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

Key data

If your company provides or receives financial services in Norway, Iceland or Liechtenstein, this decision directly affects you. Decision No. 95/2026 of the EEA Joint Committee amends Annex IX of the EEA Agreement, relating to financial services, and incorporates new EU regulation into the legal framework of European Economic Area countries that are not EU members. The objective is to maintain regulatory homogeneity between the EU and these three countries, but the practical consequence for companies is that the rules of the game change and adaptation is necessary.

The entry into force date is 20 March 2026, although publication in the Official Journal occurred on 25 June 2026. This means that the adaptation period has already begun and, in some cases, may have already passed.

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 full members. For this to work, these countries must incorporate EU regulation into their legal systems through decisions of the EEA Joint Committee.

Decision 95/2026 updates Annex IX of the EEA Agreement, which is the specific annex dedicated to financial services. With this modification:

• Updated EU financial provisions are incorporated into the EEA framework.
• Norway, Iceland and Liechtenstein are obliged to transpose and apply these new provisions in their national legal systems.
• Financial entities operating in these markets must review their regulatory compliance in accordance with the new incorporated requirements.
• Regulatory homogeneity between the EU and EEA countries in financial matters is strengthened.

In practical terms, this decision acts as a continuous update mechanism: whenever the EU approves new financial regulation, the EEA Joint Committee transfers it to the EEA Agreement through decisions like this one, ensuring that the rules are equivalent on both sides.

Economic and operational impact

The direct impact depends on the volume and type of financial activity your company develops in the three affected countries. The main impact vectors are:

• Review of financial contracts and products: If you market financial products in Norway, Iceland or Liechtenstein, you must verify that they comply with the new requirements incorporated into Annex IX.
• Update of compliance procedures: Compliance and legal departments will need to update their risk matrices and internal procedures to reflect the new provisions.
• Cross-border operations: Spanish companies providing cross-border financial services to these countries may see affected market access conditions or authorization requirements.
• Coordination with local partners: Financial entities with subsidiaries or partners in these countries will need to coordinate regulatory adaptation with their local teams.

The regulation does not establish direct economic sanctions in the text of the decision, but non-compliance with the incorporated financial provisions may result in administrative sanctions in accordance with the local regulation of each affected EEA country.

Who does it affect?

• Spanish financial entities with branches, subsidiaries or cross-border activity in Norway, Iceland or Liechtenstein.
• Banks and credit institutions operating under European passport in non-EU EEA markets.
• Investment services companies providing services in the three affected countries.
• Insurance and reinsurance companies with activity in the EEA outside the EU.
• Investment funds and management companies distributing products in Norway, Iceland or Liechtenstein.
• CFOs and financial directors of business groups with operations in these markets.
• Legal advisors and regulatory compliance specialists serving companies with presence in the EEA.

Companies operating exclusively in the Spanish market or in other EU countries are not directly affected by this decision.

Practical example

A Spanish fund management company that distributes its products in Norway through the European passport must, following the entry into force of Decision 95/2026, verify that the new financial provisions incorporated into Annex IX of the EEA Agreement do not modify the marketing requirements, documentation or information to investors applicable in that market.

If EU regulation incorporated into Annex IX introduces, for example, new disclosure requirements or product classification requirements, the management company will need to update its brochures, contracts and internal procedures to comply with the updated version of the EEA framework before continuing to operate in Norway. Non-compliance could result in suspension of the passport or sanctions by the Norwegian regulator.

This same scheme applies to any Spanish financial entity with activity in Iceland or Liechtenstein: the update of Annex IX is the starting point for a compliance review that cannot be postponed, given that entry into force already occurred on 20 March 2026.

What should companies do now?

1. Identify exposure: Determine whether your company provides or receives financial services in Norway, Iceland or Liechtenstein, either directly or through subsidiaries, branches or distribution agreements.
2. Review the updated Annex IX: Access the full text of Decision 95/2026 and Annex IX of the EEA Agreement to identify which specific EU provisions have been incorporated and whether they affect your activity.
3. Audit current compliance: Compare the new requirements with your current procedures, contracts and products to detect possible compliance gaps.
4. Coordinate with local teams: If you have local presence in the affected countries, involve your legal and compliance teams in each jurisdiction to assess the impact of national transposition.
5. Update documentation and procedures: Adapt contracts, brochures, internal policies and risk matrices to the new requirements before continuing to operate in the affected markets.
6. Consult with a specialized advisor: Given that the decision entered into force on 20 March 2026, if you have not yet initiated the review, prioritize consultation with a specialist in European financial regulation to assess the risk of retroactive non-compliance.

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_202601270