Energy EEA Annex 2025: what changes for companies in Norway, Iceland and Liechtenstein

Key data

Energy companies with a presence in European Economic Area countries not belonging to the EU have new regulatory obligations from 5 December 2025. The Decision 291/2025 of the EEA Joint Committee modifies the Annex IV on energy of the EEA Agreement, incorporating recent European legislation that is now mandatory also in Norway, Iceland and Liechtenstein.

The decision was adopted on 5 December 2025 and published in the Official Journal on 16 April 2026. If your company operates in the energy sector in any of these three countries, this regulatory change directly affects you.

What does this regulation establish?

The European Economic Area (EEA) Agreement integrates Norway, Iceland and Liechtenstein into the EU internal market without them being formal members of the Union. For this to work, the agreement includes thematic annexes that are updated periodically to incorporate the most recent European legislation.

Annex IV contains the regulations applicable to the energy sector. Decision 291/2025 updates this annex to integrate recent European energy legislation, ensuring that EU rules are applied uniformly throughout the EEA area, beyond EU borders.

The main effects of this update are:

• Extension of the most recent European energy standards to Norway, Iceland and Liechtenstein.
• Obligation of compliance for energy companies operating in these countries.
• Regulatory homogeneity in the EEA energy market.
• Greater legal certainty in cross-border transactions and operations in the European energy sector.

The specific content of the rules incorporated into the annex determines the concrete scope of the obligations. Affected companies must consult the full text of the decision to identify what exact legislation has been integrated.

Economic and operational impact

The direct impact of this decision translates into new regulatory compliance obligations for energy companies active in the three non-EU EEA countries. Although the decision does not establish its own economic sanctions, non-compliance with the rules incorporated into the annex may result in regulatory consequences in each jurisdiction.

From an operational perspective, the main effects are:

• Review of contracts and operational agreements in Norway, Iceland and Liechtenstein to verify their compliance with the new requirements.
• Update of internal compliance procedures in subsidiaries or branches located in these countries.
• Greater legal certainty in cross-border operations within the EEA, when operating under a unified regulatory framework.
• Reduction of regulatory uncertainty for companies operating simultaneously in EU countries and in the three non-EU EEA countries.

Regulatory harmonization also represents an opportunity: companies that already comply with European energy regulations in their EU operations can leverage that compliance as a basis to adapt more quickly to the new requirements in Norway, Iceland and Liechtenstein.

Who does it affect?

This decision directly affects:

• Energy companies with operations in Norway: network operators, distributors, traders and energy producers.
• Energy companies with operations in Iceland: particularly relevant given the weight of the geothermal and energy sector in the Icelandic economy.
• Energy companies with operations in Liechtenstein: companies with activity in this small market integrated into the EEA.
• Companies with cross-border operations between EU countries and the three non-EU EEA countries in the energy sector.
• Legal and compliance advisors providing services to energy sector companies in the EEA area.
• CFOs and operations directors of business groups with energy subsidiaries in these countries, who must ensure consolidated regulatory compliance.

Practical example

A Spanish energy company with a subsidiary in Norway operating in energy distribution must, as of 5 December 2025, verify that its operations in Norwegian territory comply with the requirements of recent European legislation incorporated into Annex IV of the EEA Agreement through Decision 291/2025.

If this company already applies European energy regulations in its operations in Spain and other EU countries, its starting point is favorable: it can use its compliance procedures in the EU as a reference and extend or adapt them to the Norwegian subsidiary. The legal team must identify what specific rules have been incorporated into Annex IV and check whether they generate additional obligations compared to those already being met in the rest of the group.

This same exercise applies to companies with a presence in Iceland or Liechtenstein. The key is not to assume that compliance in the EU automatically equals compliance in the EEA: incorporation into the annex may have specific timelines or conditions for each country.

What should companies do now?

1. Identify exposure: Determine whether your company or any group subsidiary has activity in the energy sector in Norway, Iceland or Liechtenstein.
2. Review the full text of Decision 291/2025: Access the official source to identify what specific European legislation has been incorporated into Annex IV of the EEA Agreement.
3. Assess impact on current operations: Compare the new regulatory requirements with the operational and contractual procedures in force in the affected EEA countries.
4. Update compliance procedures: If gaps are detected between the new requirements and the current situation, design an adaptation plan with specific timelines.
5. Coordinate with local advisors: Given that the implementation of EEA rules may have particularities in each country (Norway, Iceland, Liechtenstein), it is advisable to have local legal advice to validate compliance.
6. Document the adaptation process: Keep a record of the analysis performed and the measures adopted, as evidence of diligence in regulatory compliance.