Update of EEE Annex IX on Financial Services: What Changes for Companies in Norway, Iceland and Liechtenstein

Key data

If your company operates in Norway, Iceland or Liechtenstein—or has clients, subsidiaries or financial agreements in those markets—the applicable regulatory framework has just changed. Decision No. 145/2026 of the EEE Joint Committee, adopted on 30 April 2026 and published on 23 July 2026, amends the Annex IX of the EEE Agreement, which regulates financial services in EEE countries not belonging to the European Union.

The objective is to ensure that Norway, Iceland and Liechtenstein apply the same European financial regulation that governs the 27 EU member states, maintaining the homogeneity of the enlarged internal market.

What does this regulation establish?

The Agreement on the European Economic Area (EEE) extends the EU single market to three countries that are not Union members: Norway, Iceland and Liechtenstein. For this to work, each time the EU approves new legislation in areas covered by the Agreement, the EEE Joint Committee must formally incorporate it into the legal system of those three countries through a specific decision.

That is exactly what Decision 145/2026 does: incorporate new European legislation on financial services into Annex IX of the EEE Agreement. From its entry into force, entities operating in Norway, Iceland and Liechtenstein are obliged to comply with the same financial provisions that are already required in the EU.

The specific EU regulation incorporated through this decision is not detailed in the available summary. To find out the exact list of integrated legislative acts, it is necessary to consult the full text published in EUR-Lex.

Economic and operational impact

The direct impact of this decision is operational and regulatory compliance, not a direct tax cost. Affected companies do not pay a new fee or automatic penalty, but they do assume the obligation to adapt their internal procedures to the financial provisions that are incorporated.

The main vectors of impact are:

• Review of financial contracts and agreements in force in the three EEE countries to verify their compliance with the new incorporated regulation.
• Update of internal compliance procedures, especially in areas such as risk management, transparency, reporting or investor protection, depending on the specific content of the incorporated legislation.
• Coordination with local advisors in Norway, Iceland or Liechtenstein to confirm the scope of new obligations in each jurisdiction.
• Risk of retroactive non-compliance: given that entry into force is 30 April 2026 but publication occurred on 23 July 2026, there is a period in which obligations were already technically enforceable without the regulation being published in the Official Journal. Companies must verify whether any transaction carried out between both dates requires review.

Who does it affect?

• Financial entities (banks, insurance companies, fund managers, investment firms) with presence or activity in Norway, Iceland or Liechtenstein.
• Spanish companies with subsidiaries or branches in one of the three non-EU EEE countries.
• Corporate groups that provide cross-border financial services in the enlarged EEE market.
• Financial and legal advisors who provide services to clients with activity in these markets.
• CFOs and financial directors of companies with exposure to these markets, responsible for local regulatory compliance.

Companies that operate exclusively in Spain and other EU member states are not directly affected by this decision, as EU financial regulation was already applicable to them previously.

Practical example

A Spanish fund manager with an investment vehicle registered in Norway must verify whether the new financial legislation incorporated into Annex IX of the EEE Agreement affects its reporting obligations, capital requirements or conditions for marketing its products in that market.

If the incorporated regulation includes, for example, new transparency or investor protection requirements aligned with recent European directives, the fund manager will need to update its information documents, its contracts with Norwegian investors and its internal compliance procedures—all with effect from 30 April 2026, the date of entry into force of Decision 145/2026.

The first practical step is to consult the full text of the decision to identify which specific legislative acts have been incorporated and assess whether any of them affect the company's specific activity in the country in question.

What should companies do now?

1. Identify if you have financial activity in Norway, Iceland or Liechtenstein. If the answer is yes, this regulation directly affects you.
2. Consult the full text of Decision 145/2026 in EUR-Lex to identify which specific financial legislation has been incorporated into Annex IX of the EEE Agreement.
3. Assess the impact on your current procedures: contracts, reporting, risk management, marketing of financial products or any other area regulated by the incorporated regulation.
4. Review the retroactive period (30 April to 23 July 2026): verify whether any transaction carried out in that interval could be affected by the new obligations and whether it requires any corrective action.
5. Coordinate with local advisors in each of the EEE countries where you operate to confirm the specific scope of new requirements in each jurisdiction.
6. Update your regulatory compliance map to include this decision and future amendments to Annex IX, which occur periodically as the EU approves new financial legislation.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601525