The AFM’s finfluencer warning follows the commercial chain from private advice to onboarding and reward.
A founder approves a short video about investing. The script is careful, the disclaimer is visible and the creator’s fee looks ordinary. A week later, the real conversation continues inside a paid Telegram group. Members ask about their savings, receive product suggestions and follow a link to open an account. The public campaign was only the front door.
On 29 September 2026, the Dutch Authority for the Financial Markets reported a strong summer increase in questions and signals about finfluencing and online investment content. The AFM also sees more content moving behind paywalls, into paid courses, closed groups and exclusive communities. Consumers have reported investing with illegal providers after recommendations from finfluencers.
The immediate issue is consumer harm. The wider business direction is sharper: Dutch supervision follows the whole commercial chain. The label on the creator matters less than the work performed, the financial claim made, the provider promoted and the reward attached to the customer’s next step.
A disclaimer cannot carry the business
A creator may call the content education. An agency may call it engagement. A platform may call it community building. Those descriptions do not decide the character of the activity. Personalised investment advice requires an AFM licence, and a disclaimer such as “not financial advice” does not settle the question when someone responds to an individual’s financial situation.
That boundary can be crossed quietly. A member mentions having €20,000 available and asks which product fits. The host replies with a named investment, provider or allocation. Broad market commentary has become personal communication, and the business behind it has entered a different risk area.
Investment recommendations carry standards of their own. The AFM expects objective substantiation, a clear distinction between facts and opinions, named sources and disclosure of relevant interests or payments. This is more than wording beneath a post. It concerns the commercial honesty between creator, audience and promoted party.
The reward explains the pressure
The payment model often reveals more than the campaign brief. A fixed production fee differs from compensation linked to introduced customers. Banks and brokers may not reward third parties according to the number of customers they introduce. The relevant point can arise when a prospective customer starts onboarding for an investment account.
The AFM’s decision concerning BUX shows why this belongs at company level. In July 2025, the regulator maintained a €1.6 million fine relating to customer-acquisition compensation between 1 January 2022 and 20 April 2023. In the examined 2022 period, 27 finfluencers accounted for 3,251 acquired customers, while 149 comparison websites accounted for 2,384.
BUX lodged an appeal on 15 August 2025. The operating lesson remains clear. A licensed firm cannot place responsibility outside its walls merely because an agency, comparison website or creator supplied the lead. Referral tracking, remuneration and onboarding belong to its own operating model.
Closed doors do not end responsibility
The paywall creates a difficult illusion. It feels private, separate from the formal campaign and closer to conversation than advertising. Commercially, that intimacy is valuable. From a governance perspective, visibility weakens while influence grows.
The Grinta Invest case gives that point a harder edge. On 31 August 2026, the Rotterdam District Court upheld the finding that a finfluencer had co-perpetrated unlicensed investment services. The court reduced the fine from €256,000 to €203,500. The case involved promotion, investor introductions, sign-up assistance and commission.
A polished campaign cannot repair weak checks on the provider being promoted. Nor can an approved public video repair unseen personal exchanges in a course chat. The commercial chain needs to hold together from the first claim to the final reward.
What a small company should be able to reconstruct
For a small investment firm, fintech business or marketing agency, control does not require a large department. It requires the ability to reconstruct the relationship. Who selected the provider? Who approved the claims? Which channels were used? What could the creator say in private? When did payment arise? Who could stop the campaign?
That record should connect the contract, fee model, campaign material, referral link, onboarding trigger and relevant closed-channel communication. It should identify the person responsible when content changes or a customer complains. These records protect management time, partner confidence and the credibility of the customer journey.
Crypto promotion adds another layer. Since 30 December 2024, pump-and-dump conduct involving crypto-assets has been prohibited for organisers and participants. The AFM identifies finfluencers as possible participants. Holdings, timing, coordination and trading incentives can matter beside ordinary advertising disclosures.
Return to the founder who approved the careful video. The decisive question is no longer whether the disclaimer appeared beneath it. The question is whether the company understands what happens after the viewer clicks, joins, asks and begins onboarding. Behind the paywall, commercial influence remains business conduct. Someone must own it.
If your business works with finfluencers, I can help you map responsibility from the first claim through referral, onboarding and reward.
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 - Enforcement against promotion of an illegal asset manager
- Autoriteit Financiële Markten - Latest published procedural status of the Grinta finfluencer enforcement case
- Autoriteit Financiële Markten - Licensed firms remain responsible for the acquisition model
- Autoriteit Financiële Markten - Chat groups, impersonation and investment fraud
- Autoriteit Financiële Markten - Crypto promotion and market-manipulation risk
- Autoriteit Financiële Markten
