Can a Danish Influencer Advertise Alcohol? The Alkoholreklamenævnet Rules Explained

Yes — a Danish influencer can advertise alcohol, but only within a set of self-regulatory guidelines administered by Alkoholreklamenævnet (the Alcohol Advertising Board), which sit on top of Denmark's Marketing Practices Act. The guidelines require anyone who appears in alcohol marketing to be at least 25 years old, ban any link to children and young people, and explicitly name "influenter" (influencers) as a category of well-known people requiring particular care. If a business ignores the board's criticism, the case can end up with Forbrugerombudsmanden, Denmark's Consumer Ombudsman.

This is practical guidance from Make Influence, not legal advice. Use it to understand the framework for alcohol advertising in Denmark — get the specific legal assessment of your campaign from a lawyer.

What is Alkoholreklamenævnet, and why isn't it simply "the law"?

Alkoholreklamenævnet was established in 1999, when Denmark's Ministry of Business negotiated with a range of industry and consumer organisations over a set of guidelines for marketing alcohol. The current guidelines took effect on 1 November 2020, negotiated between Forbrugerrådet Tænk (the Danish Consumer Council), De Samvirkende Købmænd, Dansk Annoncørforening, Dansk Erhverv, Kreativitet & Kommunikation, HORESTA, the Danish Wine and Spirit Organisation (V.S.O.D.) and Bryggeriforeningen (the Danish brewers' association). Business and consumer interests are equally represented on the board, which is led by an independent chair.

Per the guidelines' own § 1, their purpose is to "fill out the legal standard for good marketing practice and good business practice for alcohol, cf. §§ 3 and 4 of the Marketing Practices Act" — the guidelines aren't standalone legislation, but the industry's own interpretation of what the law already requires. They describe themselves as "ethical minimum standards" and "responsible self-regulation." That doesn't change the fact that they apply to every business marketing alcohol in Denmark (§ 2(2)), or that Forbrugerombudsmanden and Alkoholreklamenævnet coordinate their case handling with each other.

The four rule sets that apply to any alcohol advertisement

What the guidelines actually say about "influenter"

Unlike § 11(2) of the Marketing Practices Act (which bans alcohol content aimed at children and young people under 18, covered in depth in influencer marketing in regulated industries), Alkoholreklamenævnet's own guidelines name influencers directly, in two places:

• § 2(2) (scope): the guidelines apply "regardless of whether the business itself, a subcontractor, influencers, consumers or others published the marketing." A business can't offload responsibility by letting an influencer create the actual content — liability follows the business, whoever posted it.
• § 6(4) (children and young people): alcohol advertising must "never show role models or use images, people, cartoons, animations, icons, influencers etc. that specifically appeal to children and young people." An influencer with a young, enthusiastic following can be problematic to use on that basis alone — independent of how the specific content is otherwise designed.

The guidelines' own explanatory notes to § 4 also place "bloggers" and "influencers" explicitly within the broad category of "well-known people" ("actors, musicians, sports stars, reality stars, bloggers, influencers, TV hosts, radio hosts, authors etc."), for whom § 4(4) requires "a particular degree of care." The more weight a person's statement or appearance carries because of their position or standing, the stricter the requirement — and if a campaign combines that with another violation of the guidelines, using a well-known person is treated as an aggravating circumstance.

The 25-year rule: who can actually appear in an alcohol advertisement?

§ 6(2) is short and non-negotiable: "Marketing of alcohol may only use persons, including models, actors and similar, who are at least 25 years old." The explanatory notes add that Alkoholreklamenævnet can ask for proof of age if there's any doubt, and that the reasoning is the board's own assessment that a person of at least 25 will appeal to children and young people less than a younger person would. The rule still applies even if the person is over 25: if they nonetheless particularly appeal to children and young people, using them is still a violation of the guidelines.

There's one exception: ordinary mood pictures of guests from parties and events, when the pictures themselves can't be considered marketing of alcohol. An influencer's ordinary story from a night out isn't automatically caught — but the moment the content actually functions as advertising for a specific product or brand, the 25-year requirement applies in full, whether the influencer themselves is 19 or 45.

For a brand, that means in practice: an influencer under 25 can't be the face of a paid alcohol campaign themselves — regardless of their follower base's age composition, and regardless of whether the influencer is shown drinking or simply present.

