European Regulations

EEE 2025: What Changes in Financial Services for Banks and Insurance Companies

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Equipo Editorial CambiosLegales
20 Apr 2026 5 min 36 views

Key data

RegulationDecision of the EEE Joint Committee No. 294/2025, of 5 December 2025 [2026/639]
Publication16 April 2026
Entry into force5 December 2025
Affected partiesBanks, insurance companies and investment firms with activity in the EEA (Norway, Iceland, Liechtenstein)
CategoryEuropean Regulation
Non-EU EEA countries affectedNorway, Iceland, Liechtenstein
Modified AnnexAnnex IX (Financial services) of the EEE Agreement
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Banks, insurance companies and investment firms operating in the European Economic Area have a new obligation to adapt. The Decision 294/2025 of the EEE Joint Committee, which entered into force on 5 December 2025, modifies the Annex IX of the EEE Agreement, which is the regulatory framework for financial services for the three EEA countries that do not belong to the EU: Norway, Iceland and Liechtenstein.

The decision was published in the EU Official Journal on 16 April 2026, which means that many entities may already be in breach if they have not reviewed their procedures since December 2025.

What does this regulation establish?

The European Economic Area Agreement allows Norway, Iceland and Liechtenstein to participate in the EU internal market without being member states. For this to work, their regulatory frameworks must remain aligned with EU legislation. Annex IX is the specific chapter that regulates financial services within this agreement.

Decision 294/2025 incorporates into Annex IX new financial regulation approved by the EU, thus updating the legal framework applicable in the three non-EU EEA countries. The objective is to ensure regulatory homogeneity in the enlarged internal market.

ElementDetail
Modified frameworkAnnex IX (Financial services) of the EEE Agreement
Decision-making bodyEEE Joint Committee
Content of the modificationIncorporation of new EU financial regulation into the EEE framework
ObjectiveRegulatory homogeneity in the enlarged internal market
Impact on European passportAffects regulatory equivalence and the financial services passport in Norway, Iceland and Liechtenstein

Economic and operational impact

The impact is not theoretical. Financial entities with presence or cross-border activity in non-EU EEA countries must assume real adaptation costs in three main areas:

  • Review of internal procedures: Operational and compliance processes must be updated to reflect the new requirements incorporated into Annex IX.
  • European passport: The conditions under which an entity provides services in Norway, Iceland or Liechtenstein under the European passport may be modified. It is necessary to verify that current authorizations remain valid.
  • Regulatory equivalence: Entities operating under equivalence regimes must confirm that such equivalence is maintained following the update to Annex IX.

The cost of not acting may be greater than the cost of adapting: operating without complying with the new requirements may result in loss of the European passport or regulatory sanctions in the affected EEA countries.

Who does it affect?

  • Banks with branches, subsidiaries or cross-border activity in Norway, Iceland or Liechtenstein.
  • Insurance companies that operate or distribute products in the three non-EU EEA countries.
  • Investment firms (asset managers, brokers, financial advisory entities) with clients or activity in those territories.
  • Financial entities that use the European passport to provide services in the enlarged EEA.
  • International financial groups with structures that include entities domiciled or regulated in Norway, Iceland or Liechtenstein.
  • Compliance and legal departments of any financial entity with exposure to non-EU EEA.

Practical example

A Spanish fund manager operating in Norway under the European financial services passport must verify that its authorization and marketing procedures remain compliant with the updated Annex IX. If the new EU financial regulation incorporated into Annex IX introduces additional requirements for customer information or risk management, the fund manager will need to update its contracts, documentation and operational processes for the Norwegian market before local regulatory authorities begin compliance inspections.

Similarly, an insurance company with activity in Liechtenstein operating under regulatory equivalence must confirm with its legal team that the conditions of that equivalence have not changed following the modification of Annex IX. If they have changed, it will need to request a new assessment or adapt to the new requirements to maintain market access.

Do you need to monitor this and other regulations?

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What should companies do now?

  1. Identify exposure to non-EU EEA: Determine whether the entity has activity, clients, branches or authorizations in Norway, Iceland or Liechtenstein. If the answer is yes, this regulation is a priority.
  2. Review the current European passport: Verify that the authorizations under which you operate in the three EEA countries remain valid with the updated Annex IX. Contact the legal department or local regulator if in doubt.
  3. Audit compliance procedures: Review internal compliance, risk management and customer information processes to identify possible gaps with respect to the new requirements incorporated into Annex IX.
  4. Update contracts and documentation: If the new requirements affect the contractual relationship with clients in EEA countries, update the corresponding documents (contracts, product sheets, information policies).
  5. Coordinate with local regulators: In case of doubt about the scope of changes in each EEA country, contact local regulatory authorities (Finanstilsynet in Norway, FME in Iceland, FMA in Liechtenstein) to confirm applicable requirements.
  6. Document the adaptations made: Record all measures adopted to demonstrate compliance in the event of a regulatory inspection.

Frequently asked questions

What is Decision 294/2025 of the EEE Joint Committee and who does it affect?

It is the decision that modifies Annex IX of the EEE Agreement, which regulates financial services in European Economic Area countries not belonging to the EU: Norway, Iceland and Liechtenstein. It directly affects banks, insurance companies and investment firms with cross-border activity in those territories.

When does the modification of Annex IX of the EEE Agreement enter into force?

Decision 294/2025 entered into force on 5 December 2025, although it was published on 16 April 2026. Affected entities must comply with the new requirements from that date.



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