Network Advertising Initiative
The NAI is an industry trade group founded in 2000 that develops self-regulatory standards for online advertising. Advertising networks created the organization in response to concerns from the Federal Trade Commission and consumer groups that online advertising — particularly targeted or behavioral advertising — harmed user privacy. The NAI seeks to provide self-regulatory guidelines for participating members.
History
The NAI was formally announced at the Public Workshop on Online Profiling held by the FTC and the Department of Commerce on November 8, 1999. Its membership then consisted of 24/7 Media, AdForce, AdKnowledge, Adsmart, DoubleClick, Engage, Flycast, MatchLogic, NetGravity and Real Media.In July 2000, the NAI published a set of principles, negotiated with the FTC and endorsed by the FTC, in their report to Congress on online profiling. In May 2001, the NAI released an accompanying website allowing users to more quickly download opt-out cookies for all participating ad networks.
In 2002, the NAI released guidelines for the use of web beacons — small images or pieces of code used to track visiting and traffic patterns, and to install cookies on visitors' machines. These guidelines use a similar model of notice and choice as the NAI Principles; opt-in consent is only required when sensitive information is associated with personally identifiable information and transferred to a third party.
In 2003, the NAI formed the Email Service Provider Coalition. The ESPC engages in lobbying, press relations and technical standards development to support "email deliverability" — ensuring that mass email delivery continues despite anti-spam legislation and technologies. Today the two organizations exist entirely independent from each other.
In response to a 2007 FTC staff report, the NAI published an updated set of principles in December 2008 after providing a draft in April for public comments. The new principles incorporated new restrictions on the collection and use of sensitive data and data related to children.
In 2009, the NAI launched a consumer education page, which provided a centralized location for a variety of informational articles, videos, and other creative content designed to educate users about online behavioral advertising.
In 2010, the NAI joined the Digital Advertising Alliance, a non-profit organization of leading companies and trade associations including the Association of National Advertisers, the American Association of Advertising Agencies, the Direct Marketing Association, the Interactive Advertising Bureau, the American Advertising Federation and the NAI. These associations and their members are dedicated to developing effective self-regulatory solutions to consumer choice for web viewing data.
In 2012, the NAI issued its third compliance report, which demonstrated that overall, the NAI member companies continue to meet the obligations of the NAI code.
Ad network membership in the NAI fluctuated between 12 members in 2000, two members in 2002-2003 and five members in 2007, prompting criticism that it did not consistently represent or regulate the industry. As of July 2017, the NAI lists over 100 members, including Google, Microsoft and Yahoo!.
In 2013, the NAI released its fourth annual compliance report. The report described the NAI's planned initiatives for 2013, which included the development of a revised NAI Code of Conduct governing the collection and use of data on mobile devices. Additionally, in 2013, the NAI released its first Mobile Application Code, which expanded the organization’s self-regulatory program to cover data collected across mobile applications.
In 2014, NAI released its 5th Annual Compliance report, showing that NAI members overwhelmingly met their obligations under the provisions of the code and continued to uphold the NAI's rigorous standards for providing notice and choice around interest-based advertising. The NAI compliance team reviewed 88 member companies. The NAI also created a prestigious one-year compliance and technology fellowship for highly qualified graduates with an interest in the intersection of technology, advertising and policy.
In May 2015, the NAI released an update to the Code of Conduct and its Guidance for NAI Members: "Use of Non-Cookie Technologies for Interest-Based Advertising Consistent with the NAI principles and Code of Conduct ". In July 2015, the NAI released its Guidance for NAI Members: "Determining Whether Location is Imprecise ", which provided clarity on the types of location data that may require opt-in consent. In August 2015, NAI released an update to the Mobile Application Code in order to incorporate many of the changes in the 2015 Update to the NAI Code of Conduct and apply them to the mobile advertising ecosystem.
As of January 1, 2016, NAI members engaged in cross-app advertising are required to come into compliance with the Mobile App Code. Also in April 2016, NAI welcomed its 100th member, evidence of the continued appeal of the NAI's compliance program. In September 2016, the NAI became one of the founding members of the Coalition for Better Ads, an industry coalition developing new global standards for online advertising.
