Guide
Influencer Marketing Basics
Brands
Three industries carry legal rules for influencer marketing in Denmark that go beyond the general ad-disclosure requirements: alcohol (an absolute ban on mentioning alcohol or energy drinks in content aimed at anyone under 18, regardless of whether the post is paid), finance (specific disclosure duties under the EU's Market Abuse Regulation when an influencer recommends a concrete investment), and pharma (a total ban on advertising prescription medicine to the public, on any channel). This article covers what applies in each industry, and who enforces it.
The general rule — that influencer content involving a commercial benefit must be marked as an ad — applies to every industry. But three industries carry their own, additional rules that go further: alcohol (an absolute ban on mentioning alcohol or energy drinks in content aimed at anyone under 18, whether the post is paid or not), finance (specific disclosure duties when an influencer recommends a concrete investment), and pharma (a total ban on advertising prescription medicine to the public — on any channel). Three different authorities enforce these rules, and they apply on top of, not instead of, the general ad-disclosure rules.
This is practical guidance from Make Influence, not legal advice. Use it to get an overview of which extra rules apply in each industry — get the specific legal assessment of your campaign from a lawyer, particularly if the campaign involves prescription medicine or investment products.
| Industry | Extra rule | Who enforces it | What it means for a campaign |
|---|---|---|---|
| Alcohol (and energy drinks) | Markedsføringsloven § 11(2) — ban on any mention aimed at anyone under 18 | Forbrugerombudsmanden (the Consumer Ombudsman) | The creator's actual audience age decides it — intent or paid status is irrelevant |
| Finance (investment recommendations) | The EU Market Abuse Regulation (MAR), Article 20(1) | Finanstilsynet (the Danish FSA) | A concrete buy/sell recommendation requires disclosing method and any conflicts of interest — whether the sender is a professional or not |
| Pharma | The Danish executive order on advertising for medicines | Laegemiddelstyrelsen (the Danish Medicines Agency); the industry itself also answers to ENLI | Prescription medicine can't be advertised to the public at all — not even through an influencer |
Markedsføringsloven (the Danish Marketing Practices Act) § 11(2) prohibits any mention, image or reference to alcohol in a commercial practice aimed at children and young people under 18. Per Forbrugerombudsmanden's own wording, the prohibition is a general rule that applies regardless of whether the specific marketing practice concerns selling alcohol or simply uses alcohol as a device — and it explicitly covers energy drinks too, a category the authorities discourage for children and young people. What matters is not whether the post is paid advertising or organic content: the ban covers both. A violation can be punished with a fine under § 37(3) of the same act.
Forbrugerombudsmanden sharply stepped up enforcement in autumn 2024. A press release dated 9 October 2024 states that the authority reported several influencers to the police for nine violations of the Marketing Practices Act — specifically for marketing alcohol or energy drinks to children and young people under 18. The case shows the rule is enforced in practice, not only on paper, and that Forbrugerombudsmanden actively monitors influencer content in this category.
The rule reaches further than most brands assume. It isn't only a ban on directly advertising an alcohol brand — it's a ban on any mention, any image and any reference, whenever the content is aimed at an audience under 18. A creator with a predominantly young following therefore can't lawfully show a beer or a cocktail in the background of a post, regardless of whether it's the brand's own product, and regardless of whether money is involved.
When a creator recommends a concrete purchase or sale of shares, cryptocurrency or another financial instrument, they fall under the EU's Market Abuse Regulation (MAR), Article 20(1), and its accompanying Delegated Regulation 2016/958 on investment recommendations. The rule applies to anyone who produces or disseminates an investment recommendation — not only licensed analysts. The requirement is that the information must be presented objectively, and that the sender's own interests or conflicts of interest in relation to the recommended instrument must be disclosed. This disclosure duty is separate from, and less strict than, the licensing requirement that applies once a recommendation becomes personal advice to one identified customer — see when does promoting an investment product cross into regulated financial advice for exactly where that second, more serious line sits.
