New financial regulations in the EEA 2026: what companies with operations in Norway, Iceland and Liechtenstein must do

Key data

If your company operates in the financial sector in Norway, Iceland or Liechtenstein, or if you have products, contracts or compliance structures linked to these markets, this decision is already in force and requires action. The Decision 175/2026 of the EEA Joint Committee, adopted on June 5, 2026 and published on September 24, 2026, amends Annex IX of the EEA Agreement, which regulates financial services in the European Economic Area.

The practical effect is clear: the three EEA countries that are not EU members are obliged to incorporate the new EU financial regulations recently adopted into their domestic legal systems. For Spanish companies, this translates into regulatory homogeneity across the EEA, but also into the need to review whether their operations in these markets comply with the new standards.

What does this regulation establish?

The EEA Agreement allows Norway, Iceland and Liechtenstein to participate in the European single market without being EU members. To do so, they must incorporate relevant EU legislation through decisions of the EEA Joint Committee, the body that manages the continuous updating of this regulatory framework.

Decision 175/2026 updates Annex IX of the EEA Agreement, which is the specific annex dedicated to financial services. Through this amendment, the EU financial regulations recently adopted are incorporated into the EEA framework, with direct effect in the legal systems of the three non-EU EEA countries.

This incorporation mechanism is standard in EEA operations: whenever the EU approves new legislation in areas covered by the EEA Agreement, the Joint Committee formally integrates it so that the three non-EU countries apply it in their jurisdictions.

Economic and operational impact

For Spanish companies, the impact materializes in three distinct areas:

• Regulatory homogeneity: The new EU financial regulations will be applied equivalently in Norway, Iceland and Liechtenstein, which facilitates operating under a common framework throughout the EEA. This can simplify compliance management for companies already operating in multiple jurisdictions across the European area.
• Adjustment of contracts and products: Financial contracts, investment products or distribution structures operating under the legislation of these three countries may require modifications to align with the new requirements incorporated into Annex IX.
• Review of compliance structures: The compliance, legal and risk areas of entities with presence in the EEA must verify that their internal procedures reflect the new standards, given that the decision takes direct effect from June 5, 2026.

The cost of adaptation will depend on the degree of exposure of each company to the markets of Norway, Iceland and Liechtenstein, and on the nature of the specific changes introduced by the new EU legislation incorporated into Annex IX. No specific penalty amounts have been published in the analyzed decision.

Who does it affect?

• Financial entities (banks, insurance companies, fund managers, intermediaries) with activity in Norway, Iceland or Liechtenstein.
• Spanish companies that market financial products or services in any of the three non-EU EEA countries.
• CFOs and financial directors of business groups with subsidiaries or active contracts in these markets.
• Legal advisors and regulatory compliance professionals providing services to clients with EEA exposure.
• Compliance and risk departments of supervised entities operating in the EEA sphere.
• Law firms and consulting firms specializing in European financial regulation advising clients in these markets.

Practical example

A Spanish fund manager that distributes investment products in Norway through a local distribution agreement has, as of June 5, 2026, the obligation to verify that this agreement and the distributed products comply with the new financial requirements incorporated into Annex IX of the EEA Agreement by Decision 175/2026.

If the new EU legislation incorporated into Annex IX modifies, for example, the requirements for client information or the conditions for marketing certain financial instruments, the fund manager will need to update its contracts with the Norwegian distributor, review product documents and ensure that its compliance procedure reflects the new standards. Non-compliance could result in sanctions from the Norwegian regulator, which is already required to apply these regulations in its jurisdiction.

What should companies do now?

1. Identify EEA exposure: Map which contracts, products, subsidiaries or commercial agreements are linked to Norway, Iceland or Liechtenstein in the financial services sphere.
2. Review existing contracts: Analyze whether active financial contracts in these markets include regulatory adaptation clauses or require renegotiation in light of the new Annex IX requirements.
3. Update compliance procedures: Verify that internal manuals, policies and compliance controls reflect the new standards applicable in the three EEA countries from June 5, 2026.
4. Consult the incorporated EU legislation: Identify which specific EU financial regulations have been integrated into Annex IX through this decision, accessing the full text in the Official Journal of the EU.
5. Coordinate with local advisors: Contact legal advisors in Norway, Iceland or Liechtenstein to confirm national transposition deadlines and specific requirements of each local regulator.
6. Establish a regulatory alert system: Given that the EEA Joint Committee updates Annex IX periodically, implement a continuous monitoring mechanism to anticipate future amendments.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202602013