When Does Promoting Insurance Require an Influencer to Hold an Insurance Intermediary Licence?

Short answer: it depends on whether the influencer is advertising, or actually distributing the insurance

Yes — but only under specific circumstances. An influencer who, in a paid partnership, talks about their own insurance, recommends a company, or shows a screen recording of an app is not, by itself, conducting insurance distribution. But as the Academy's article on regulated industries covers for alcohol, finance and pharma, insurance is another industry with its own, separate licensing requirement — and the line for when it hits an influencer runs, per the law's own definition, between giving information and actually helping the follower conclude the contract, typically via a personal discount code or affiliate link.

This is practical guidance from Make Influence, not legal advice. Use this article to understand where the line sits — get a concrete assessment of your own arrangement from a lawyer specialising in financial regulation if you're unsure.

Two questions, not one: does the law even cover this, and does it hit the influencer?

Denmark's Insurance Distribution Act (lov om forsikringsformidling) implements the EU's Insurance Distribution Directive (IDD, Directive 2016/97) into Danish law. Under the Act's § 3(1), any business conducting insurance distribution must hold Finanstilsynet's (the Danish FSA's) licence and be listed in Finanstilsynet's register of insurance intermediaries. That applies regardless of whether the business calls itself an influencer, an agent, a broker or something else entirely — the law looks at the activity, not the title.

	Pure mention/advertising	Insurance distribution
What the influencer does	Talks about the product, reviews it, shares their own experience	Helps the follower actually take out or conclude the contract
Typical mechanic	Generic mention, no personal code or link to complete the purchase	Personal discount code or affiliate link the follower uses to take out the insurance
Payment	Flat fee for exposure, regardless of whether anyone takes out the insurance	Commission per policy sold or per completed sign-up
Requires a licence?	No — falls under the law's own exclusion, outside insurance distribution	Likely yes — requires a licence or registration with Finanstilsynet

What counts as insurance distribution under the law?

Article 2(1)(1) of the IDD defines insurance distribution broadly: the activities of advising on, proposing, or carrying out other work preparatory to the conclusion of contracts of insurance, of concluding such contracts, or of assisting in the administration and performance of such contracts — including providing information about one or more insurance contracts according to criteria a customer selects via a website or other media, compiling a ranking list of insurance products (including price and product comparison), or offering a discount on the price of an insurance contract, when the customer can directly or indirectly conclude the insurance contract via that website or medium. That last part is the one that matters most for an influencer: a personal discount code or affiliate link that a follower uses to actually complete the sign-up is, per the directive's own wording, exactly the kind of activity the definition targets.

Article 2(2) of the directive carries an explicit exclusion alongside it: providing information on an incidental basis in the context of another professional activity does not constitute insurance distribution, provided the purpose of that activity is not to help the customer conclude or perform an insurance contract, and the provider takes no additional steps to assist in the conclusion. That exclusion is what keeps an ordinary sponsored review or recommendation outside the law's scope — but it stops applying the moment the influencer takes that "additional step": a personal link or code that leads directly to sign-up, especially when it's tied to commission.

Two categories: full authorisation and accessory registration

Per Finanstilsynet's own description of insurance distribution, there are, in practice, two tracks:

Category	What it requires	Typical example
Insurance intermediary (full authorisation)	Finanstilsynet's licence as an insurance intermediary, including a "fit & proper" approval of the business's management, professional liability insurance, and competency requirements for staff	An independent insurance and pension broker, where distribution is the core business
Accessory insurance intermediary (registration)	Registration with Finanstilsynet, without the full licensing requirement — but only when the insurance is complementary to the business's own actual good or service	A moving company offering transport insurance, or a travel agency selling cancellation insurance alongside the trip

A caution: this research found nothing that clarifies whether an influencer's distribution of insurance — where the "core business" is content production, not the sale of another good or service — can even qualify as "accessory" in the law's sense, or whether it must instead be treated as full insurance distribution. That is not settled either in this research or, as far as could be established, in published Finanstilsynet practice specific to influencers. Get a concrete assessment from a lawyer specialising in financial regulation if the question is live for your arrangement.

