EEE Financial Services 2026: what changes for companies operating in Norway, Iceland and Liechtenstein

Key data

Spanish companies with presence in Norway, Iceland or Liechtenstein have a specific obligation from 6 February 2026: to review their regulatory compliance procedures in financial services. The Decision 35/2026 of the EEA Joint Committee, published in the EU Official Journal on 21 May 2026 with reference OJ:L_202600987, amends Annex IX of the EEA Agreement relating to financial services.

The mechanism is the usual one in EEA functioning: when the EU approves new financial regulation, the EEA Joint Committee adopts a decision to incorporate it into the EEA Agreement and extend its application to the three non-EU countries that are part of the European Economic Area. This ensures regulatory homogeneity in the expanded European financial single market.

What does this regulation establish?

Decision 35/2026 amends the Annex IX of the EEA Agreement, which is the specific annex dedicated to financial services. Through this amendment, new EU financial regulation is incorporated into the EEA scope and becomes applicable in Norway, Iceland and Liechtenstein.

The objective of this update is to ensure that the financial regulatory framework is equivalent in all countries of the expanded European single market, regardless of whether or not they are members of the European Union. Financial entities operating in these countries must adapt their procedures and compliance systems to the new incorporated requirements.

Economic and operational impact

The direct impact of this decision is operational and regulatory compliance. It is not a new fee or direct sanction, but rather the extension of EU financial regulatory obligations to three additional EEA markets.

For Spanish companies, this translates into concrete adaptation costs:

• Review of internal compliance procedures in branches or subsidiaries located in Norway, Iceland or Liechtenstein.
• Update of policies and controls to align them with the new requirements incorporated into Annex IX.
• Possible training of personnel responsible for compliance in those markets.
• Coordination with local advisors in each of the three countries to verify the specific scope of the new requirements.

The cost of non-adaptation can be significant: operating in EEA markets without complying with applicable financial regulation exposes entities to regulatory sanctions in the affected countries, in addition to reputational risks in the European single market.

Who does it affect?

This decision directly affects:

• Spanish financial entities with subsidiaries, branches or operations in Norway, Iceland or Liechtenstein.
• Banks and credit institutions operating in the expanded European financial single market.
• Investment firms and fund managers with activity in the three non-EU EEA countries.
• Insurance and reinsurance companies with presence in those markets.
• International financial groups headquartered in Spain that have extended their activity to EEA countries.
• CFOs and regulatory compliance directors responsible for regulatory supervision in these markets.
• Legal advisors and compliance consultants providing services to entities with activity in the EEA.

Practical example

A Spanish financial entity with a branch in Oslo (Norway) that already complied with EU financial regulation in its operations in Spain must now verify that this same regulation—in the version incorporated into Annex IX of the EEA Agreement through Decision 35/2026—is being correctly applied in its Norwegian operations.

The concrete process involves: identifying which EU financial regulation has been incorporated into Annex IX through this decision, reviewing whether the branch's current procedures already comply with those requirements or if they require adaptation, and documenting the compliance analysis in case of a request from the local Norwegian supervisor.

The same applies to any company in the group with presence in Iceland or Liechtenstein: the decision affects all three non-EU EEA countries equally, so the review must be simultaneous in all three markets if there is presence in all of them.

What should companies do now?

1. Identify presence in non-EU EEA countries: Verify if the company or any entity in the group operates in Norway, Iceland or Liechtenstein in the financial services sector.
2. Review the text of Decision 35/2026: Access the official source on EUR-Lex (OJ:L_202600987) to identify which specific financial regulation has been incorporated into Annex IX of the EEA Agreement.
3. Analyze the impact on current procedures: Compare the new incorporated requirements with the compliance procedures in force in each affected country.
4. Coordinate with local advisors: Contact advisors specialized in financial regulation in Norway, Iceland or Liechtenstein to confirm the scope and adaptation timelines required by the local supervisor.
5. Update policies and controls: Implement necessary changes in internal procedures, compliance policies and operational controls to align with the new requirements.
6. Document the adaptation process: Record the analysis performed and measures adopted, in case of requests from the financial supervisor in the affected countries.