EEE Digital Agreement 2025: What Changes for Technology and Telecommunications Companies

Key data

If your company operates in Norway, Iceland or Liechtenstein in the digital sector, you now have new obligations to comply with. Decision 309/2025 of the EEA Joint Committee, published on 16 April 2026 but in force since 5 December 2025, amends Annex XI of the Agreement on the European Economic Area to incorporate the most recent European legislation on electronic communication, audiovisual services and information society.

In practical terms: what is already required in the EU in digital matters is now also required in these three countries. If your company already complies with EU digital regulations but has not reviewed its extension to non-EU EEA markets, there is a risk of active non-compliance since December 2025.

What does this regulation establish?

The EEA Agreement allows Norway, Iceland and Liechtenstein to participate in the European internal market without being EU members. To maintain that integration, the EEA Joint Committee periodically updates the annexes of the Agreement to incorporate new European legislation.

In this case, Decision 309/2025 amends Annex XI, which regulates three key areas:

• Electronic communication: obligations for telecommunications operators and providers of electronic communications networks and services.
• Audiovisual services: requirements for video-on-demand platforms and online audiovisual services.
• Information society: obligations for digital service providers, platforms and other actors in the digital ecosystem.

The amendment incorporates recent European legislation in these matters, aligning the obligations of the three non-EU EEA countries with those in force in the 27 EU Member States. The regulation does not specify in its publication which specific directives or regulations are incorporated, but the practical effect is clear: the digital regulatory framework applicable in Norway, Iceland and Liechtenstein is updated and aligned with that of the EU.

Economic and operational impact

The impact is not of a direct sanctioning nature in this decision, but of regulatory compliance: companies operating in the affected markets must adapt their processes, contracts, policies and systems to the new requirements incorporated into Annex XI.

Associated costs will depend on the degree of exposure of each company to these markets and whether it already has a digital compliance framework aligned with EU regulations. In general terms, the most relevant operational impacts are:

• Review of contracts and terms of service for customers in Norway, Iceland and Liechtenstein.
• Adaptation of internal compliance processes to extend the EU framework to the three non-EU EEA countries.
• Possible technical adjustments to digital platforms or communication systems to comply with new requirements.
• Review of agreements with suppliers and local partners in these markets to ensure the compliance chain.

Companies that already operate with a solid digital compliance framework in the EU will have a lower adaptation burden, as requirements are aligned with European standards. Those that maintained differentiated operations for these markets will need to conduct a more thorough review.

Who does it affect?

Decision 309/2025 directly affects the following categories of companies and professionals:

• Telecommunications operators with presence or customers in Norway, Iceland or Liechtenstein.
• Electronic communications service providers (networks, voice services, data, messaging) active in the EEA.
• Digital platforms providing services in these three markets.
• On-demand audiovisual services (streaming, video-on-demand, content platforms) with users in non-EU EEA countries.
• Information society service providers (e-commerce, online services, digital intermediaries) active in these markets.
• Spanish companies with presence in non-EU EEA countries that have not reviewed their digital regulatory compliance in these territories.

Practical example

A Spanish audiovisual content streaming company that operates in Spain and several European countries, including Norway, has active users in this market for years. Until now, it managed regulatory compliance in Norway separately from the EU, assuming that obligations were different.

With Decision 309/2025 in force since 5 December 2025, the obligations applicable in Norway regarding audiovisual services are aligned with those of EU Member States. This means the company must:

• Review whether its terms of service for Norwegian users comply with the requirements of the updated Annex XI.
• Verify that its obligations as an on-demand audiovisual service (European content quotas, accessibility, etc.) also apply in Norway with the same standards as in the EU.
• Update its regulatory compliance map to include Norway, Iceland and Liechtenstein within the same framework as EU countries.

The risk of not acting is operating in non-compliance since December 2025 in a market where the company already has presence and active users.

What should companies do now?

1. Identify if your company operates in any of the three non-EU EEA countries (Norway, Iceland, Liechtenstein) in the affected sectors: telecommunications, audiovisual services, digital platforms or information society services.
2. Audit current regulatory compliance in those markets and compare it with the requirements of Annex XI of the EEA Agreement updated by Decision 309/2025.
3. Review contracts, terms of service and policies applicable to customers and users in Norway, Iceland and Liechtenstein to verify their alignment with new requirements.
4. Extend the EU digital compliance framework to the three non-EU EEA countries if they were still managed separately, taking advantage of the fact that requirements are now aligned.
5. Consult with legal advisors specialized in EEA regulations to determine the specific requirements incorporated into Annex XI and the degree of adaptation necessary for your company.
6. Establish a monitoring system for future updates to the EEA Agreement on digital matters, as the Joint Committee makes periodic amendments that may generate new obligations.