[kuerbel]

In Germany, ads are not subject to prior government approval, as that would violate the constitution's prohibition of prior restraint. However, advertising is heavily regulated, especially in areas like medicine, gambling, and tobacco.

There is also industry self-regulation through bodies like the German Advertising Standards Council, which reviews complaints and can issue public reprimands.

So the system is not "you must get permission before speaking," but rather "you are free to publish, but you are accountable if you violate clear legal standards."

I’m also skeptical of pre-approval mechanisms in principle. I think the German mechanism works really well.

[Nursie]

In the UK there is also no prior government approval. Clearcast is a private company owned by the networks, who pass advertising through checks to ensure it meets their commitments and guidelines.

In theory they could still broadcast it if they wanted to, but in general if it fails their checks, they won't.

It's not so much permission as risk evaluation.