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

Key data

Spanish companies with activity in non-EU EEE countries —Norway, Iceland and Liechtenstein— have new regulatory obligations to review. The Decision 310/2025 of the EEE Joint Committee, adopted on 5 December 2025 and published on 16 April 2026, amends Annex XI of the EEE Agreement to incorporate updated EU regulations on digital matters.

The objective is to ensure regulatory homogeneity between the EU and the three non-EU EEE countries in the areas of electronic communication, audiovisual services and information society. If your company operates digital platforms, telecommunications networks or audiovisual content services in these territories, this decision directly affects you.

What does this regulation establish?

The EEE Joint Committee is the body responsible for maintaining regulatory equivalence between the EU and non-EU EEE countries. When the EU approves new regulations in areas covered by the EEE Agreement, the Joint Committee formally incorporates it into the agreement through decisions such as this one.

In this case, Decision 310/2025 updates Annex XI, which covers three major areas:

• Electronic communication: telecommunications networks and services, connectivity infrastructure.
• Audiovisual services: content platforms, broadcasting, video-on-demand services.
• Information society: digital platforms, e-commerce and online services.

The amendment may involve new operational obligations in any of these three areas for companies operating in the EEE space. The decision does not specify in its publication the specific regulatory texts incorporated, so it is necessary to consult the full text in the official source to identify the specific obligations applicable to each type of company.

Economic and operational impact

The main impact of this decision is of an operational and regulatory compliance nature, not directly economic in terms of published fees or sanctions. However, non-compliance with the incorporated obligations may generate relevant economic consequences:

• Costs of adapting systems and processes to comply with new requirements in electronic communication or audiovisual services.
• Risk of sanctions by regulatory authorities in Norway, Iceland or Liechtenstein if compliance with updated regulations is not demonstrated.
• Possible contractual reviews with partners or clients in the affected EEE countries if existing agreements do not contemplate the new regulatory obligations.
• Need to update privacy policies, terms of service or technical procedures according to the new provisions incorporated into Annex XI.

Companies that already operate under EU regulations in these areas have an advantage, as the decision seeks precisely to extend that same regulation to non-EU EEE countries. The adaptation effort will be smaller for those who already comply with the current European framework.

Who does it affect?

This regulation directly affects:

• Telecommunications companies that operate networks or provide electronic communication services in Norway, Iceland or Liechtenstein.
• Digital platforms and technology companies with presence or active users in non-EU EEE countries.
• Audiovisual service operators: streaming platforms, video-on-demand services, broadcasters with activity in the EEE space.
• Spanish companies with subsidiaries, branches or direct commercial activity in Norway, Iceland or Liechtenstein in the mentioned sectors.
• Legal and regulatory compliance advisors providing services to companies with exposure to the EEE market in the digital field.
• CFOs and operations directors of business groups with presence in the EEE space who must validate regulatory compliance in these territories.

Practical example

A Spanish technology company operating a video-on-demand platform with users in Norway must verify whether the new provisions incorporated into Annex XI of the EEE Agreement impose additional obligations on it regarding audiovisual services: for example, European content quota requirements, accessibility obligations or new registration conditions with the Norwegian regulatory authority.

If this company already complies with the EU Audiovisual Media Services Directive in its operations within the EU, it is likely that the new obligations incorporated into the EEE are equivalent or identical. In that case, the adaptation effort would be limited to verifying that its compliance formally extends also to users and operations in Norwegian, Icelandic or Liechtenstein territory.

If, on the other hand, the company had treated these markets as territories with lower regulatory burden, it will need to review in detail the updated text of Annex XI to identify compliance gaps and act before local authorities initiate supervision procedures.

What should companies do now?

1. Identify exposure: Determine whether your company operates telecommunications services, digital platforms or audiovisual services in Norway, Iceland or Liechtenstein. If the answer is yes, this decision directly affects you.
2. Consult the full text: Access the full text of Decision 310/2025 in the EU Official Journal to identify what specific regulations have been incorporated into Annex XI.
3. Audit current compliance: Compare the new incorporated provisions with your current policies and procedures in the affected EEE countries. Detect possible compliance gaps.
4. Coordinate with local advisors: Contact legal advisors specialized in non-EU EEE countries to validate compliance under updated local regulations, especially in Norway given the size of its digital market.
5. Update contracts and policies: If new applicable obligations are detected, update terms of service, privacy policies and contractual agreements with partners and clients in these territories.
6. Establish continuous monitoring: The EEE Joint Committee adopts regulatory incorporation decisions periodically. Implement a monitoring system to detect future updates to Annex XI with sufficient advance notice to adapt.