EEE and Financial Services 2025: What Changes for Banks and Insurance Companies

Key data

Banks, insurance companies and fund managers operating in the European Economic Area have a new regulatory review obligation. Decision 295/2025 of the EEE Joint Committee, adopted on 5 December 2025 and published on 16 April 2026, amends Annex IX of the EEE Agreement, which regulates financial services in the three EEE countries not belonging to the EU: Norway, Iceland and Liechtenstein.

The objective is to ensure that the financial regulatory framework of these three countries remains aligned with EU regulation, ensuring the homogeneity of the enlarged financial internal market. For entities with cross-border activity, this translates into a mandatory review of internal procedures and compliance frameworks.

What does this regulation establish?

The European Economic Area Agreement allows Norway, Iceland and Liechtenstein to participate in the EU internal market without being member states. For this to work, their legislation must be updated periodically to incorporate current European regulation.

Annex IX of the EEE Agreement is the chapter specifically dedicated to financial services. When the EU approves new financial regulation, the EEE Joint Committee must decide whether and how to incorporate it into this annex so that it also applies in the three non-member countries.

Decision 295/2025 does exactly that: it incorporates new EU regulation into Annex IX, updating the provisions governing cross-border financial activity in the EEE. Entities operating in these markets must adapt their procedures to the new incorporated provisions.

Economic and operational impact

The direct impact of this decision is not a new fee or automatic penalty: it is an obligation to review and adapt regulatory compliance frameworks for operations in the three affected countries.

For financial entities with presence or cross-border activity in Norway, Iceland or Liechtenstein, this involves operational costs associated with:

• Review of internal compliance procedures to align them with the new provisions of Annex IX.
• Update of contracts, policies and regulatory documentation applicable in the three countries.
• Possible review of European passport structures or cross-border financial product distribution agreements.
• Coordination with legal and compliance teams in the jurisdictions of Norway, Iceland and Liechtenstein.

The risk of not acting is not only regulatory: entities that do not adapt their procedures may face restrictions on access to the enlarged financial internal market in these three countries.

Who does it affect?

Decision 295/2025 directly affects the following entities:

• Banks with operations, subsidiaries, branches or cross-border activity in Norway, Iceland or Liechtenstein.
• Insurance companies that distribute products or provide services in these three non-EU EEE countries.
• Fund managers with investment vehicles registered or distributed in the enlarged EEE.
• Compliance and regulatory departments of any financial group with exposure to the EEE.
• CFOs and financial directors of entities with cross-border activity in the enlarged financial internal market.
• Legal advisors and regulatory compliance consultants providing services to financial entities with presence in the EEE.

Practical example

A Spanish fund manager that distributes its products in Norway through the European passport must verify that its marketing procedures and regulatory documentation remain compliant with the updated Annex IX of the EEE Agreement.

If the new EU regulation incorporated into Annex IX affects, for example, investor information requirements or cross-border distribution conditions, the fund manager will need to update its documentation, review contracts with local distributors and notify changes to Norwegian supervisory authorities if required by the new incorporated regulation.

The same applies to a bank with a branch in Iceland or an insurance company operating in Liechtenstein: the starting point is to identify what specific EU regulation has been incorporated into Annex IX and assess whether its current procedures comply with it. The review should begin now, given that the entry into force date was 5 December 2025.

What should companies do now?

1. Identify exposure to non-EU EEE: Determine whether the entity has activity, distribution or presence in Norway, Iceland or Liechtenstein. If there is no exposure, the impact is null.
2. Review the updated Annex IX: Consult the full text of Decision 295/2025 to identify what EU regulation has been incorporated and whether it affects the entity's products or services.
3. Audit current compliance frameworks: Compare current internal procedures with the new provisions incorporated into Annex IX and identify compliance gaps.
4. Update documentation and procedures: Adapt contracts, internal policies, regulatory documentation and operational processes to the new requirements in the three affected countries.
5. Coordinate with local advisors: Involve legal teams or consultants specialized in the jurisdictions of Norway, Iceland and Liechtenstein to validate the adaptation.
6. Document the adaptation process: Maintain a record of the impact analysis and measures adopted, as evidence for potential supervisory reviews.