Energy in the EEA 2025: what changes for companies with activity in Norway, Iceland and Liechtenstein

Key data

If your company operates in the energy market and has activity in Norway, Iceland or Liechtenstein, there is a regulatory change that is already in force and that you cannot ignore. The Decision No. 290/2025 of the EEA Joint Committee, adopted on December 5, 2025, amends Annex IV (Energy) of the EEA Agreement, incorporating new European energy regulations into the scope of the Agreement.

The practical result is clear: the three EEA countries that are not EU members—Norway, Iceland and Liechtenstein—are obliged to transpose and apply the same energy rules as any EU Member State. For Spanish energy operators, this has a dual reading: easier market access, but also new demands for regulatory adaptation.

What does this regulation establish?

The Agreement on the European Economic Area (EEA) allows Norway, Iceland and Liechtenstein to participate in the EU internal market without being Member States. To do so, the Agreement contains thematic annexes that are updated periodically to incorporate new European legislation.

Annex IV covers the energy sector. With Decision 290/2025, the EEA Joint Committee—the body responsible for managing and updating the Agreement—has incorporated new European energy regulations into this annex. This means that the EU energy market rules that have been included in this amendment become mandatory in the three non-EU EEA countries as well.

The incorporation of European energy regulations into the EEA Agreement is a routine process, but each update of Annex IV can imply new specific obligations for operators working in those markets. The key is to identify what specific regulations have been incorporated and what new requirements they generate for your activity.

Economic and operational impact

This amendment has two effects that go in opposite directions for Spanish energy companies with presence in the EEA:

Opportunity: Regulatory harmonization reduces divergences between the EU regulatory framework and that of Norway, Iceland and Liechtenstein. This simplifies operations for companies that already work under European regulations, as they do not need to adapt their processes to different rules in each market.

Obligation: At the same time, the incorporation of new energy regulations into the EEA Agreement can generate new compliance requirements. Companies must review whether operations already underway in these countries comply with updated standards, or whether technical, contractual or administrative adjustments are necessary.

The costs of adaptation will depend on the specific European energy regulations that have been incorporated into Annex IV with this decision, and the degree of divergence that previously existed between the rules applied in those countries and the new harmonized requirements.

Who does it affect?

This decision directly affects:

• Spanish energy sector companies with operations in Norway, Iceland or Liechtenstein
• Operators that export energy or energy services to these three countries
• Companies that participate in the wholesale energy market of the EEA
• Energy infrastructure operators (networks, storage, generation) with presence in non-EU EEA countries
• Legal advisors and compliance professionals providing services to energy companies with activity in the EEA
• CFOs and operations directors of energy groups with subsidiaries or contracts in Norway, Iceland or Liechtenstein

Companies that operate exclusively in Spain or in other EU Member States are not directly affected by this decision, as European energy regulations already applied to them.

Practical example

A Spanish energy trading company that has supply contracts with industrial customers in Norway must review whether the conditions of those contracts and the associated operating procedures comply with the new requirements of the European energy regulations incorporated into Annex IV of the EEA Agreement through Decision 290/2025.

Before this decision, Norway could apply its own rules in aspects not covered by the EEA Agreement. Following the amendment, those aspects are harmonized with EU regulations. If the Spanish company already operated under European standards, the adaptation may be minimal. If there were differences between the previous Norwegian framework and the new harmonized framework, it will be necessary to review contracts, billing procedures, information requirements or technical supply conditions.

The same analysis applies to operators with activity in Iceland or Liechtenstein: the entry into force on December 5, 2025 marks the point from which the new standards are enforceable, so any operation initiated or renewed from that date must comply with the harmonized framework.

What should companies do now?

1. Identify if you have activity in Norway, Iceland or Liechtenstein: If you operate, export or have energy contracts in any of these three countries, this decision directly affects you.
2. Consult the official text of Decision 290/2025: Access the reference OJ:L_202600629 in EUR-Lex to identify what specific European energy regulations have been incorporated into Annex IV of the EEA Agreement.
3. Review compliance of your current operations: Compare the requirements of the new regulations incorporated with the procedures, contracts and technical conditions you apply in those markets from December 5, 2025.
4. Detect adaptation gaps: If there are differences between what you were already doing and the new harmonized standards, prioritize adjustments according to regulatory risk and the volume of affected activity.
5. Update contracts and documentation if necessary: Supply contracts, network access or energy service provision in non-EU EEA countries may require updated clauses to reflect the new regulatory framework.
6. Involve your legal advisor specialized in European energy regulations: Precise identification of specific obligations arising from this amendment requires analysis of the decision text and incorporated regulations.