Finanstilsynet has enforced the rule against ordinary private individuals, not only professionals. On 16 September 2022, Finanstilsynet issued a reprimand against a well-known figure in Danish investment circles who, in May 2022, posted "signals" on several stocks based on a momentum model in the Facebook group "Dansk Investor Netværk" (53,000 members) — without disclosing the calculation behind the model. According to Økonomisk Ugebrev's coverage of the case, the person was held to the same disclosure standard as a professional analyst despite being a private investor, and a disclaimer that the post "wasn't a call to trade" didn't change the fact that the investment-recommendation rules applied. In April 2026, Finanstilsynet issued a comparable reprimand against a professional analyst for failing to disclose their own shareholding in an internal memo that in substance amounted to an investment recommendation — Finanstilsynet stressed that neither the format nor the "internal memo" label exempts anyone from the disclosure duty.
Finanstilsynet also published a consumer-facing warning in June 2024 urging people to be critical of finfluencers' investment tips — its central point being that a finfluencer, unlike a licensed financial adviser, is under no obligation to act in the recipient's best interest. That's a consumer warning, not a separate legal obligation on the influencer beyond MAR Article 20 — but it shows the authority is actively watching the space.
Finans Danmark, the trade body for the Danish financial sector, presented a seven-point proposal on 9 March 2026 aimed at protecting young people from fraud and misleading financial advice on social media — grounded in the organisation's own research finding that, in its words, "four out of ten Danish investment influencers" give poor or outright misleading advice. The proposal includes a certification scheme for professional finfluencers, tighter oversight of non-professional actors, and platform obligations to remove misleading financial content. It's important to be precise about status: this is a proposal from a trade body, not enacted legislation. Until any legislation is passed, it's MAR Article 20 and the Marketing Practices Act's general ban on misleading marketing that apply.
Advertising for medicines is regulated by the Danish executive order on advertising for medicines, elaborated in the Danish Medicines Agency's (Laegemiddelstyrelsen) own guidance no. 9400 of 20 April 2022. The central distinction runs between prescription-only medicine and over-the-counter (OTC) medicine: advertising prescription medicine to the general public is prohibited — it may only be marketed to healthcare professionals. OTC medicine, by contrast, may be advertised to the public, but the advertisement must be balanced, must not be misleading or exaggerate the product's properties, and must be consistent with the product information the Danish Medicines Agency has approved. According to Ugeskriftet.dk, the Danish medical journal, the internet is treated on the same footing as print media in this context — meaning an influencer post about a prescription medicine is exactly as prohibited as a printed ad, and a post about an OTC medicine is subject to precisely the same content requirements as a TV commercial.
The pharmaceutical industry is also held to its own self-regulation through ENLI (Etisk Nævn for Lægemiddelindustrien, the Ethical Committee for the Pharmaceutical Industry), which enforces the industry's own advertising code for member companies' marketing, including collaborations with healthcare professionals and patient organisations. ENLI's rules are primarily directed at the member companies themselves, not directly at the influencer — but that means a pharma company considering an influencer collaboration generally has to weigh it against both the statutory regulation and the industry's own code.
For a brand, this means in practice: if the product is a prescription medicine, a consumer-facing influencer campaign isn't an option at all — no matter how carefully the content is worded, no matter the disclaimer, and regardless of whether the creator is themselves a healthcare professional. If the product is OTC medicine, an influencer campaign can go ahead, but the content has to meet the same balance and product-information requirements as any other advertisement for the medicine — which typically means the marketing copy and claims need sign-off from the responsible company's regulatory function, not only its marketing team, before a creator posts it.
The most common mistake in all three industries isn't knowingly breaking a rule — it's misclassifying the product, so the wrong rule gets applied from the start.
IF the product is alcohol or an energy drink → confirm the creator's actual audience demographics are 18+, and write it into the brief as a requirement, not an assumption.
