Financial services in the EEA 2026: what changes for companies with activity in Norway, Iceland and Liechtenstein

Key data

Companies with financial activity in the European Economic Area have a new compliance obligation from 20 March 2026. The Decision No. 97/2026 of the EEA Joint Committee amends Annex IX of the EEA Agreement, relating to financial services, and incorporates new European regulation into the legal framework governing Norway, Iceland and Liechtenstein.

The practical effect is direct: any financial entity or company with operations in these three countries must now apply the same rules that govern EU Member States in the amended areas. There is no additional grace period: the decision was adopted on 20 March 2026 and is already in force.

What does this regulation establish?

The Agreement on the European Economic Area (EEA) allows Norway, Iceland and Liechtenstein to participate in the European single market without being EU members. For this to work, the EEA Joint Committee periodically updates the annexes to the Agreement to incorporate current European legislation.

Decision 97/2026 acts on Annex IX, which covers financial services. Through this amendment, the new European financial regulation—already applicable in the 27 EU Member States—becomes mandatory in the three non-EU EEA countries.

The mechanism is standard in EEA functioning: when the EU approves new financial legislation, the Joint Committee incorporates it into the EEA Agreement through decisions like this one, ensuring regulatory homogeneity throughout the expanded single market.

Economic and operational impact

The impact is not abstract. For companies with operations in Norway, Iceland or Liechtenstein, this decision means that regulatory compliance procedures designed for the EU market must be extended or adapted to these three additional markets.

The main vectors of operational impact are:

• Review of internal procedures: compliance and legal departments must verify that processes already implemented for the EU also cover operations in the three non-EU EEA countries.
• Contracts and documentation: agreements with counterparties in Norway, Iceland or Liechtenstein may require updating of regulatory clauses to reflect the new requirements.
• Relationship with local regulators: the supervisory authorities of these countries will have to apply the same standards as their European counterparts, which may result in new reporting or documentation requirements.
• Opportunity for simplification: regulatory harmonization also reduces regulatory asymmetry between jurisdictions, which can simplify management for companies already operating in the EU and EEA simultaneously.

Who does it affect?

• Financial entities (banks, insurers, fund managers, payment entities) with presence or activity in Norway, Iceland or Liechtenstein.
• Non-financial companies with cross-border activity in the EEA that use regulated financial services in these countries (financing, hedging instruments, cross-border payments).
• Business groups with subsidiaries or branches in the three non-EU EEA countries.
• Financial and legal advisors providing services to clients with exposure to the EEA market.
• CFOs and financial directors responsible for regulatory compliance in companies with international operations in the EEA.

Practical example

A Spanish payment entity that operates in Spain (EU) and also provides services in Norway through its European passport must, from 20 March 2026, ensure that the compliance procedures it applies to its Norwegian operations comply with the new requirements incorporated by Decision 97/2026 into Annex IX of the EEA Agreement.

In practice, this means that its compliance team cannot assume that the Norwegian regulatory framework remains static: it must review what specific European regulation has been incorporated into Annex IX through this decision and verify that its internal processes already contemplate it. If the incorporated regulation was already being applied in its EU operations, the adaptation may be minimal. If there were differences in treatment between jurisdictions, it will need to unify them.

What should companies do now?

1. Identify exposure: determine whether the company has direct or indirect financial activity in Norway, Iceland or Liechtenstein that falls within the scope of Annex IX of the EEA Agreement.
2. Review the text of Decision 97/2026: consult the specific European regulation incorporated into Annex IX to understand what specific requirements have been extended to the three EEA countries. The full text is available in the Official Journal of the EU (OJEU).
3. Audit compliance procedures: compare current internal processes with new requirements to identify gaps between what is applied in the EU and what is applied in non-EU EEA operations.
4. Update contracts and documentation: review agreements with counterparties in Norway, Iceland and Liechtenstein to incorporate updated regulatory references.
5. Coordinate with local advisors: contact legal advisors in the affected countries to confirm the local transposition timeline and any additional requirements from national supervisory authorities.
6. Document the adaptation process: maintain a record of the impact analysis and measures taken, as evidence of due diligence in the event of regulatory inspections.

Official source

Consult complete regulation in official source — EUR-Lex OJEU OJ:L_202601269

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_202601269