Lunar's Referral Bonus and Affiliate Program: Why a Bank Account Isn't Finfluencer Regulation

Short answer

Lunar is a Danish mobile bank with its own banking licence from Finanstilsynet, and it runs two entirely separate arrangements for outside content creators: a confirmed, open affiliate program via the network Adtraction (Denmark, "Opened" status, 30-day cookie), and a separate customer-to-customer referral bonus ("invite a friend"). Neither one triggers Denmark's finfluencer rules — not the disclosure duty under Article 20 of the Market Abuse Regulation (MAR), nor the requirement to hold Finanstilsynet's licence as an investment adviser — because an ordinary payment account isn't a financial instrument. That line only moves if the content instead promotes Lunar's separate stock-trading feature, Lunar Invest.

What Lunar is, and why it's relevant to the finfluencer rules at all

Lunar is a Danish mobile bank, founded in Aarhus in 2015 by Ken Villum Klausen. The company started as the payment app Lunar Way, without its own banking licence, but received Finanstilsynet's licence to operate as a bank on 19 August 2019 and became Lunar Bank A/S — the same supervisory authority that enforces MAR Article 20 and issues licences to investment advisers, as covered in the Academy's article on finfluencers in Denmark. Precisely because Lunar is a bank under the same supervision, it's a useful concrete example for showing where the finfluencer rules' line actually sits: is mentioning a bank account the same as recommending an investment? The answer depends on which part of Lunar's product range is actually being promoted.

Two separate arrangements for an outside content creator

Research of Lunar's own channels and the independent directory affi.io (30 August 2026) confirms two structurally different arrangements, neither dependent on the other:

A separate, older Adtraction listing under the name "Lunar - Kreditkort og Online Bank App" via the network Adservice is marked "Closed", with a 60-day cookie and a note stating it paid "per approved Business application and private sign-up" — a historical confirmation that the program has previously paid per concrete action, even though the specific rate isn't disclosed there either. A comparable Swedish Adtraction listing is also marked "Closed". The current, open Danish program is therefore the only confirmed active affiliate route in this research.

The reason for keeping the two arrangements separate is the same one the Academy has already documented for GoMore and Too Good To Go: a referral bonus between two individuals isn't the same thing as an affiliate program, even though both involve a personal link and some form of reward. See open vs application-only affiliate programs for the general distinction. Lunar's case is a clearer positive variant than GoMore/Too Good To Go's, though: here a genuine, open affiliate program is actually confirmed alongside the referral scheme, not only the latter.

Why neither the affiliate program nor the referral bonus triggers the finfluencer rules

As the Academy's finfluencer article covers, what decides whether MAR Article 20 or the investment-adviser licensing requirement applies is whether a recommendation concerns a financial instrument — stocks, bonds, fund units, crypto-assets under MiCA and similar. An ordinary payment account, a payment card or an overdraft facility isn't a financial instrument in that sense — it's a payment product regulated under an entirely different set of rules (including the Danish Payment Accounts Act and PSD2), not the Market Abuse Regulation.

Concretely, that means: a creator who makes content about opening a free Lunar account, sharing their personal referral link, or promoting Lunar's affiliate program to other publishers isn't recommending a transaction in a financial instrument. Neither MAR Article 20's disclosure duty nor Finanstilsynet's investment-advice licensing requirement applies to that kind of content. The ordinary advertising-disclosure rule under Section 6(4) of the Danish Marketing Practices Act still applies, exactly as it would for any other paid or commission-based collaboration — see influencer marketing disclosure rules in Denmark and the EU — but that's the general rule for any commercial relationship, not a finfluencer-specific one.

The line moves at Lunar Invest

Lunar also offers a separate investment feature, Lunar Invest, where the customer gets an investment account at Saxo Bank — a company with its own, full licence to trade securities — accessed through Lunar's app, with a commission of 19 kr for trades up to 50,000 kr and 0.1% above that, plus a 0.5% currency surcharge for securities not traded in Danish kroner, according to Lunar's own pricing page. This is exactly where the line from the finfluencer article becomes relevant: a creator making content about opening a free Lunar account isn't caught by MAR Article 20 — but a creator who makes a concrete recommendation to buy or sell a specific stock or ETF via Lunar Invest is making an investment recommendation in exactly the same way as if the recommendation had been made through any other trading platform. The account and the investment feature are two different products inside the same app, and it's the concrete subject of the content — not the app's name — that decides which rulebook applies.

Decision framework

IF the content is about opening a free Lunar account, sharing a personal referral link, or signing up to Lunar's affiliate program as a publisher → ordinary advertising disclosure applies, but neither MAR Article 20 nor the investment-adviser licensing requirement does.

IF the content recommends a specific stock, ETF or other financial instrument through Lunar Invest → treat it like any other finfluencer content, and see the full walkthrough in the Academy's finfluencer article for when it also requires Finanstilsynet's licence.

IF you're considering Lunar's referral link as a revenue source rather than actual affiliate sign-up → remember the amount is flat, not percentage-based, and the Danish figure couldn't be confirmed directly on Lunar's own page in this research — confirm the current amount inside the app before building content or an expectation around it.

