Thinking of launching a commerce media network? Three questions to answer first
Will Ryanair be launching a media network soon? I wouldn't bet against it.
Every few weeks, another business that isn't a retailer announces a media network. In the space of a few weeks in autumn 2026, McDonald's, Delta Air Lines, Citi and the shopping centre owner Simon all made moves.
If you lead one of those businesses, whether a loyalty programme, a shopping centre, a foodservice company, a bank or a travel brand, the interesting question isn't what everyone else is doing. It's what you have that someone else would pay to access.
I've spent much of my career inside retail. At Tesco and Sainsbury's, I saw retail media take shape at the forefront of the industry. Then at Delivery Hero, I helped build a retail media business that didn't fit the grocery model. We were small in each market and had to win brands over with something other than scale, which is exactly where most new commerce media networks are today. The principles travelled. The playbook didn't.
Now I'm seeing organisations well outside retail ask the same fundamental questions. Before you buy any technology, I'd answer three of them. Alongside each, I'll share how we answered it at Delivery Hero.
What is commerce media?
Commerce media is advertising sold by a business that isn't a media company, using its own customer relationship: its data, its channels and the moments when customers deal with it.
It grew out of retail media. Modern retail media is usually traced back to Amazon's advertising; its ad platform launched in 2012. The breakthrough wasn't that retailers discovered advertising. It was the combination of first-party customer data, digital scale and the ability to link an ad to a sale.
Fourteen years on, retail media is a nearly $200bn global advertising market, according to WARC, across hundreds of networks. Commerce media applies the same idea beyond retail: a bank selling access to its cardholders, an airline to its passengers, a shopping centre to its visitors.
The label is still settling. Commerce, after all, is simply the buying and selling of goods and services, so almost any organisation with customers could qualify. That's partly the point. The useful question isn't what to call it, but what you have that someone else would pay for.
Who's doing it and what each business says it brings
The pioneers have been at this for years. What's changed in 2026 is the pace, and the range of sectors. The examples below aren't an exhaustive list. Every one of them has ad space to sell. What sets them apart is what sits around it, based on what each has said publicly:
Business | Sector | Customer data | Attention | Context | Trust |
Quick-service restaurants | ✓ | ✓ | ✓ | ||
Banking | ✓ | ✓ | |||
Shopping centres | ✓ | ✓ | ✓ | ||
Shopping centres | ✓ | ✓ | |||
Airline | ✓ | ✓ | ✓ | ||
Banking | ✓ | ✓ | |||
Meal kits | ✓ | ✓ | ✓ | ||
Discounts for frontline workers | ✓ | ✓ |
Indicative only, based on publicly stated propositions; this is not an assessment of the quality or scale of each asset.
The banks lead with spending data and trust. The airline and the shopping centres lead with attention and context. Same idea, very different propositions.
In my own work, I'm now having two or three commercial conversations a week with non-retail organisations exploring their own version of this: loyalty apps, shopping centre landlords, B2B foodservice, pharma.
Start with the customer, not the media network

Before anything else, step back to how your customers see you. Nobody thinks, "I'm going to interact with a media network today." They think:
I'm going on holiday.
I'm doing up my house.
I'm looking after my dog.
I'm going to university.
I'm commuting.
I'm sorting out my finances.
Different businesses sit inside those missions. An airline owns part of the holiday. A bank sees the whole of the finances. A shopping centre hosts the Saturday afternoon.
That's what makes a non-retailer interesting to a brand. You're present at a moment when a customer has a clear need, and often when they're paying attention. The mission tells you which brands would want to be there, and why.
The mission is the starting point. The media network is the monetisation layer.
And the question I now help organisations answer through Carroll Commerce: what is the commercial value of the customer relationship you already have?
![Navy graphic headed "[The key questions to ask if you're considering starting a commerce media network]". Three cards side by side: Proposition, "What do you have that someone else would pay to access?"; Proof, "How will you prove its value, and know what to charge?"; Operating model, "How will you deliver it, and make it easy to buy?" Carroll Commerce logo bottom right.](https://framerusercontent.com/images/tjoKvrr3rwjADe0j7ZzSB2os.png?width=1200&height=630)
Question 1: Proposition
What do you have that someone else would pay to access?
Start by being honest about what makes your customer relationship valuable to someone else. It's usually some combination of:
Customer data: who your customers are and what they do, which brands can't see anywhere else.
Attention: time customers spend with you, on a seatback screen, in an app, in a shopping centre.
Trust: a relationship that makes a recommendation from you land differently.
Context: the mission a customer is on when they're with you.
Inventory: physical or digital space where a brand can appear.
Most businesses have some of these. Few have all of them, and that's fine. The work is to be honest about which are genuinely distinctive, then build a proposition around those, not around an inventory list.
From the operator's seat
When I joined Delivery Hero in 2021, quick commerce was still a relatively small and emerging part of the global e-commerce market. It represented a tiny fraction of the big FMCG players' e-commerce revenue, and that made it hard to get the attention of big brands.
The assortment was narrow at first, weighted towards drinks and snacks. So we leant into that. Many of our early partnerships were with Unilever, Nestlé, Mars, Coca-Cola and PepsiCo.
What got us in the door wasn't size. It was a business growing fast, an enormous amount of data, access to the convenience shopper, a 24-hour service, closed-loop measurement because everything was online, and global scale.
Over time, the proposition evolved. As the assortment broadened, especially into fresh and non-food categories, customers started using us for top-up shops, dinner tonight and gifts. Having worked at Tesco and Sainsbury's, I knew grocery customers shop on many different missions, not just a big weekly shop. But we didn't copy the grocers' model, because that isn't how people used Delivery Hero's apps. We built around the missions our customers actually had.