Two different "children and young people" tests — not one shared rulebook

It's easy to conflate Alkoholreklamenævnet's rules with § 11(2) of the Marketing Practices Act — but they're two separate rule sets, asking different questions and enforced by two different authorities:

The consequence for a brand: even a campaign that passes the § 11(2) test (because the influencer's follower base is genuinely 18+) can still draw criticism from Alkoholreklamenævnet if, for example, the people shown in the ad itself are under 25, or if the ad otherwise comes across as provocative or links alcohol to active sports participation. The two rule sets have to be checked separately, not as one combined requirement.

Alcohol-free products and "kids' beer": where the line sits

The guidelines generally apply to beverages above 0.5% alcohol by volume (§ 2(3)) — but for marketing aimed at children and young people, they apply to all alcoholic beverages regardless of ABV (§ 2(4)). The explanatory notes give a concrete example: it isn't permitted to market "kids' beer, kids' wine or similar" at 0.0% ABV to children if the product — including the product name — indicates it relates to alcoholic beverages. An alcohol-free variant of an ordinary beer or wine brand also can't be confused with, or marketed alongside, the alcoholic version (§ 2(5)).

Do the rules apply to a foreign influencer or a foreign brand?

The guidelines generally follow the effects principle: any marketing aimed at, or with an effect on, the Danish market is covered — regardless of whether the business is established in Denmark or abroad. There's an important exception for online marketing, though: if the business is established in another EU/EEA country, the country-of-origin principle applies instead, and Alkoholreklamenævnet's guidelines then don't apply — the business instead has to comply with the rules of its own country of establishment. For a Danish brand working with a foreign influencer on alcohol content aimed at Danish consumers, however, the guidelines apply in full, because it's the Danish business's own marketing being assessed.

How a complaint actually works, and what happens if the rules are broken

Complaining to Alkoholreklamenævnet is free and open to anyone — private individuals, businesses and organisations alike. A complaint must be submitted in writing (letter, email or online form) and must state which marketing activity the complaint concerns, where and when the marketing was seen (with a clear date), a copy of or link to the material, and the complainant's own contact details. The complaint has to concern current marketing, or marketing that took place within the past year. Case processing typically takes 1–3 months.

Alkoholreklamenævnet can reach one of three outcomes:

• Criticism — the board finds the marketing breaches the guidelines and expects immediate action (stopping or changing it). In particularly serious or repeated cases, the criticism is published via a press release.
• Noted — a breach is found, but the respondent has already stopped or sufficiently changed the marketing before the case is decided.
• No criticism (dismissal) — the board finds the marketing doesn't breach the guidelines and publishes a reasoned decision explaining why.

Every decision is published on Alkoholreklamenaevnet.dk. If a business doesn't follow up on a criticism, the board can refer the case to Forbrugerombudsmanden. For cases specifically concerning § 6 (children and young people), that isn't just an option: under the case-handling agreement between the two authorities, Alkoholreklamenævnet must forward those cases to Forbrugerombudsmanden for potential further action under the Marketing Practices Act — where a violation can ultimately trigger a fine under § 37(3).

Decision framework: how to check an alcohol campaign before it goes live

IF an influencer is going to appear in the content themselves (drinking, holding the product, talking about it on camera) → confirm they're at least 25, and keep documentation if age is in any doubt.

IF a meaningful share of the follower base is under 18 → stop the campaign. That's true both under § 11(2) of the Marketing Practices Act, and because the content could genuinely be assessed as aimed at an audience that's primarily children and young people.

IF the campaign involves sport, an educational institution or potentially risky behaviour (e.g. driving) → alcohol can't be linked to any of them, regardless of context.

IF the product is alcohol-free (0.0%) → check whether the name or packaging still signals a connection to an alcoholic line, particularly if the target audience includes young people.

IF the influencer or brand is established in another EU/EEA country and the campaign runs online only → work out whether the country-of-origin principle means Alkoholreklamenævnet's guidelines don't apply at all — but remember § 11(2) of the Marketing Practices Act can still apply if the campaign genuinely targets Danish consumers.

