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

Key data

Companies and financial entities operating between Spain and non-EU EEE countries —Norway, Iceland and Liechtenstein— have a new compliance review obligation on the table. The Decision 303/2025 of the EEE Joint Committee, adopted on 5 December 2025, modifies Annex IX of the EEE Agreement, which regulates financial services in the European Economic Area, incorporating new EU regulations into the common legal framework.

The practical effect is clear: the rules of the financial game in those three countries are updated to remain aligned with European ones. If your company has products, contracts or compliance structures that affect those markets, now is the time to verify that everything is in order.

What does this regulation establish?

The European Economic Area Agreement allows Norway, Iceland and Liechtenstein to participate in the European single market without being EU members. For this to work, these countries must apply rules equivalent to European ones in key areas such as financial services. The mechanism to achieve this is precisely the periodic updating of the annexes to the EEE Agreement.

Annex IX is the one that contains all regulations relating to financial services. When the EU approves new financial legislation, the EEE Joint Committee —the body that manages the relationship between the EU and non-EU EEE countries— must formally incorporate it into that annex through a decision.

Decision 303/2025 does exactly that: it incorporates new EU financial regulations into Annex IX, ensuring that Norway, Iceland and Liechtenstein apply rules equivalent to European ones in financial matters. The decision was adopted on 5 December 2025 and published in the Official Journal of the EU on 16 April 2026.

Economic and operational impact

The impact of this decision is not a new burden in the strict sense, but rather an update of the regulatory framework that already applies in EEE markets. However, it has concrete operational consequences for companies operating in those territories:

• Review of regulatory compliance procedures: Financial entities operating in Norway, Iceland or Liechtenstein must adapt their internal processes to the new rules incorporated into Annex IX.
• Review of cross-border financial contracts: Contracts or financial products operating between Spain and non-EU EEE countries may be affected if the new rules modify conditions, information requirements or product structures.
• Regulatory homogeneity as an advantage: For companies already operating under EU regulations, the alignment of rules in EEE countries simplifies compliance management, as they do not need to maintain differentiated frameworks.
• Adaptation cost: The summary of the regulations does not specify concrete adaptation amounts, but the review of contracts and procedures involves time and internal or external advisory resources.

Who does it affect?

This decision primarily affects:

• Spanish financial entities with subsidiaries, branches or direct activity in Norway, Iceland or Liechtenstein.
• Non-financial companies with financing contracts, investment products or treasury structures involving counterparties in non-EU EEE countries.
• CFOs and financial directors of business groups with presence in the EEE who must ensure regulatory compliance in those markets.
• Legal advisors and compliance consultants providing services to clients with operations in Norway, Iceland or Liechtenstein.
• Fund managers and investment entities that distribute or manage financial products within the EEE.

Practical example

A Spanish financial entity that distributes investment products in Norway through a cross-border distribution agreement currently has its compliance procedures adapted to the EU regulations in force until the date of Decision 303/2025.

With the entry into force of this decision on 5 December 2025, Annex IX of the EEE Agreement incorporates new EU financial regulations. This means that the rules applicable in Norway are updated. The Spanish entity must:

1. Identify what specific EU regulations have been incorporated into Annex IX through this decision.
2. Verify whether that regulation affects the products it distributes in Norway.
3. Review distribution contracts and product documents to ensure they comply with the new equivalent rules.
4. Update its internal compliance procedures if necessary.

If the entity does not carry out this review and continues to operate under the previous framework, it assumes the risk of regulatory non-compliance in the Norwegian market, with the regulatory consequences that this may imply before local supervisory authorities.

What should companies do now?

1. Identify exposure: Determine whether your company has contracts, products or financial activity in Norway, Iceland or Liechtenstein that may be affected by the update to Annex IX.
2. Consult the full text of Decision 303/2025: Access the official source in the Official Journal of the EU to identify exactly what EU financial regulations have been incorporated into Annex IX.
3. Review regulatory compliance procedures: Update internal compliance processes to reflect the new rules applicable in non-EU EEE markets.
4. Review cross-border financial contracts and products: Verify that existing contracts and financial products operating in those markets remain compliant with the new regulatory framework.
5. Coordinate with local advisors: If activity in Norway, Iceland or Liechtenstein is relevant, involve local legal advisors to confirm the specific impact of the new rules in each jurisdiction.
6. Document the review: Keep internal records that the impact analysis has been carried out, as evidence of due diligence in the event of possible inspections or audits.