IF the creator is going to mention a concrete financial product, a stock or a cryptocurrency with a buy or sell recommendation → build disclosure of method and any conflicts of interest into the content, whether or not the creator is a professional adviser.
IF the product is a medicine → confirm first whether it's prescription-only or OTC. If prescription-only, a consumer-facing influencer campaign is off the table. If OTC, the content needs sign-off from your regulatory function, not just marketing.
IF you're unsure about the product's classification in any of the three industries → get the classification confirmed before the campaign is planned, not after it's already live.
In our experience, the biggest risk in these three industries isn't a brand deliberately wanting to break the rules — it's that the rules never get checked, because the campaign otherwise looks like any other influencer campaign. We recommend treating an industry check as a fixed, early step in campaign planning — on the same footing as ad disclosure and the contract's terms — rather than something that only surfaces once an authority reacts. For alcohol and finance, in practice this mostly means knowing and documenting the creator's audience demographics and the content's actual claims before the contract is signed. For pharma, our clear recommendation is that regulatory sign-off on the content is locked in before any creator gets access to the brief.
Yes. What matters is who the content actually reaches and is aimed at — not the creator's own age. A creator with a meaningful share of followers under 18 is in the danger zone, regardless of the creator's own age.
Yes — general discussion and personal experience aren't themselves prohibited. What triggers MAR Article 20's disclosure requirement is when the discussion turns into a concrete recommendation to buy or sell a specific instrument — at that point, method and any conflicts of interest have to be disclosed.
Only if the product is actually presented or functions as a medicine — for example, with a claim to cure or prevent a specific disease. A supplement that sticks to legitimate supplement claims isn't covered by the pharma advertising rules, but the line is crossed more easily than most brands assume.
No. They apply on top of, not instead of, the general ad-disclosure rules. A post in one of these three industries can easily breach both rulebooks at once.
Yes, but only for OTC medicine aimed at consumers, and only with content approved to the same standard as any other advertisement for the product. Prescription medicine is excluded from consumer-facing influencer campaigns regardless of how carefully it's worded.
A separate, dedicated rulebook: the EU's Nutrition and Health Claims Regulation (1924/2006), which governs which health and nutrition claims may be used at all, regardless of any medicine-reclassification risk. See dietary supplements and influencer marketing: what Danish food-advertising law requires for that full regime, including a 2024 enforcement spot check that sanctioned 61% of the companies inspected.
Yes, on top of the general giveaway rules. See how to run an influencer giveaway or contest, legally for the spam ban and the Danish prize tax — both apply on top of the industry rules covered here if the prize itself is alcohol, a financial product or medicine.
Yes. See environmental and sustainability claims in influencer marketing: what Danish law requires for the separate documentation rules and the automatically-misleading claims that take effect on 27 September 2026 — an environmental claim about a product in one of these three industries has to satisfy both rulebooks at once.
No — it's one of four rules, and the narrowest one. A broader set of Section 11 rules covers dangerous-behaviour content, profiles belonging to under-15s, and using children under 15 in content more generally, plus a separate, stricter ban on directly urging a child to buy anything at all — not just alcohol. See marketing to children and teenagers through influencers: what Danish law actually requires for the full framework, including who besides the influencer can be held liable.
Yes — a separate EU regime, MiCA (the Markets in Crypto-Assets Regulation), sets its own marketing-communication requirements for a crypto-asset's issuer, on top of the personal-recommendation rules in MAR Article 20 covered above. See crypto and token promotions by influencers under MiCA: what changed from 1 July 2026 for how the two rulebooks differ and can both apply to the same post.
Yes, once the recommendation stops being public and becomes personal advice to one identified customer — for example, a paid one-to-one consultation or a subscription tailored to an individual's portfolio. See finfluencers in Denmark: when does promoting an investment product cross into regulated financial advice for exactly where that line sits and what triggers Finanstilsynet's investment-adviser licence.
