EEE 2025: New Financial Obligations for Companies Operating in Norway, Iceland and Liechtenstein

Key data

Spanish companies with cross-border activity in the European Economic Area have new regulatory compliance obligations in the field of financial services. The Decision 298/2025 of the EEE Joint Committee, adopted on 5 December 2025 and published in the Official Journal on 16 April 2026, amends the Annex IX of the EEE Agreement, which is the text that regulates financial services applicable in the three EEE countries not belonging to the EU: Norway, Iceland and Liechtenstein.

The objective of this amendment is to ensure regulatory homogeneity in the enlarged internal market, incorporating into the EEE framework the new financial legislation approved in the European Union. In practice, this means that the rules of the financial game in these three countries are updated to align with EU standards.

What does this regulation establish?

The European Economic Area Agreement allows Norway, Iceland and Liechtenstein to participate in the EU internal market without being full members. For this market to function homogeneously, the EEE Joint Committee periodically updates the annexes of the Agreement to incorporate current European regulations.

The Annex IX is the one that specifically contains the regulation of financial services. With Decision 298/2025, this annex is amended to include new EU financial legislation, so that entities operating in EEE countries are subject to the same requirements that apply in the European market.

It is important to distinguish between the entry into force of the decision (5 December 2025) and the effective application of the specific obligations, which may be subject to the transposition timelines that each of the three EEE States establishes in its national legislation.

Economic and operational impact

For Spanish companies, the impact depends directly on the type and volume of activity they have in EEE countries. The main operational effects are:

• Review of internal procedures: Financial entities operating in Norway, Iceland or Liechtenstein will have to adapt their processes to the new requirements incorporated into Annex IX.
• Compliance cost: Regulatory adaptation involves costs for legal review, contract updates and, where applicable, modification of operational or reporting systems.
• Risk of transitional non-compliance: Since effective application depends on the transposition timelines of each EEE State, there is a period in which obligations may not be fully defined, requiring active monitoring.
• Opportunity for early alignment: Companies that adapt their procedures before each EEE State completes its transposition reduce the risk of non-compliance and avoid last-minute adjustments.

Who does it affect?

This regulation directly affects:

• Spanish financial entities with branches, subsidiaries or direct activity in Norway, Iceland or Liechtenstein.
• Banks and credit institutions that provide cross-border services in EEE countries.
• Investment firms and fund managers operating in these markets.
• Insurance and reinsurance companies with presence or activity in the non-EU EEE.
• Non-financial companies that, due to their activity in EEE countries, are subject to compliance obligations in the field of financial services (payments, financing, financial instruments).
• CFOs, financial directors and legal advisors of business groups with exposure to these markets.

Practical example

A Spanish financial entity operating with a branch in Oslo (Norway) provides asset management services to institutional clients. Until now, its compliance procedures were aligned with EU regulations applicable in Spain.

With the entry into force of Decision 298/2025, Norway must incorporate into its legal system the new EU financial legislation that has been added to Annex IX of the EEE Agreement. This means that the Oslo branch will have to:

1. Identify what specific new requirements Annex IX has incorporated.
2. Verify the timeline in which Norway completes the transposition of those requirements into its national legislation.
3. Adapt its operational and reporting procedures in the branch before that deadline expires.

If the company does not carry out this monitoring and the branch operates without complying with the new requirements once transposed, it is exposed to regulatory sanctions in Norway, regardless of its compliance in Spain.

What should companies do now?

1. Identify exposure to non-EU EEE: Determine whether the company has regulated financial activity in Norway, Iceland or Liechtenstein, either directly or through subsidiaries, branches or cross-border provision of services.
2. Review the updated Annex IX: Access the text of Decision 298/2025 published in the Official Journal of the EU to identify what specific EU financial legislation has been incorporated into Annex IX.
3. Monitor transposition timelines: Keep track of the transposition schedules of Norway, Iceland and Liechtenstein, as the effective application of new obligations depends on each EEE State.
4. Update compliance procedures: Adapt internal processes, contracts and reporting systems to the new requirements before the transposition deadlines expire in the countries where you operate.
5. Involve the legal and compliance team: Assign clear responsibility for monitoring to regulatory compliance teams or external advisors specializing in EEE financial regulation.