Services in the EEA 2025: what changes for Spanish companies in Norway, Iceland and Liechtenstein

Key data

Spanish service sector companies with a presence in Norway, Iceland or Liechtenstein have a regulatory change to review. Decision 306/2025 of the EEA Joint Committee, adopted on 5 December 2025 and published on 16 April 2026, modifies the Annex X of the European Economic Area Agreement, which regulates services in general within the EEA.

The practical effect is direct: the three EEA countries that are not EU members are obliged to transpose and apply the same European services regulation as Spain and the rest of the Member States. This can translate into new market access requirements, but also into new facilities or greater legal certainty for operating in those territories.

What does this regulation establish?

The European Economic Area Agreement extends the EU internal market to Norway, Iceland and Liechtenstein. To keep that integration up to date, the EEA Joint Committee periodically incorporates new EU regulation into the Agreement through decisions such as this one.

Decision 306/2025 incorporates new EU regulation into Annex X of the EEA Agreement, which is the specific annex dedicated to services in general. From its entry into force, Norway, Iceland and Liechtenstein are obliged to:

• Transpose the new service provisions incorporated into Annex X.
• Apply the same rules as EU Member States in the field of services.
• Ensure regulatory coherence in cross-border service transactions within the EEA.

Harmonization strengthens legal certainty for companies operating in these markets, by reducing regulatory differences between EEA countries and EU countries.

Economic and operational impact

The concrete impact for each company depends on the specific provisions incorporated into Annex X and the activity it carries out in non-EU EEA countries. In general terms, this harmonization can have two types of consequences:

Companies already operating in these markets must verify whether the new provisions incorporated into Annex X affect their existing contracts, their service delivery models or their establishment structures in those countries.

Who does it affect?

This regulation is relevant for Spanish companies with activities in the three non-EU EEA countries. Specifically:

• Professional service companies (consulting, engineering, architecture, legal, accounting) with clients or subsidiaries in Norway, Iceland or Liechtenstein.
• Technology and digital service companies that provide cross-border services within the EEA.
• Companies in the tourism, hospitality and leisure sector with operations in these markets.
• Financial services and insurance companies operating under the European passport in non-EU EEA countries.
• Companies evaluating expansion to Norway, Iceland or Liechtenstein and needing to know the updated regulatory framework.
• Legal and tax advisors serving clients with a presence in non-EU EEA.

Practical example

A Spanish engineering services consulting firm that provides services in Norway under the EEA Agreement framework must review whether the new provisions incorporated into Annex X modify the access requirements to the Norwegian market for its specific activity.

If the new regulation incorporated into Annex X harmonizes, for example, the procedures for recognition of professional qualifications or the establishment requirements for service providers, this company will need to:

• Verify whether its current accreditations remain valid under the new framework.
• Check whether there are new administrative procedures with Norwegian authorities.
• Assess whether harmonization opens new access opportunities in Iceland or Liechtenstein where barriers previously existed.

The same analysis applies to any service company with active or negotiated contracts in these three countries: entry into force was on 5 December 2025, so obligations are already enforceable.

What should companies do now?

1. Identify whether your activity falls within the scope of Annex X: Review whether your company provides services in Norway, Iceland or Liechtenstein and whether that activity is covered by Annex X of the EEA Agreement on services in general.
2. Consult the specific provisions incorporated: Access the full text of Decision 306/2025 in the EU Official Journal to identify what specific regulation has been incorporated into Annex X and whether it affects your sector.
3. Evaluate the impact on existing contracts and operations: Check whether active service contracts in these countries need to be adapted to the new provisions, given that entry into force was 5 December 2025.
4. Review market access requirements: Verify with a specialist in European law whether the new rules generate new procedures, accreditations or establishment requirements in Norway, Iceland or Liechtenstein.
5. Take advantage of new facilities if any: Harmonization may remove previous barriers. If your company was considering expanding into these markets, this is the time to assess whether the new regulatory framework facilitates that expansion.