Yes — a separate, self-regulatory layer on top of the statutory rule. Section 11(2) above bans alcohol content aimed at children and young people specifically. Alkoholreklamenævnet's own industry guidelines go further and apply to every alcohol advertisement regardless of audience age: anyone appearing in the marketing must be at least 25, and the guidelines explicitly name influencers as a category requiring extra care. See can a Danish influencer advertise alcohol? The Alkoholreklamenævnet rules explained for the full framework.
Not yet, and that's itself worth knowing: unlike the three industries above, Denmark's proposed tightening of the gambling-advertising rules for influencers and affiliates (Spilpakke 1) hasn't been passed into law. Gambling marketing already has its own regulator (Spillemyndigheden, not Forbrugerombudsmanden, Finanstilsynet or Laegemiddelstyrelsen) and its own current rules for affiliates and influencers — see Denmark's gambling advertising reform: what changes for influencers for what already applies today and what's still pending.
It's regulated even more strictly, which is why it has its own dedicated article rather than a section here: unlike alcohol, finance and pharma, 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 ban it outright too — with no conditional pathway of the kind that exists for alcohol or gambling on Meta's branded content tool. See can a Danish influencer promote tobacco or vapes? for the full picture, including a real enforcement case from June 2025.
Yes, if a specific nutrition or health claim is made about the food or drink itself — that's governed by a separate, dedicated regime (the EU's Nutrition and Health Claims Regulation), not the alcohol, finance or pharma rules above. See marketing food and restaurants through influencers: what Fødevarestyrelsen's claims rules require for what that separate regime bans, including for a restaurant dish specifically.
Yes, potentially a completely different rulebook: if a municipality or other public body is the one purchasing the campaign, Danish and EU public-procurement law can require the purchase to go to tender once its value crosses a threshold — regardless of which industry the campaign falls in. See does a Danish municipality have to tender an influencer campaign? for the thresholds and what applies below them.
Yes — a separate licensing question, distinct from the alcohol, finance and pharma rules above: promoting an insurance product through a personal discount code or affiliate link tied to commission per policy sold can require Finanstilsynet authorisation as an insurance intermediary, on top of the ordinary ad-disclosure rules. See when does promoting insurance require an influencer to hold an insurance intermediary licence? for exactly where that line sits.
Yes — another licensing question with its own, less settled line: promoting a specific property listing for commission can, in some cases, require approval as an ejendomsmægler or affiliation with an approved real estate mediation business, on top of the ordinary ad-disclosure rules. See does promoting a property listing for commission make an influencer an unlicensed real estate agent? for where that line likely sits, and what's still unresolved.
Yes — a more specific rule and real, dated cases. The executive order's own ban on using a person of "special esteem" in a medicine advertisement names influencers and bloggers explicitly, and two real Danish cases from 2024 and 2025 show weight-loss clinics and influencer marketing of Ozempic/Wegovy-based treatment programmes are under active scrutiny. See can an influencer legally promote weight-loss drugs like Ozempic or Wegovy in Denmark? for the full picture.
Yes, but with a materially different rule: unlike prescription medicine, a medical device isn't banned from consumer advertising at all — the EU's Medical Device Regulation (MDR) instead prohibits specific misleading claims, and, unusually, the marketing itself can help decide whether a product counts as a medical device in the first place. See advertising medical devices through influencers: what's different from the pharma rules for that separate regime, including why Lægemiddelstyrelsen enforces it too.
Yes, and it splits in two: Botox (botulinum toxin) is prescription medicine and falls under the same total ad ban as Ozempic and Wegovy, while hyaluronic-acid fillers are a Class III medical device where advertising is allowed but must be documented. See can an influencer legally promote Botox, fillers and other cosmetic procedures in Denmark? for the full picture, including the separate patient-safety registration and reflection-period rules that apply to both.
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