In 2017, the 2018 NAI Code of Conduct was released. Also released in 2017 were updates to the non-cookie technology guidance, titled Guidance for NAI Members: Use of Non-Cookie Technologies for Interest-Based Advertising, and a cross-device linking guidance in May 2017.
In 2019, the most recent version of the NAI Code of Conduct was released.
In 2022, the NAI released Precise Location Information Solution Provider Voluntary Enhanced Standards.
In 2023, the NAI announced that they temporarily paused enforcement of the 2020 NAI Code of Conduct in order to draft new governing guidelines that more accurately reflect state legal requirements.
In 2025, the NAI launched the NAI Self-Regulatory Framework which superseded and replaced the 2020 NAI Code of Conduct. The Framework establishes a new approach to self-regulation based on five core Privacy Principles for NAI members.
NAI Principles & Self-Regulatory Framework
In March 2025, the Network Advertising Initiative adopted a new Self-Regulatory Framework to guide privacy practices for member companies engaged in network advertising in the United States. The Framework replaced the legacy 2020 NAI Code of Conduct and was designed to better align industry self-regulation with the rapidly evolving landscape of state and federal privacy laws. Rather than imposing detailed prescriptive requirements, the Framework is structured around a set of high-level privacy Principles that establish a baseline standard of conduct for NAI members, together with non-binding guidance, best practices, tools, and annual accountability reviews to help members implement the Principles and comply with applicable legal obligations.The Framework defines five core principles that all NAI member companies must adhere to as a condition of membership:
Transparency: Members must provide clear, accessible disclosures about their processing of personal data, including what data is collected and how it is used.
Choice and Consumer Control: Members are required to offer mechanisms by which consumers can express choices about how their personal data is processed, in accordance with applicable laws regarding opt-in and opt-out rights.
Data Governance: Each member must implement data governance practices to ensure that personal data processing aligns with both the company’s privacy commitments and legal obligations, including procedures for honoring consumer choices and updating disclosures.
Sensitive Personal Data: Members must limit the processing of sensitive personal data to disclosed purposes and, where required by law, obtain consumer consent, while also providing additional safeguards when handling such data.
Accountability : Companies must demonstrate, through documentation and participation in the NAI’s annual privacy review process, that they are meeting their privacy commitments and legal obligations with respect to personal data processing.
The Framework’s accountability component continues the NAI’s practice of annual privacy reviews, in which member companies undergo assessments that include questionnaires and interviews with NAI staff to confirm adherence to these Principles. The NAI emphasizes that the Principles are intended to be adaptable and to support compliance with relevant privacy laws rather than to supplement or conflict with them; they function as a flexible, organizational privacy foundation for network advertising activities in the U.S.
Criticism
The NAI and its set of self-regulatory principles have been widely criticized by consumer advocacy organizations.Since its first review in 2007, however, the World Privacy Forum’s founder has described the NAI improvements “profound,” calling its 2013 Code of Conduct “remarkable” for a number of reasons. The founder went on to say that the “NAI represents a really important step forward for what self-regulation has been.”
Concerns have also been raised about the process for developing and enforcing the NAI principles. The Electronic Privacy Information Center criticized the negotiation of the original set of principles for not substantively including privacy advocates or consumer protection organizations, a concern echoed by seven senators in a letter to then FTC Chairman Pitofsky.
The NAI used TRUSTe for third-party enforcement of its principles starting in 2002, but over time TRUSTe provided less and less detail in their reports on consumer complaints about the NAI and stopped reporting these complaints altogether in 2006. When the NAI published updated principles in 2008, it chose to review member compliance itself, which the Center for Democracy and Technology argued would reduce consumer trust in the organization. The NAI responded to this criticism on its blog.
The NAI initially allowed for "associate members" to join the association; these members were not required to comply with the organization's principles. However, this concept was quickly discarded, and all members of the NAI are currently required to comply with the NAI Codes of Conduct and are evaluated regularly.