important minority, because you have to read it. We will link to it. You need to see it.

The disappointing part of the update is the general stagnation in the last 10 years. The report highlighted non‑transparent business practices within US media agencies, including undisclosed rebates and highly marked‑up principal trading transactions that advertisers did not think were prevalent. The report described these practices as pervasive across the US.

We believed at the time that the report would be a significant catalyst, forcing advertisers to demand greater transparency in their contracts and in how agency partners operated. We expected almost immediate change. Yet a new ANA survey of members suggests otherwise.

David reads some of the figures. A recent survey of ANA member companies revealed that 43 percent of advertisers still have serious concerns about levels of transparency. When that question was asked 10 years ago, the figure was 46 percent. So nothing has really changed.

Among advertisers who are concerned, 49 percent say the situation has gotten worse over the last 12 months. But the most surprising figure is that 46 percent of advertisers do not know whether they have transparency clauses in their contracts. Just under half do not know whether their contracts protect them on transparency issues.

While 56 percent of ANA member companies updated their contracts in the last 12 months, only 61 percent of those contracts actively address principal media. Nearly 40 percent of updated contracts do not even mention it.

Trade bodies such as the ANA and ISBA can only do so much. If advertisers do not lean in and act on insights and recommendations, little will change. Tom asks David, as a former media director at companies like Coca‑Cola and Nike, why more marketers have not picked this up.

David suggests two reasons. First, not all organizations have specialist media experts in‑house. Bill Duggan said that in the US, if you are spending 50 million dollars or more a year on media, you should have a specialist. Those that have not leaned in often lack someone responsible.

Second, media transparency is complicated, and the industry has made it more so. As Rich Plansky noted, extreme complexity can be a breeding ground for non‑transparency, and non‑transparency often leads to fraud. Many generalist marketers put media transparency in the 'too difficult' box.

The advertisers that do have media leaders or procurement specialists who understand media are generally in better shape. The problem shows up most strongly among brands without that capability.

Tom notes that the honesty in the ANA survey is helpful. Marketers admitting they have no idea about their contract protections shines a light on the real situation. The true number is probably even higher.

The good news is that the industry at least recognizes the problem. Transparency is still a gnarly, nebulous concept. ID Comms has spent the last 10 years advising advertisers who come to ask what to do about it. The aim now is practical advice.

Tom highlights a few implications. Without the ANA’s work, things might have been far worse. The awareness created has probably reined in some of the worst practices. But digital expectations of precision and accountability have actually produced huge complexity in the supply chain. Many marketers now say they really do not know where their money goes.

Principal media is a particular flashpoint. In many non‑US markets, principal trading can work for advertisers if governed transparently. The US, however, is not technically a principal market, yet similar arbitrage incentives exist. Agencies may not take the same inventory risk, but they often have more profitable inventory they are motivated to sell on.

In advance of the episode, some agency CEOs asked Tom not to lump everyone together, and he agrees. There are meaningful differences between holding companies and networks. If you are pitching agencies or curious about models, ID Comms can help you understand who does what, without naming and shaming on air.

The bigger issue is the widening gap in understanding. Agencies and platforms have asymmetric power over the complexity and business models, while clients see a black box. The solution is to re‑establish primacy for the advertiser: you own the gold, so you make the rules.

David then lays out three immediate tactics and one harder move. First, update your contracts using ANA or ISBA best‑practice templates. Second, stop fearing 'stupid' questions and demand to know where your digital money is going. Third, verify your spend, especially in programmatic, to ensure you are not paying for non‑human traffic or waste.

The harder move is to hire expertise, either in‑house or via a partner like ID Comms. If media is a lever for growth and competitive advantage, it is too important to ignore.

Tom adds that if you are planning a media agency pitch, it is a perfect moment to upgrade governance: scope of work, contract terms, and payment models that reward transparency and service. ID Comms' Pitch Week is designed to help advertisers run lean but rigorous pitches with strong governance baked in.

To close, David’s parting shot is simple: on Monday, find and read your contract. Make sure there is at least some protection. Start there and build. Tom reinforces that ID Comms will happily review contracts under NDA and point out concerns, because every dollar of media you recover can be reinvested in growth.

Thanks for watching Media Snack Live. If you found it helpful and want to learn more, head to idcomms.com to get more tips, tools, and resources to help you get good at media. We'll see you next week.