Hypothetical example: why the influencer's own age isn't enough

The figures and names in this example are made up, used purely to illustrate the point. A brewery signs a 28-year-old influencer for a campaign promoting a new beer brand. The influencer's follower base skews 25–40 — the campaign clears the § 11(2) test without issue. But the videos also feature two of the influencer's friends, both 22, drinking alongside them on camera. Because § 6(2) requires that every person appearing in the ad is at least 25 — not just the lead — the campaign breaches the guidelines, even though the audience's age is a non-issue. Had the brewery checked the age of everyone appearing on camera, not just the influencer themselves, the violation would have been avoidable without changing the campaign's core message at all.

Make Influence's operational perspective

In our experience, the most common mistake in an alcohol campaign isn't a brand deliberately breaking the rules — it's checking only the influencer's own age and follower base, and missing that the 25-year requirement applies to everyone who appears in the content, and that the guidelines explicitly name influencers as a category requiring extra care because of the weight their endorsement carries. We recommend making an age check of everyone appearing on camera a fixed line item in the brief, alongside the other requirements in what to put in an influencer contract — written in as a specific requirement, not an assumption the brand takes for granted.

FAQ

Does the influencer have to actually drink alcohol in the content for the rules to apply?

No. The rules apply to alcohol marketing as such — regardless of whether the people in the content actually consume the product, or simply show, hold or talk about it. What matters is whether the content functions as advertising for an alcoholic product.

Does the 25-year rule also apply to people who just appear in the background of a video?

The guidelines don't explicitly distinguish between a lead and a background role — the requirement covers people used in the marketing. The safe approach is to treat every identifiable person in the finished content as if the requirement applies, unless the footage can be documented as an ordinary mood shot with no advertising purpose.

Can Alkoholreklamenævnet issue a fine?

No. The board can issue and publish criticism, but has no independent fining power of its own. A fine only comes into play if the case is referred to Forbrugerombudsmanden, and that authority subsequently finds the Marketing Practices Act — for example § 11(2) — has been breached.

Is alcohol influencer marketing banned if the follower base is 100% adult?

Not by itself — but that doesn't exempt a campaign from the other requirements. The people appearing in the ad still have to be at least 25, the content still can't encourage excessive consumption or be linked to sport, driving or educational institutions, and it still can't come across as intrusive or provocative.

How is this different from the alcohol section in the regulated industries article?

That article covers § 11(2) of the Marketing Practices Act — the statutory ban on alcohol content aimed at children and young people under 18, enforced by Forbrugerombudsmanden. This article covers Alkoholreklamenævnet's own, broader self-regulatory rules, which apply to all alcohol advertising regardless of the audience's age — including the 25-year requirement for anyone appearing in it, and the explicit rules about influencers. The two rule sets apply on top of each other, not instead of each other.

Can a brand avoid responsibility by letting the influencer handle all the creative content themselves?

No. The guidelines' § 2(2) explicitly states they apply regardless of whether the business itself, a subcontractor, influencers, consumers or others published the marketing. Liability follows the business behind the product, not just whoever specifically posted the content.

Does this alcohol rule have anything to do with gambling advertising rules for influencers?

Not directly — they're separate regulatory areas, each with its own regulator. But the two rules follow a similar pattern: Denmark's proposed gambling-advertising reform, Spilpakke 1, would introduce the same 25-year minimum age for anyone appearing in a gambling ad that Alkoholreklamenævnet's guidelines already require for alcohol. See Denmark's gambling advertising reform: what changes for influencers for the gambling-specific rules, including which parts are already in force and which are still just a political agreement.

Is tobacco advertising regulated the same way as alcohol?

No — tobacco is regulated far more strictly. Alcohol advertising is permitted by default within Alkoholreklamenævnet's guidelines (the 25-year rule, no link to children and young people); tobacco and e-cigarette advertising is banned by default under the Tobacco Advertising Act, with only a few narrow exceptions, and Meta, TikTok and Google's own ad policies prohibit it outright too. See can a Danish influencer promote tobacco or vapes? Danish law and platform policy both say no for the full comparison.

Sources and further reading

This article is built on Alkoholreklamenævnet's own guidelines for marketing alcohol (in effect from 1 November 2020, with their accompanying explanatory notes), and on Alkoholreklamenaevnet.dk's own pages about filing a complaint and case handling. See influencer marketing in regulated industries: alcohol, finance and pharma in Denmark for § 11(2) of the Marketing Practices Act, and marketing to children and teenagers through influencers for the full § 11 framework and who besides the influencer can be held liable. See also influencer marketing disclosure rules for the general ad-disclosure duty that applies on top of everything covered here.