Shadow Campaigns in India – Regulating Political Influence in the Age of Digital Intermediaries
iasparliament
December 29, 2025
Mains: GS II – Governance
Why in News?
Recently, there has been concerns over the issues of the shadow campaign in the electoral process of India.
What is the issue?
Shadow campaigns – It refer to political communication efforts carried out by third-party actors such as digital marketing firms, ideological groups, influencers, or surrogate pages that are not officially linked to political parties or candidates.
Missing regulation – While election rules continue to focus on political parties and candidates as the primary actors, contemporary electoral influence is shaped by a broader ecosystem of third-party intermediaries, including campaign firms, digital influencers, interest groups, and surrogate advertisers.
India’s electoral regulatory framework is increasingly misaligned with the realities of modern political campaigning.
Supreme Court’s directive – This disconnect was highlighted during the Bihar Assembly elections, when the Election Commission of India (EC) issued a series of directives aimed at regulating political advertisements, exposing critical gaps in both the scope and timing of election regulation.
Election commission’s directives – On October 14, the Election Commission mandated pre-certification of political advertisements by the Media Certification and Monitoring Committee (MCMC).
It reiterated the requirement under Section 77(1) of the Representation of the People Act, 1951, which obliges political parties to disclose expenditure on social media campaigns.
On October 21, the EC expanded its advisory, prohibiting political advertisements in print media on polling day and the preceding day without prior MCMC approval.
These measures aimed to ensure transparency and fairness in electoral communication.
What are the limited lens of regulation?
Overemphasis on Parties and Candidates – The EC’s directives continue to address political parties and candidates as the central regulatory subjects.
This approach overlooks the reality that electoral outreach is increasingly mediated by third-party actors operating outside formal party structures.
Campaign consultancies, influencer networks, and issue-based organisations now play a decisive role in shaping voter perceptions.
Narrow Media and Time Focus – The October 21 notification extended regulation to non-party entities but applied only to print media.
The restriction was limited to a narrow pre-poll window, despite digital campaigns peaking well before polling day. This reveals a regulatory imagination that remains anchored in legacy media, even as electoral persuasion has decisively shifted to digital platforms.
Digital Campaigns and the Question of Timing – Digital political campaigns operate on a long temporal arc, building influence over weeks and months through repeated exposure.
Regulations that activate only immediately before polling are ineffective in addressing persuasive effects already embedded in voter consciousness.
The mismatch between the speed of regulation and the scale of digital influence allows early-stage manipulation to go unchecked.
Bihar Assembly Election as a Case Study – The Bihar Assembly election provides a useful empirical case to examine shadow campaigning.
Data from Meta’s Ads Library was analysed for political advertisers spending more than ₹1 lakh in Bihar during the 30 days preceding November 10, the day before the final polling phase.
Advertisers were categorised into official party or candidate pages and third-party actors.
Who Pays and Who Persuades?
Distribution of digital campaign spending – During the period analysed, 55 advertisers spent more than ₹1 lakh on digital political advertisements on Meta platforms.
Only 23 advertisers were official political parties or candidates.
The remaining 32 advertisers were third-party or surrogate campaigners operating independently.
This demonstrates that a significant proportion of electoral messaging originates outside formally regulated actors.
Unequal Circulation of Political Messages – Digital political influence depends not only on expenditure but also on reach and algorithmic amplification.
Despite near-identical average spending, third-party advertisers generated almost twice the average impressions compared to official party or candidate pages.
This suggests that communicative power in digital elections is increasingly concentrated outside formal political actors.
Age-wise consumption patterns – Approximately 76.4% of digital outreach by parties and candidates, and 74.5% by third-party actors, was consumed by individuals aged 13–34 years.
Party and candidate advertisements remained sharply concentrated among the 13–24 and 25–34 age groups.
Third-party advertisements displayed a more dispersed reach, generating higher impressions among 25–44-year-olds and retaining significant presence beyond the age of 44.
This indicates that third-party actors are more effective in reaching a broader demographic spectrum.
Campaign efficiency and cost asymmetry – Campaign efficiency was measured as impressions generated per ₹10 lakh spent.
Third-party advertisers generated an average of 2.60 crore impressions, while party or candidate pages generated 1.54 crore impressions.
This stark difference demonstrates that equal financial inputs result in unequal political visibility.
Blurring of financial responsibility – The analysis revealed cases where official party pages hosted advertisements funded by external entities.
For example, advertisements on the official Meta page of the Janata Dal (United) were sponsored by an entity named “The Spectrum”.
Such arrangements raise serious concerns regarding the transparency of campaign finance reporting.
Understatement of true campaign expenditure – Expenditure incurred by third-party entities to sponsor ads on official pages may not be reflected in party expenditure statements submitted to the EC.
This leads to a systematic underreporting of the actual financial footprint of digital campaigning.
What are the legal and constitutional concerns?
Supreme Court precedent – In Secretary, Ministry of Information and Broadcasting v. M/s Gemini TV (2004), the Supreme Court held that no individual or entity may publish advertisements for the benefit of any political party or candidate.
By implication, advertisements directed against a party or candidate are equally impermissible, as they benefit rival political actors.
Inconsistent application by the EC – Despite this legal position, third-party actors continued campaigning during polling hours in the Bihar elections.
The EC’s guidelines did not adequately extend regulatory obligations to these actors, creating an accountability gap.
The accountability gap in campaign finance – Political parties are required to disclose what they spend on elections.
They are not required to disclose what others spend on their behalf.
Digital expenditure disclosures often list payments under platform names such as “Facebook” rather than identifying the actual funders or content creators.
The reverse flow of funding, where third-party entities finance advertisements on official party pages, remains legally invisible.
This inversion poses a serious threat to electoral transparency and fairness.
Temporal misalignment – Electoral influence now accumulates over prolonged digital exposure rather than last-minute messaging.
Regulations triggered only at the end of campaigns fail to address structural manipulation occurring earlier.
Democratic costs –Each election conducted without comprehensive digital regulation erodes public trust in electoral fairness.
The continued mismatch between law and practice risks weakening India’s democratic legitimacy in the digital age.
What lies ahead?
India’s election rules are governing a campaign ecosystem that no longer exists in isolation around political parties and candidates. Electoral influence today flows through a complex network of digital intermediaries whose financial and communicative power remains largely unregulated.
The challenge is no longer one of recognising this transformation, but of demonstrating regulatory resolve.
Unless election laws expand their scope to include third-party actors, platform dynamics, and long-duration digital persuasion, the gap between formal compliance and real influence will continue to widen, undermining the foundations of democratic accountability.
