EEE Agreement 2025: new obligations for companies with activity in Norway, Iceland and Liechtenstein

Key data

If your company has subsidiaries, branches or financial activity in Norway, Iceland or Liechtenstein, this regulation already affects you. The Decision 304/2025 of the EEE Joint Committee modifies the annexes IX (Financial services) and XXII (Company law) of the Agreement on the European Economic Area, incorporating updated European legislation that is now mandatory in these three non-EU EEE countries.

The objective is to ensure regulatory homogeneity between the European Union and EEE countries that are not EU members. In practice, this means that European rules on financial and corporate matters that already apply in Spain are formally extended to those territories, and companies operating there must adapt their structures and compliance processes.

What does this regulation establish?

Decision 304/2025 updates two regulatory blocks of the EEE Agreement:

The update integrates into the EEE framework the current European legislation in these matters, ensuring that Norway, Iceland and Liechtenstein apply the same rules as EU member states. For Spanish companies with presence in these countries, this is not a theoretical change: it implies reviewing whether their local subsidiaries or structures comply with the new incorporated provisions.

Economic and operational impact

The impact depends on the type of activity the company develops in non-EU EEE countries. The most relevant effects are:

• Financial entities: possible new capital requirements and reporting obligations that may involve costs of adapting internal systems and processes.
• Commercial companies with subsidiaries: need to review corporate structures to ensure they comply with European legislation now incorporated into the EEE Agreement.
• Transparency obligations: the new provisions may require greater disclosure of information to local authorities in Norway, Iceland or Liechtenstein.
• Compliance costs: internal audits, contract updates, review of bylaws and possible adaptations of financial reporting systems.

The regulation has been in force since December 5, 2025, which means that any non-compliance is enforceable from that date, although the official publication in the Official Journal of the EU took place on April 16, 2026.

Who does it affect?

This regulation directly affects:

• Spanish business groups with subsidiaries or holdings in Norway, Iceland or Liechtenstein.
• Financial entities (banks, asset managers, insurers, funds) with activity or presence in the three non-EU EEE countries.
• Commercial companies incorporated or with branches in Norway, Iceland or Liechtenstein.
• CFOs and financial directors responsible for regulatory compliance in cross-border structures that include these territories.
• Legal and tax advisors managing clients with presence in the EEE outside the EU.
• Compliance departments of companies with cross-border activity in the European Economic Area.

Practical example

A Spanish business group in the financial sector has a subsidiary in Norway dedicated to asset management. Until now, that subsidiary operated under the Norwegian regulatory framework prior to the incorporation of the new European provisions. With the entry into force of Decision 304/2025 on December 5, 2025, that subsidiary must comply with the same transparency and reporting obligations that would be required if it operated in an EU member state.

In practice, the group must:

1. Review whether the bylaws and structure of the Norwegian subsidiary comply with European legislation now incorporated into Annex XXII of the EEE Agreement.
2. Verify whether the subsidiary's financial reporting systems cover the new obligations of Annex IX.
3. Assess whether there are new capital requirements applicable to the financial activity developed in Norway.

The same analysis applies to any company with presence in Iceland or Liechtenstein.

What should companies do now?

1. Identify exposure: Determine whether your group has subsidiaries, branches, holdings or operational activity in Norway, Iceland or Liechtenstein.
2. Review corporate structures: Analyze whether local companies in those countries comply with European legislation incorporated into Annex XXII (Company law) of the EEE Agreement.
3. Audit financial compliance: Verify that the group's financial entities with presence in the three countries comply with the new provisions of Annex IX, including transparency, reporting and capital requirements.
4. Consult with local advisors: Since the regulation has been in force since December 5, 2025, it is urgent to verify current compliance with advisors specialized in Norwegian, Icelandic or Liechtenstein law.
5. Update compliance policies: Incorporate the new obligations arising from Decision 304/2025 into internal manuals and procedures for cross-border regulatory compliance.