Enforcement is real — even against large, established companies

On 10 April 2025, Finanstilsynet published a news item headlined "Insurance companies must use intermediaries with a licence" (Forsikringsselskaber skal benytte formidlere med tilladelse). The background was a concrete investigation in which Finanstilsynet found that an insurance company sold products through independent insurance intermediaries, 2 of 12 of which lacked a valid licence to conduct insurance distribution. The requirement, per Finanstilsynet's own wording, is anchored in the Act's § 3(7): an insurance company may only use the services of an insurance intermediary that holds a licence — and the company must have sufficient procedures and controls to ensure this, both when the partnership begins and on an ongoing basis. A licence can be checked in Finanstilsynet's public business register.

Just over a month later, on 13 May 2025, Finanstilsynet issued a reprimand (påtale) to Nordea Finans Danmark A/S for having conducted insurance distribution without the required licence from 18 October 2018 to 11 June 2024 — a breach of the Act's § 3(1). The case came to light because Nordea itself contacted Finanstilsynet on 13 June 2024 to clarify whether certain products required a licence; the company had already voluntarily stopped offering them by then. Finanstilsynet weighed the circumstances and nature of the case and issued a formal reprimand — not a fine, but a published, named supervisory action against a large, well-established financial company, for exactly the violation this article is about: conducting insurance distribution without a licence.

Together, the two cases show something worth noting: Finanstilsynet is actively enforcing the licensing requirement in 2025, and even a large company with its own legal department missed it for six years. Neither case involves an influencer specifically — which is, honestly, exactly the unresolved part this article itself flags.

When does an influencer's coverage cross the line into distribution?

Based on the law's and the directive's own wording, the following is what, in practice, determines whether a specific influencer activity is likely to require a licence or registration:

• Is there a personal discount code or affiliate link that the follower themselves uses to take out the insurance? If yes, the activity moves closer to the directive's own definition of insurance distribution — "a discount on the price of an insurance contract, when the customer can directly or indirectly conclude the contract via the website or medium."
• Is the payment commission per policy sold, rather than a flat fee for exposure? Commission tied to the actual sale is a strong signal that the influencer is "assisting in the conclusion" of the contract — not merely informing about it.
• Does the influencer advise on which specific product the follower should choose, tailored to the follower's own situation? That moves closer to advising, one of the core concepts the definition itself names.
• Is the coverage purely general — no personal link, no sale traceable back to the influencer, flat fee? That keeps the activity inside the exclusion for incidental information in the context of another professional activity (content production), provided the influencer takes no additional steps to help with the sign-up.

This research found no case, guidance or decision from Finanstilsynet that specifically applies this line to an influencer campaign — the line above is drawn directly from the law's and the directive's own wording, not from a published influencer-specific ruling. That is an honest limitation of this article, not an attempt to guess at an answer the law doesn't itself provide.

Decision framework for a brand considering an influencer campaign for insurance

IF the campaign is only a sponsored review or recommendation, with no personal link or code the follower uses to take out the insurance → the activity looks like ordinary advertising and likely falls outside insurance distribution.

IF the influencer gets their own discount code or affiliate link that the follower uses to take out the insurance, and the influencer earns commission per policy sold → get it legally clarified with a lawyer specialising in financial regulation before the campaign goes live. Don't assume it's unproblematic just because it resembles the affiliate models common in other industries in Denmark.

IF you're unsure whether the influencer's role could qualify as "accessory" insurance distribution or requires full authorisation → remember that this research could not settle the question definitively; seek clarification from Finanstilsynet or a lawyer yourself, rather than assuming the lighter category applies.

IF the insurance company itself is entering the partnership with the influencer → remember that, per Finanstilsynet's April 2025 statement, it is the insurance company's own responsibility to verify that any intermediary — including an influencer, if the activity qualifies as distribution — holds a valid licence, both at the start of the partnership and on an ongoing basis.

Worked example: why the commission model changes the picture (hypothetical, not a real case)

The figures below are invented and for illustration only — not a Make Influence customer or a real case.

An influencer enters into two different arrangements with an insurance company over the course of a year:

Arrangement A (advertising): The influencer is paid DKK 15,000 for a single sponsored video talking about the company's travel insurance. There is no personal link, no code, and the fee is the same regardless of whether any follower subsequently takes out the insurance. This activity looks like ordinary advertising.