IF you're a brand considering a similar dual setup (both an open affiliate sign-up and a separate customer referral) → see open vs application-only affiliate programs for how the two models differ structurally, and why they can run side by side without conflict.

Worked example (hypothetical)

The figures below are hypothetical and for illustration only — they are not a Make Influence customer case, and they deliberately use a made-up commission rate, since the Adtraction listing's own rate isn't published.

Assume a Danish creator with 30,000 followers runs both channels at once over one month. Through the open Adtraction affiliate program, the creator generates 40 approved account sign-ups; assume hypothetically a commission of 75 kr per approved private sign-up (an invented, unconfirmed figure, for illustration only): 40 × 75 kr = 3,000 kr, paid on an ongoing basis as new sign-ups are approved and tracked through the network's 30-day cookie. Through their own personal referral link, the same creator invites 5 friends, the maximum under a comparable rule for the Norwegian version of the program; if the same assumption (200 kr/friend) applied in Denmark, that would yield 5 × 200 kr = 1,000 kr, paid as a one-off sum with a cap that can't scale further, regardless of how many followers the creator has. The two amounts aren't comparable in scalability: the affiliate commission grows in principle with however many approved sign-ups the creator drives, while the referral bonus is fixed by Lunar's own limit on the number of friends.

Common mistakes

• Assuming Lunar's referral bonus and Lunar's affiliate program are the same thing. They differ in access, tracking and scalability, and only the affiliate program is confirmed open to external publishers.
• Assuming any Lunar content is automatically finfluencer-regulated because Lunar is a bank. That's only true if the content concretely recommends a financial instrument through Lunar Invest — not for an account, a card or a referral link.
• Copying the Danish referral amount from a third-party site without confirming the current figure directly inside Lunar's own app, the same way the Danish GoMore amount also couldn't be confirmed directly.
• Forgetting the ordinary advertising-disclosure rule because the finfluencer rules don't apply — both arrangements are still a commercial relationship that must be disclosed as advertising under Section 6(4) of the Marketing Practices Act.

Make Influence's perspective

Make Influence doesn't have a documented customer case with Lunar and doesn't run any campaign or affiliate arrangement with the bank. Our experience reviewing this kind of financial brand for the Academy series is that "it's a bank" is often misread as "so the finfluencer rules automatically apply" — but the rules attach to what's concretely recommended, not to which industry the promoted company sits in. A bank account is a payment product; a stock recommendation is a financial instrument. Our clear recommendation to a brand or a creator unsure which category a specific piece of content falls into is to ask the question concretely — "does this content recommend a transaction in a financial instrument, or is it talking about a payment account?" — rather than letting the company's industry decide the answer.

FAQ

Does a creator need to disclose content about Lunar's referral bonus as advertising?

Yes, if there's a commercial benefit involved (e.g. the creator themselves receives a bonus for the referral) — the ordinary advertising-disclosure rule under Section 6(4) of the Marketing Practices Act applies, regardless of whether the finfluencer rules apply. See influencer marketing disclosure rules in Denmark and the EU.

Does Lunar have a real affiliate program, or only a referral bonus?

Both, confirmed separately in this research: an open affiliate program via Adtraction for Denmark (status "Opened", 30-day cookie), and separately a customer-to-customer "invite a friend" bonus inside the app.

How much can you earn from Lunar's Danish referral bonus?

This couldn't be confirmed directly on Lunar's own current page in this research — only via third-party sites and one stale search result citing 250 kr per referral with a cap of 5 friends within 3 months. Confirm the current amount directly inside the app before building content around it.

Does MAR Article 20 or Finanstilsynet's licensing requirement apply if I promote my Lunar account?

No — a payment account isn't a financial instrument. See the Academy's finfluencer article for when the line is actually crossed.

What is Lunar Invest, and why is it relevant here?

It's Lunar's separate stock-trading feature, giving access to an investment account at Saxo Bank through Lunar's own app. It's the part of Lunar's product range where a concrete buy or sell recommendation would trigger the same finfluencer rules as on any other trading platform.

Is Lunar's referral bonus the same as GoMore's or Too Good To Go's?

Structurally, yes — both are a flat, one-off bonus between two existing users with no application. The difference is that Lunar also has a separate, confirmed open affiliate program alongside it, which neither GoMore nor Too Good To Go has shown any sign of. See GoMore and Too Good To Go: why a referral bonus isn't an affiliate commission.

Can a referral bonus and an affiliate commission both trigger on the same customer?

That's a related but separate question — see what happens when a loyalty or referral program and an influencer's commission both trigger on the same sale for the concrete collision points.

When did Lunar receive its banking licence?

19 August 2019, from Finanstilsynet — the same authority that enforces MAR Article 20 and issues licences to investment advisers. Lunar was founded in Aarhus in 2015 by Ken Villum Klausen, originally as the payment app Lunar Way, without its own banking licence.

Is there a general overview of affiliate networks and tax for Danish influencers?

Yes — see affiliate influencer marketing in Denmark for the three most-used networks (Partner-ads, Adtraction, Awin) and the rules on B-income, the VAT threshold and advertising disclosure for affiliate income generally.