On 29 September 2026, Dutch regulators reported a sharp summer increase in questions and signals about online investment content. More promotion is moving into paid groups, courses and private communities. Financial claims are harder to check there, while private replies can lead people toward account applications.
Why this matters
A public post may only start the sales route. In a paid group, a creator may answer questions about savings, name a product or share an account link. Personalised investment advice may require a licence, even with a disclaimer. Your contract, fee model and campaign file should cover private messages, referral links, onboarding and payments for new customers.
Example
A 2025 objection decision maintained a €1.6 million fine against BUX over customer-acquisition payments. During the examined 2022 period, 27 finfluencers brought in 3,251 customers. Another 149 comparison websites brought in 2,384. The review covered referral tracking, payment and the point when a customer started onboarding.
XTROVERSO tips
- Map the full customer route. List every post, course, group, message, referral link and onboarding page. Record who controls each step.
- Read the payment clause again. Check whether payment follows content delivery, a lead, onboarding, a deposit or trading. Keep the fee terms with the campaign file.
- Set rules for private replies. Tell creators and moderators what they may discuss. Stop personal product suggestions based on someone’s savings or financial position.
- Check the promoted provider. Confirm the provider’s status before launch. Record who checked it and keep that check with the campaign file.
- Keep one usable record. Connect the contract, approved claims, disclosures, messages, links, invoices and approvals. The file should show what changed and when.
- Give one person stop authority. Name the person who can pause the campaign if a claim, provider, payment term or customer complaint changes the risk.
Need a clear review of creator contracts, referral fees and campaign records? We can help map gaps before your next launch
The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Paolo Maria Pavan before publication.
References
- Online beleggingstips? Herken de red flags!
- Autoriteit Financiële Markten - Personal advice, general recommendations and disclosure of interests
- Autoriteit Financiële Markten - Licensed firms remain responsible for the acquisition model
- Autoriteit Financiële Markten - BUX procedural status
- Autoriteit Financiële Markten - Enforcement against promotion of an illegal asset manager
- Autoriteit Financiële Markten - Latest published procedural status of the Grinta finfluencer enforcement case
- Autoriteit Financiële Markten - Crypto promotion and market-manipulation risk
