EEE Transport 2025: what Spanish companies must do

Key data

Spanish transport companies with operations in Norway, Iceland or Liechtenstein have an active compliance obligation from December 5, 2025. Decision 317/2025 of the EEE Joint Committee amends the Annex XIII on transport of the EEE Agreement, incorporating new European regulation into the legal framework applicable in these three countries. Published in the Official Journal of the EU on April 16, 2026 with reference [2026/600], this decision is already mandatory.

The purpose of the amendment is regulatory harmonization to facilitate the free movement of transport services throughout the European Economic Area. In practice, this means that the rules for operating in those three countries are updated and must be reflected in the operational procedures of any affected company.

What does this regulation establish?

The EEE Agreement extends the European internal market to Norway, Iceland and Liechtenstein. For this to work, the EEE Joint Committee periodically updates the annexes of the Agreement to incorporate new legislation approved by the EU. Annex XIII specifically sets out the transport rules applicable in those three countries.

Decision 317/2025 introduces new European regulation in that annex, which means that transport companies operating in Norway, Iceland and Liechtenstein are subject to the new rules under the same conditions as if they were operating in an EU Member State.

The regulatory harmonization pursued by this decision is relevant for companies because it eliminates regulatory asymmetries: what is valid in the EU must also be valid in these three countries, and vice versa. Any company that has adjusted its operations to European transport regulation has a solid foundation, but must verify that the specific changes incorporated into Annex XIII do not require additional adaptations.

Economic and operational impact

The direct impact of this regulation is operational and compliance-related. This is not a new fee or tax, but an update to the regulatory framework that may involve changes in procedures, documentation, technical requirements or conditions of market access in the three affected countries.

The practical consequences for affected Spanish companies include:

• Review of contracts and service conditions in Norway, Iceland and Liechtenstein to verify that they comply with the new requirements.
• Possible operational adaptations in fleets, routes, documentation or procedures if the new regulation incorporated into Annex XIII so requires.
• Risk of retroactive non-compliance, given that entry into force was December 5, 2025 and official publication occurred on April 16, 2026, which may have created a period of unawareness.
• Market opportunity: harmonization facilitates the free movement of transport services, which may open or consolidate market access for companies that already comply with European regulation.

Who does it affect?

This regulation directly affects:

• Freight transport companies with regular or occasional operations in Norway, Iceland or Liechtenstein.
• Passenger transport companies with routes or services that include these three EEE countries.
• Logistics operators and freight forwarders that manage supply chains with origin or destination in Norway, Iceland or Liechtenstein.
• Spanish companies with subsidiaries or branches in these countries that provide transport services.
• Legal and compliance advisors serving any of the above profiles.
• CFOs and operations directors responsible for managing regulatory risks in companies with cross-border activity in the EEE.

It does not affect companies whose transport activity is limited to EU territory or countries outside the EEE.

Practical example

A Spanish road freight transport company that carries out regular routes between Spain and Norway operates under the EEE Agreement framework. Until December 4, 2025, its operations in Norwegian territory were governed by the previous version of Annex XIII. From December 5, 2025, Decision 317/2025 has updated that framework by incorporating new European regulation.

This company must identify what specific regulation has been incorporated into Annex XIII, assess whether its current procedures already comply with it (by being aligned with current European regulation) or whether it requires specific adaptations for the Norwegian market. If it has not conducted this review since December 2025, it has been in a situation of non-compliance risk for months that should be remedied as soon as possible.

The same scenario applies to operators with routes to Iceland or Liechtenstein, although traffic volume with these two countries is usually lower for most Spanish companies.

What should companies do now?

1. Identify if you have active operations in Norway, Iceland or Liechtenstein. If the answer is yes, this regulation affects you directly.
2. Consult the full text of Decision 317/2025 in the Official Journal of the EU to identify what specific regulation has been incorporated into Annex XIII.
3. Review your operational procedures in those countries in light of the new requirements: documentation, technical conditions, market access, etc.
4. Assess the period of potential non-compliance from December 5, 2025 to today and take corrective measures if necessary.
5. Update contracts and service conditions with customers and partners in Norway, Iceland and Liechtenstein if the new requirements so require.
6. Inform your legal or compliance advisor so they can assess the specific impact on your operations and help you manage the adaptation.