Arrangement B (affiliate/commission): The influencer instead gets a personal discount-code link and DKK 150 in commission for every policy taken out. Over the year, 220 followers take out the insurance via the link — total commission of DKK 33,000. This activity contains exactly the elements the directive's own definition highlights: a personal link through which the customer can conclude the contract directly, and payment tied to the actual sale.

The example doesn't show what's "right" or "wrong" — it shows why two seemingly similar influencer insurance partnerships can end up in different legal categories, purely because the payment and link structure differs.

Make Influence's operational perspective

In our experience, insurance is an industry where brands and influencers think about the regulation less often than they do for finance or pharma — probably because an insurance product feels like an ordinary consumer good. Our clear recommendation is to treat any insurance campaign involving a personal link or a commission model as a regulatory question from the outset — not something investigated for the first time only if Finanstilsynet reacts. If the campaign is purely a flat-fee recommendation with no traceable sale, the risk is, in our assessment, markedly lower, but we still recommend getting that confirmed in writing with the insurance company's own legal or compliance function before the contract is signed — it is the company, not the influencer, that per Finanstilsynet's own practice carries the primary responsibility for verifying the intermediary's licence.

FAQ

Does an influencer need to apply for a licence from Finanstilsynet themselves?

It depends on whether the activity qualifies as insurance distribution under the law. If the influencer actually helps conclude the insurance contract — typically via a personal link or code tied to commission — the law's own definition points to a licence or registration being required. A purely flat-fee recommendation with no traceable sale likely does not, per the directive's own exclusion.

Is it the insurance company or the influencer who is responsible for checking the licence?

Both can be relevant, but Finanstilsynet's April 2025 statement is addressed explicitly to the insurance company: it is the company's responsibility to verify that any intermediary it uses holds a valid licence — both at the start of the partnership and on an ongoing basis. That doesn't exempt the influencer from needing the required licence themselves if the activity requires it.

Does this only apply if the influencer sells a whole insurance policy, or also with discount codes?

The directive's own definition explicitly names "a discount on the price of an insurance contract, when the customer can directly or indirectly conclude the contract via the website or medium" as part of insurance distribution. A discount code that leads directly to sign-up is therefore not automatically excluded just because it's "only" a discount rather than a full sale.

What's the penalty for distributing insurance without a licence?

This research found that Finanstilsynet can issue a reprimand (as in the Nordea case) and has the authority to issue orders to insurance companies that fail to comply with the requirement. This research could not find a published, concrete fine level specifically for an intermediary conducting business without a licence — get a concrete assessment from a lawyer if the question is live.

Is "accessory insurance intermediary" an easier path for an influencer?

Maybe, but it's not settled. The category is intended for businesses where the insurance complements another good or service the business already sells — as the moving-company and travel-agency examples show. Whether an influencer's content production could count as that "other good or service" in the sense of the law has not been researched or settled in this article.

Do the same rules apply to recommending an investment-linked insurance product or a pension scheme?

Likely yes for the insurance-distribution rules described here, but a product with an investment element can additionally trigger the separate rules on investment recommendations and advice. See finfluencers in Denmark: when does promoting an investment product cross into regulated financial advice for the parallel regime under the Market Abuse Regulation.

Does this replace the ordinary ad-disclosure rules?

No. Regardless of whether the activity qualifies as insurance distribution or is "just" advertising, a paid partnership still needs to be clearly marked as an ad. The two rule sets apply on top of each other, not instead of each other.

Does the same licensing logic apply in other industries, like real estate?

Yes, the same principle recurs: a licence attaches to a specific regulated activity, not to the title "influencer." The Academy's article on real estate mediation covers the parallel, but less settled, line for an influencer promoting a property listing for commission.

Does the same prohibition apply to other regulated professions, like lawyers?

No, not in the same absolute way. Insurance distribution turns on when the activity itself requires Finanstilsynet's licence, while the rules for lawyers instead prohibit the payment structure itself — any referral fee or fee-sharing with a non-lawyer — regardless of whether the underlying activity otherwise resembles distribution.