How does the Gmail Verified Sender Program Pilot work for political campaigns?

Key findings

• FEC Approval: The program received an advisory opinion from the FEC, allowing Google to proceed with the pilot without being seen as making an illegal in-kind contribution to campaigns.
• Direct Inbox Delivery: Participating political campaign emails were intended to bypass standard spam filters and land directly in the primary inbox of Gmail users.
• User Control: Despite bypassing filters, users would see a banner on the first message from a pilot participant's domain, prompting them to opt-in, unsubscribe, or report as spam. If a user reported an email as spam, all future messages from that sender would be sent to the spam folder.
• Associated Domain Suspension: A key policy stated that if one domain under an FEC Committee participant violated program policies, all other domains associated with that FEC Committee would be suspended for a week, after which they could reapply. This was designed to prevent campaigns from using multiple domains to evade accountability.

Key considerations

• High Bar for Entry: The eligibility requirements for the pilot were stringent, limiting the number of campaigns that could realistically participate. This included being actively registered with the U.S. Federal Election Commission (FEC) during the 2022 U.S. elections.
• Limited Scope and Duration: The pilot was specifically for political campaigns and had a defined end date, meaning it was not a long-term solution for all email senders.
• User Opt-in/Out Impact: While emails bypassed spam filters initially, the mandatory user prompt meant deliverability still hinged on recipient engagement and explicit consent. This shifted the responsibility of inbox placement to user choice, rather than entirely on Google's filtering algorithms. For more on this, see our article on how Google's political email approach impacts spam filtering.
• Transparency: There was a strong desire within the email community for Google to be transparent with the data collected from the pilot program, to better understand its effectiveness and implications for future email deliverability policies. The FEC approval process for this pilot highlighted specific legal and technical considerations.
• Deliverability Challenges for Political Campaigns: The pilot underscored the ongoing struggles political campaigns face in reaching the inbox, often due to high volume, inconsistent sending practices, and recipient complaints. Understanding why political campaign emails go to spam remains critical.

Key opinions

• Initial Misinterpretations: Many in the press initially misunderstood the program's mechanics, leading to unnecessary concern among marketers. The details of the pilot revealed a more nuanced approach than simply bypassing spam filters entirely.
• User Opt-in/Out Criticality: The mandatory banner prompting users to opt-in or unsubscribe was seen as a significant hurdle, meaning campaigns still needed strong engagement to maintain inbox placement. This mechanism reinforces the importance of rebuilding sender reputation through engagement.
• Program Effectiveness Skepticism: Some marketers doubted that the program would attract many applicants, particularly those who truly struggled with deliverability, as the requirements were quite demanding. There was a feeling that campaigns with good practices already didn't need it, and those with poor practices wouldn't qualify or benefit.
• Linked Domain Accountability: The policy linking all domains under a single FEC Committee for suspension was generally viewed positively, as it prevented campaigns from isolating bad sending practices to separate domains.

Key considerations

• Compliance Focus: Marketers noted that the pilot emphasized strict compliance with disclosure rules and prohibitions against impersonation or misrepresentation, aligning with broader email best practices and Google's bulk sender guidelines.
• Short-Term Solution: The program's limited timeframe through 2023 meant it was not a permanent fix, but rather an experiment to gauge the impact of different filtering approaches for political emails.
• Alternative Solutions: Despite the pilot, marketers continued to focus on fundamental deliverability strategies, such as list hygiene and strong engagement, which are universally beneficial for inbox placement, regardless of political affiliation.
• Unsubscribe Experience: The pilot highlighted the importance of a clear and accessible unsubscribe option, reinforcing Google's broader push for user-friendly unsubscribe mechanisms.

Key opinions

• Crafty Design: Experts noted the pilot's crafty design by Google, suggesting that it was a well-thought-out response to political pressures rather than a simple 'spam bypass' mechanism. It cleverly shifted the burden of inbox placement to user choice.
• Lack of Third-Party Reporting: A key concern was the absence of a clear mechanism for non-recipients or third parties to report breaches of pilot terms, such as the sharing of private information or inciting harm. Google typically does not accept such reports from third parties, which could limit external oversight.
• Ambiguity in Terms: Some terms, such as inciting harm, were considered subjective and potentially open to interpretation, raising questions about consistent enforcement.
• Monitoring Expectations: It was assumed that Google would actively monitor all mail coming into the pilot, despite the lack of a specific third-party reporting channel, to ensure compliance with the program's policies. This relies heavily on internal Google mechanisms.

Key considerations

• Domain Association: The strict policy that links all domains under a single FEC ID for suspension purposes was recognized as a powerful deterrent against bad sending practices. This reinforces the importance of maintaining a solid domain reputation.
• User Feedback Mechanism: The primary complaint mechanism remained the user's ability to report an email as spam via the opt-out banner. This direct user feedback loop directly impacts future deliverability, emphasizing the role of user engagement and satisfaction.
• Scope of Terms: The pilot's terms were specifically tailored to mail sent to Google, meaning compliance with these terms did not necessarily translate to improved deliverability across other inbox providers. This highlights the complexity of multi-platform email deliverability strategies.

Key findings

• Eligibility: The pilot was open exclusively to certain political committees actively registered with the U.S. Federal Election Commission (FEC) during the 2022 U.S. elections.
• First Message Banner: For the first message a user read from a pilot participant's domain in the official Gmail app/client, a banner would be displayed. This banner would prompt users to either continue receiving emails or unsubscribe (with an option to report as spam).
• Compliance Requirements: Emails had to contain clear disclosures identifying the responsible committee and the recipient of the solicitation. Recurring donations needed explicit communication to donors.
• Prohibition on Misrepresentation: The policies strictly forbade impersonation of any person, campaign, or organization, and prohibited omitting material information about sender identity or affiliations. Sending emails on behalf of unauthorized committees was also forbidden.

Key considerations

• Accountability Across Domains: The documentation explicitly stated that if any domain participating under a specific FEC Committee violated policies, all other domains under that same Committee would be suspended for a week. This meant a single violation could impact an entire campaign's email operations through Gmail.
• User-Initiated Spam Reporting: While emails bypassed initial spam filters, a user's decision to report an email as spam via the banner would result in all future mail from that sender going to the spam folder. This mechanism effectively allowed users to override the pilot's direct-to-inbox privilege. This aligns with broader Google policies on how emails are filtered to spam.
• Information Security: Policies included prohibitions against distributing personal or confidential information, such as Social Security numbers, bank accounts, or sensitive health documents. This emphasized a commitment to recipient privacy and security within the program.
• Limited Scope: The documentation clarified that the pilot was a temporary program for the 2022 U.S. elections and was not a permanent change to Google's general spam filtering policies. For more on Gmail's broader filtering changes, see our article on why campaigns are filtered to social or promotions tabs.