For the analysis of ZnO luminescence, a set of rate equations (SRE) is proposed. It contains a set of parameters that characterize processes participating in luminescence: zone–zone excitation, excitons formation and recombination, formation and disappearance of photons, surface plasmons (SP), and phonons. It is shown that experimental ZnO microstructure radiation intensity dependence on photoexcitation levels can be approximated by using SRE. This approach was applied for the analysis of ZnO microfilm radiation with different thicknesses of Ag island film covering. It was revealed that the increase of cover thickness leads to an increase of losses and a decrease of the probability of photon-to-SP conversion. In order to take into account visible emission, rate equations for level populations in the bandgap and for corresponding photons and SPs were added to the SRE. By using such an SRE, it is demonstrated that the form of visible luminescence intensity dependence on excitation level (P) like P1/3, as obtained elsewhere, is possible only if donor–acceptor pairs exist. The proposed approach was also applied for consideration of experimental results obtained in several papers taking into account the interpretation of these results based on assumptions about the transfer of electrons from the defect level in the ZnO bandgap to metal and then to the conduction band.