Question 2: Proof
How will you prove its value, and know what to charge?
Measurement was one of the things that helped turn retail media from shopper marketing into a growth business. Brands paid more because they could see what they got. Many new networks lead with it too: both Citi and Simon promise closed-loop measurement in their launch announcements.
For non-retailers, it's harder. A retailer sees the sale. A shopping centre, an airline or a loyalty app often sees part of the journey, but not the purchase itself. So the first decision is what you're selling:
Reach, awareness and consideration: you need to show who you reached and what it did for the brand over time.
Sales: you need to link the media to purchases, which may mean data partnerships with the businesses that see the transaction.
Either way, you need to decide this before you set a price. Measurement tells you what your media is worth. Without it, you're pricing by guesswork, and brands will pay accordingly.
Retail media hasn't fully cracked this either, especially for in-store media. That's an opportunity for new networks that build measurement in from the start.
From the operator's seat
At Delivery Hero, we started closest to the sale: sponsored products in search and category pages, priced per click. We aimed for a return on ad spend of 2–4x, varying a little by category. In alcohol and beauty, where items cost more, it was higher.
When the average dipped, we dug into campaigns to improve performance. When returns ran at 6–10x, well above our range, we didn't raise click prices, as some retailers might. We told our sales teams this was the moment for brands to get in, while competition was low. As more brands came on board and bid, the yield rose on its own.
Display taught us a different lesson. Some tenancy banners had been sold as fixed placements. When we worked back the cost per thousand impressions, many were astronomically expensive. Nobody could see it without transparent reporting, and that doesn't last once advertisers ask for results. We introduced new display formats with CPM pricing and real-time reporting, at rates in line with premium digital display. Not as cheap as Meta or Google, because you're reaching a customer while they're in the market to buy (a high-value moment).
Measurement wasn't only for proving value to advertisers. It was how we managed pricing and demand.
If you can't see the sale, the display lesson is the one to take. Price in a metric advertisers recognise, report it transparently, and your rates will stand up when they ask for results.
Question 3: Operating model
How will you deliver it, and make it easy to buy?
This is where many businesses jump straight to technology. But the tech is the enabler. It isn't the business. The harder questions are about people and structure:
Ownership: who runs it, and where does it sit? A media business inside a bank or an airline needs a clear owner and its own P&L, or it stays a side project.
Talent: you need people who understand media, data and your core business at the same time.
Internal alignment: media touches customer experience, data, brand and commercial teams. Each has a reason to say no.
Customer experience: how much advertising can you add before it damages the relationship you're selling?
Then there's how you sell. Brands and agencies are already being pitched by hundreds of networks, and they don't have time to learn each one. WARC found that none of eight of the UK's largest retail media networks gets even a third of its revenue from the long tail of smaller advertisers. If established networks struggle to reach beyond their core buyers, a new one will find it harder.
So decide early how brands will buy from you: a direct sales team, programmatic access, agency relationships, or partnerships with other networks. The hard-to-buy networks get left out of the plan.
From the operator's seat
At Delivery Hero, we chose a hybrid model: a programmatic ad platform, plus dedicated media sales roles working closely with our commercial buyers. Over time, those roles grew into teams.
Brands could buy through a managed service, which at first cost nothing on top of the media, or self-serve, with no platform fee. Both were deliberate choices to remove friction and get brands buying. Even on self-serve, our biggest clients had ad operations and account managers alongside them.
Later, we added partnerships with media agencies and off-platform players such as The Trade Desk. The principle was simple: make it easy to start buying, then build the commercial model around how demand actually grows.
Same questions, different answers
Proposition, proof and operating model are the same questions retail media had to answer. The answers won't be the same. A bank's data isn't a grocer's. An airline's attention isn't a website's. A shopping centre can't see the sale.
That's why copying the retail media playbook rarely works. Answer the three questions for your own business first, then choose the technology that fits.
Carroll Commerce helps organisations build retail and commerce media as a business, not a project. If you're exploring what your customer relationship could be worth, that's the conversation I help businesses have. Get in touch with Tara Carroll.
FAQs - Building a Commerce Media Network
What is the difference between retail media and commerce media?
Retail media is advertising sold by a retailer, using its customer data and its own channels: website, app and stores. Commerce media applies the same idea to businesses that aren't retailers, such as banks, airlines, shopping centres, restaurants and loyalty programmes. The principles are shared: first-party data, owned channels and measurable outcomes. But the proposition and the measurement usually look very different, because most non-retailers don't see the sale the way a retailer does.
What does a business need before launching a commerce media network?
Three things: a customer relationship that brands would pay to access, a credible way to prove the value of advertising against it, and an operating model to sell and deliver it. In practice, that means identifiable customers, a clear moment or mission in which you reach them, and an owner with a mandate to run it as a business. Technology comes after those decisions, not before.
How can a commerce media network measure results if it doesn't see the sale?
There are three main routes. Partner with businesses that do see the transaction, such as a payments provider or a retailer, through data partnerships or clean rooms. Measure what you can see directly, such as visits or engagement. Or work with an independent measurement specialist on brand lift research. HelloFresh, for example, works with Kantar and Ipsos to track awareness, consideration and purchase intent directly, because most of the value it creates for brands sits before any purchase it could track. Many networks combine these routes. Either way, price in a metric advertisers recognise and report it transparently, so your rates stand up when brands ask for results.
![Yellow card with a large navy number 3 beside the words "[Commerce media questions to answer first]". Carroll Commerce logo in the corner.](https://framerusercontent.com/images/wN0wXK6Pb4Ln2fIJwUaORoQMZ8M.png?width=1200&height=630)