Marketing to Greenland and the Faroe Islands: Why Danish and EU Rules Don't Automatically Apply

The Danish Realm, briefly

Greenland and the Faroe Islands are both part of the Danish Realm (Rigsfællesskabet) alongside Denmark, but neither is Denmark in a legal sense. Both have home rule — Greenland since 2009 under the Greenland Self-Government Act (Act no. 473 of 12 June 2009), the Faroe Islands since 1948 under its Home Rule Act — and each has its own legislature (Inatsisartut in Greenland, the Løgting in the Faroe Islands) with the authority to take over policy areas from the Danish state, including marketing law. A campaign that's lawful in Denmark isn't automatically lawful in Nuuk or Tórshavn, and a Danish influencer contract written with only Danish law in mind can miss rules that genuinely apply in either territory.

Greenland and the Faroe Islands sit outside the EU, the EU customs union and the EU VAT area

Neither Greenland nor the Faroe Islands is an EU member. Greenland left the European Communities in 1985, following a 1982 referendum driven mainly by a dispute over fishing rights, and today holds status as one of the EU's Overseas Countries and Territories (OCTs). The Faroe Islands has never been an EU member; its relationship with the EU instead runs through a 1977 Fisheries Agreement and a 1991 Free Trade Agreement (revised 1998). The European Commission's own list of the Customs Territory of the Union states the exclusion explicitly: "Denmark, except the Faroe Islands and Greenland." That means neither the EU customs union nor the EU VAT area covers either territory — and the same holds for EU regulations and directives generally, which don't apply in Greenland or the Faroe Islands unless a territory has separately adopted them into its own law.

Denmark's Marketing Practices Act doesn't automatically apply

The same principle holds inside the Realm itself. Denmark's Marketing Practices Act (markedsføringsloven) states its own boundary directly: the law does not apply to the Faroe Islands and Greenland, though it can be put into force for the Faroe Islands by royal decree with whatever modifications Faroese conditions require. In practice, that means the Danish Consumer Ombudsman's rulings, guidance and enforcement practice under the Marketing Practices Act — the same body of practice most of this Academy is built on — doesn't by itself cover a campaign targeting consumers in Greenland or the Faroe Islands. Both territories have their own marketing legislation instead.

Greenland: its own marketing law — and a language rule for public signage and advertising

Greenland has its own marketing law, Inatsisartutlov nr. 39 af 9. december 2015 om markedsføring og mærkning (Greenland's Marketing and Labelling Act), enforced by Greenland's own Consumer and Competition Authority — not the Danish Consumer Ombudsman. The law's chapter on language use (§ 8) states: "Skriftlig reklamering, skiltning og markedsføring i det offentlige rum skal i videst muligt omfang ske på grønlandsk" — written advertising, signage and marketing in public spaces must, to the greatest extent possible, be in Greenlandic. The rule is framed as a default rather than an absolute ban — other languages may still be used alongside it — but it means a campaign that's exclusively in Danish or English doesn't automatically satisfy Greenlandic law if it involves public signage or advertising in Greenland.

The Faroe Islands: its own marketing law — and a stricter language rule for advertising aimed directly at Faroese consumers

The Faroe Islands likewise has its own marketing law, Løgtingslóg nr. 19 frá 8. mai 2008 um marknaðarføring (most recently amended by løgtingslóg nr. 57 of 2 May 2022), which sets requirements for fair marketing practice, bans misleading marketing, and gives special protection to children and young people — enforced by the Faroe Islands' own Consumer Ombudsman office. It goes further than Greenland's law on language: § 7a, paragraph 1 states directly that "lýsingar og lýsingatilfar, sum er beinleiðis ætlað brúkarum í Føroyum, skal vera á føroyskum" — advertisements and advertising material aimed directly at consumers in the Faroe Islands must be in Faroese. That's not a recommendation; it's a legal requirement, and it has no parallel anywhere in Danish marketing law.

Comparison: Denmark, Greenland and the Faroe Islands

Does GDPR apply in Greenland and the Faroe Islands?

No, not directly. Both territories are third countries for the purposes of EU law and so aren't subject to GDPR as such. Each has its own data protection legislation instead. The Faroe Islands is a notable case: the European Commission has recognised Faroese data protection law as providing an adequate level of protection since 2010 — an adequacy decision — which allows personal data to be transferred from the EU to the Faroe Islands without further contractual safeguards. For a campaign that collects personal data (through a giveaway or a link-in-bio opt-in, for example) from Greenlandic or Faroese followers, that means checking the local framework rather than assuming GDPR compliance automatically covers it.

What this means for an influencer campaign in practice

The practical takeaway isn't that "no rules apply" in Greenland or the Faroe Islands — that's exactly the wrong conclusion this article is meant to head off. The takeaway is that leaning on the Danish compliance checklist by default means leaning on the wrong rules. A brand or agency planning a campaign with a Greenlandic or Faroese audience should, at minimum:

• Work out whether the campaign is genuinely "aimed directly" at consumers in the Faroe Islands (that's the trigger for the § 7a language rule) — a global English-language campaign that happens to be seen by Faroese followers isn't automatically the same as a campaign that targets them.
• For Greenlandic signage and public advertising, make sure Greenlandic is used "to the greatest extent possible," not necessarily exclusively.
• Not assume a Danish legal review of the contract or the disclosure wording automatically covers the Greenlandic or Faroese part of a campaign — get local advice if the campaign is genuinely targeted at either market, rather than just distributed there as a byproduct of a wider Nordic media buy.
• Handle personal data from Greenlandic and Faroese followers under the local framework, not on the assumption that GDPR compliance is automatically sufficient.

Make Influence's take

In our experience, the usual mistake isn't bad intent, it's habit: a Danish marketing team so used to the Marketing Practices Act and the Consumer Ombudsman's guidance that the question "does this also apply in Greenland and the Faroe Islands?" never comes up, because the two territories are a small line item in a combined Nordic media budget. That's a defensible commercial priority, but it isn't the same thing as legal compliance — and it's cheaper to ask the question at campaign planning stage than to find out afterward.

Related reading in the Academy

This article focuses specifically on marketing law. If the task is broader — adapting a whole campaign for the Danish market — see localizing a global influencer campaign for the Danish market. If the campaign also involves a regulated product or industry, the rules covered in influencer marketing in regulated industries in Denmark sit on top of everything here. If the task is finding the right Danish influencers for a campaign in the first place, see how to find Danish influencers. And if the question is instead whether a creator is personally subject to Danish press law, see is a creator subject to Denmark's media liability law.

FAQ

Does a Danish influencer contract need to change if a campaign also runs in Greenland or the Faroe Islands?

The contract's basic structure can usually be reused, but it shouldn't assume Danish marketing law and Consumer Ombudsman practice cover the part of the campaign aimed at either territory. If the campaign is genuinely targeted at Greenlandic or Faroese consumers — not just incidentally visible there — the compliance section should be checked against the local marketing law, not just the Danish one.

Can the same advertising material be used in Denmark, Greenland and the Faroe Islands?

Not without changes for the Faroe Islands if the material is aimed directly at Faroese consumers — the law requires Faroese in that case. For Greenland the requirement is softer ("to the greatest extent possible" for written advertising and signage in public spaces), so reuse is more likely to be acceptable, but it should still be assessed case by case.

Who regulates marketing in Greenland and the Faroe Islands, if not the Danish Consumer Ombudsman?

Greenland has its own Consumer and Competition Authority, which enforces Greenland's marketing law. The Faroe Islands has its own Consumer Ombudsman office under the Faroese marketing law. Neither is a branch of the Danish Consumer Ombudsman.