Limitations on Customer List Custom Audiences

Meta will impose new restrictions on customer list custom audiences in 2025. Does this apply to you? What should you do?
Let’s get started…
Who does this apply to?
These restrictions apply to advertisers using Customer List Custom Audiences to promote the following categories:
In other words, all special advertising categories except politics, elections, and social issues. Restrictions apply to advertisers located in the United States or reaching U.S. audiences.
Share your customer list with a custom audience
New restrictions apply to the sharing of customer list custom audiences for these business categories. Consider two situations:
1. Shared between ad accounts within the same portfolio.
You can share your customer lists with other ad accounts within the same business portfolio (the new name for your business management platform) as long as everyone who has permission to manage the campaign has the same business email domain Customer Audiences.
No, this restriction cannot be bypassed using Gmail, Yahoo, and other common email domains.
It’s unclear if this is a complete list, but assume you’ll be using an email domain that proves you work for the same employer.
2. Sharing between advertising accounts of different business portfolios.
In this case, you will not be able to share your customer list custom audience regardless of the email domain. Both ad accounts must be in the same portfolio.
Meta provides the following example for ad accounts within the same portfolio…
The first column of email addresses represents all the people in the ad account who will share the Customer List Custom Audience with permission to manage campaigns. The last column represents those who will host that audience.
The first example is acceptable because everyone in both ad accounts has the same email domain. The second reason is not because the person in the shared account who has permission to manage campaigns uses the Gmail domain.
consumer reporting agency
Consumer reporting agencies (CRAs) may not use any customer list custom audiences (including their own audiences) for targeting. CRA collects and sells financial and credit information about people.
Yes, that would be bad in this case. Meta doesn’t want advertisers to discriminate, and these lists can be used to do that.
Additional certification
Starting in January 2025, advertisers will begin to see new certification requirements for custom audiences for customer lists.
Key points:
1. They are not a consumer reporting agency and do not receive information from consumer reporting agencies.
2. Audiences are not based on sensitive information that should not be used for targeting.
3. They will comply with Meta’s advertising policies.
Execution schedule
If you’re using Customer List Custom Audiences in these categories, here’s how to roll out an enforced schedule…
January 2025
New campaigns must use Customer List Custom Audiences that meet the above guidelines, or you may not be able to publish them. If you published campaigns before these new limits, they will continue to run, but you may not be able to edit them.
March 2025
Events posted prior to restrictions that do not follow these guidelines may be suspended.
Why does this happen?
Meta has faced a lot of pressure over the years for ads that touched on sensitive topics. This is why special ad categories exist in the first place.
Special ad category designations are intended to protect advertisers (and metas) by preventing them from using discriminatory targeting. Audience selection looks like this:
- Unable to select zip code
- A radius of at least 15 miles around a location
- 18-65+, no ability limit minimum or maximum age
- No ability to limit gender
- Removed some sensitive detailed targeting options
Because of these limitations, it’s not surprising that advertisers might try to get around them by using custom audiences. They can collect a list of people who belong to a specific age group or community. This would violate the terms of these special ad categories.
In fact, I’m surprised Meta didn’t simply remove the ability to use customer lists to customize audiences in this case. This will be much easier. But since they haven’t done so yet, they need to add more restrictions to ensure advertisers understand and follow the rules.
Regardless, custom audience sharing also falls into a gray area. I’ve long interpreted these rules to mean that you can only target people who have explicitly given you the right to contact them. In a way, if everyone interpreted it this way, these restrictions wouldn’t be necessary.
What should you do?
First, investigate whether this applies to you. Are you advertising for businesses that fall into the housing, employment, or financial products and services categories? Are you or the client based in the United States?
If so, check your alerts for warnings related to these limits. I’m assuming you’ll see them on the Audience page, but you might also see something on the Account Overview.
Next, do you share custom audiences of these businesses’ customer lists? If not, this isn’t really a problem.
Finally, consider whether all advertisers on your ad account are using the same email domain. They most likely don’t, as it’s certainly common for advertisers to use “generic” email domains like Gmail. You’ll need to correct this, which can be a bit cumbersome.
now you
Do you advertise for US businesses that fall into these categories? How are you preparing?
Let me know in the comments below!