EEE Financial Services 2025: what changes for companies with activity in Norway, Iceland and Liechtenstein

Key data

Spanish companies with financial activity in the countries of the European Economic Area not belonging to the EU —Norway, Iceland and Liechtenstein— have an active regulatory review obligation from 5 December 2025. The Decision No. 296/2025 of the EEE Joint Committee modifies Annex IX of the EEE Agreement, the text that regulates financial services applicable in these three countries, incorporating new European regulation and ensuring regulatory homogeneity in the enlarged internal market.

The practical impact is clear: if your company provides financial services or has operations in any of these markets, the legal framework governing that activity has changed. And although the official publication in the Official Journal of the EU took place on 16 April 2026, the effects are retroactive to 5 December 2025.

What does this regulation establish?

The European Economic Area (EEE) Agreement extends the EU internal market to three non-member countries: Norway, Iceland and Liechtenstein. For this market to function homogeneously, the EEE Joint Committee periodically updates the annexes of the Agreement to incorporate the European regulation being approved.

The Annex IX is the one that specifically regulates financial services. Decision 296/2025 modifies it to incorporate new European financial regulation, so that the rules applicable in Norway, Iceland and Liechtenstein are aligned with those in force in EU member states.

The decision does not publicly detail in its summary which specific European directives or regulations are incorporated into Annex IX, so to know the exact list of incorporated standards it is necessary to consult the full text in the official source.

Economic and operational impact

The impact of this decision is not of a direct sanctioning nature nor does it imply new published fees or tax costs. Its effect is regulatory and operational: companies already operating in these markets must verify that their internal procedures comply with the new requirements incorporated into Annex IX.

The main impact vectors are:

• Internal adaptation costs: review of contracts, compliance procedures and documentation applicable to activity in Norway, Iceland or Liechtenstein.
• Opportunity for operational simplification: greater regulatory homogeneity between the EEE and the EU can reduce the burden of managing different regulatory frameworks for each market.
• Risk of retroactive non-compliance: given that the regulation entered into force on 5 December 2025 and was published on 16 April 2026, there is a period in which the obligation was already enforceable without many companies having formal knowledge of it.

Financial entities with direct presence in these countries —branches, subsidiaries, financial product distribution agreements— are those that must act with greater urgency.

Who does it affect?

• Spanish financial entities with branches, subsidiaries or regulated activity in Norway, Iceland or Liechtenstein.
• Banks and credit institutions operating in the enlarged internal market of the EEE.
• Investment firms and fund managers with cross-border activity in the three non-EU EEE countries.
• Insurance companies and payment service entities providing services in these markets.
• CFOs and financial directors of business groups with subsidiaries in Norway, Iceland or Liechtenstein who must report or comply with local financial regulation.
• Legal and regulatory compliance advisors serving clients with activity in the non-EU EEE.

Practical example

A Spanish financial entity with an operating branch in Oslo (Norway) that provides asset management services to local clients must verify that its internal procedures —contracts, client information policies, applicable capital or liquidity requirements— comply with the new requirements incorporated into Annex IX of the EEE Agreement through Decision 296/2025.

Given that the regulation entered into force on 5 December 2025, any operation or contract signed from that date in Norway, Iceland or Liechtenstein must have already been governed by the updated framework. If the internal review has not been carried out, there is a risk of regulatory non-compliance that should be remedied as soon as possible by consulting the full text of the decision and its annexes in the official source.

What should companies do now?

1. Identify if you have regulated financial activity in Norway, Iceland or Liechtenstein. If the answer is yes, this regulation affects you directly from 5 December 2025.
2. Consult the full text of Decision 296/2025 in the Official Journal of the EU to identify which specific European regulations have been incorporated into Annex IX and which affect your specific activity.
3. Review internal regulatory compliance procedures applicable to your operations in non-EU EEE countries, contrasting them with the new requirements incorporated.
4. Update contracts and documentation if the new requirements of Annex IX imply changes in the conditions applicable to clients or counterparties in these markets.
5. Inform compliance and legal teams of the retroactive entry into force (5 December 2025) to assess whether there is any period of exposure to non-compliance that should be managed.
6. Consult with an advisor specialized in EEE financial regulation if activity in these markets is relevant to the business, given that the full text of the decision may imply specific obligations not detailed in the public summary.