Doing Business In... 2026

Last Updated July 16, 2026

Norway

Law and Practice

Author



LexOslo is a Norwegian boutique business law firm based in Oslo. The firm advises corporates, investors, banks and other financial undertakings on business law matters in Norway, with a particular focus on finance law and international business in Norway. Its work includes transactions, regulatory questions, commercial matters and disputes, often where Norwegian law must be understood in a broader commercial or cross-border context. LexOslo was founded by attorney Harald Sætermo and reflects a practice developed over more than 25 years in private practice and senior in-house legal roles in the banking sector. The firm’s boutique format allows for direct senior involvement, continuity and close attention to the client’s business and legal position. For international clients, LexOslo provides advice grounded in Norwegian law, market practice and practical commercial judgement. The firm’s approach is focused and personal, with an emphasis on clear responsibility, efficient execution and legal advice that supports sustainable business growth.

Norway is a civil law jurisdiction. Legislation, including Acts of Parliament and secondary regulations, is the primary source of law, but preparatory works, case law and treaty obligations are also important legal sources. Although Norway is not a common law jurisdiction, Supreme Court judgments carry significant precedential weight and are generally followed by lower courts.

The ordinary courts are organised in three tiers. The Supreme Court is Norway’s highest court and serves as the final court of appeal in civil and criminal matters. It consists of 20 justices and is headed by the Chief Justice. Together with the Norwegian Parliament (the Storting) and the government, the Supreme Court is one of Norway’s highest constitutional bodies.

The courts of appeal hear appeals in civil and criminal cases from the district courts and land consolidation courts within their respective geographical jurisdictions. There are six courts of appeal in Norway.

The district courts are the ordinary courts of first instance. Norway has 28 district courts, operating across a total of 59 court locations. They hear both civil and criminal cases. In 2025, the average case processing time for civil disputes before the district courts was 5.3 months.

For many civil disputes, Norway’s Conciliation Boards serve as the first step and primarily function as mediation bodies.

Norway also has certain specialised courts and court-like bodies, such as the Labour Court, which handles disputes between parties to collective agreements concerning such agreements, and the land consolidation courts, which deal with matters relating to property boundaries and rights in real property. Norwegian courts are independent, and judges cannot be instructed on how to decide individual cases. The courts may also review the constitutionality of legislation and the legality of administrative decisions in cases brought before them.

In addition, there are administrative appeals boards, such as the Immigration Appeals Board and the Tax Appeals Board, as well as private, industry-based dispute resolution bodies, such as the Norwegian Financial Services Complaints Board.

Although Norway is not a member of the EU, EU law has a substantial practical impact through the Agreement on the European Economic Area (the “EEA Agreement”). The EEA Agreement extends the EU internal market to Norway, Iceland and Liechtenstein and covers areas such as the four freedoms, establishment rights, competition law and a substantial body of EU secondary legislation. EEA-relevant EU acts are incorporated into the EEA Agreement and implemented in Norwegian law, typically through legislation or regulations. Norwegian provisions implementing EEA obligations prevail over conflicting Norwegian provisions regulating the same matter. Norwegian courts place considerable weight on relevant case law from both the Court of Justice of the European Union and the European Free Trade Association (EFTA) Court. A distinctive feature of the EEA system is its two-pillar structure: Norway remains outside the EU institutions but is subject to parallel EEA supervision through the EFTA Surveillance Authority and judicial oversight by the EFTA Court.

Norway does not currently have a general foreign investment approval regime applying to all acquisitions of Norwegian businesses. Foreign investors may generally establish companies, acquire shares and operate in Norway on the same basis as Norwegian investors, subject to ordinary corporate, tax, employment, competition and sector-specific rules.

The Norwegian Security Act

The main investment screening rules are found in the Norwegian Security Act. These rules are directed at national security risks and apply to acquisitions of qualified ownership interests in undertakings that are subject to ownership control under Chapter 10 of the Act, typically because their activities, information, infrastructure or systems are important to fundamental national functions or national security interests. The scope is target-specific and may include businesses in areas such as defence, telecommunications, digital infrastructure, energy, transport, finance, space or other critical infrastructure, depending on the target’s role.

Under the current ownership control rules, notification is required where an acquirer obtains a qualified ownership interest in an undertaking subject to the Security Act, generally at least one third of the share capital, ownership interests or voting rights, or significant influence by other means. The filing is made to the competent ministry or, where the undertaking does not fall within any ministry’s area of responsibility, to the Norwegian National Security Authority. The regime applies to both Norwegian and foreign acquirers, although foreign ownership, state links, connections to high-risk jurisdictions and access to sensitive assets will often be relevant to the assessment.

The authorities may approve the transaction, impose conditions or prohibit it if it presents a not insignificant risk to national security interests. They may also intervene outside the mandatory filing regime where a transaction or activity threatens national security.

Amendments to the Security Act adopted in 2023 have partly entered into force. In particular, the basis for making undertakings subject to the Act, or to the ownership control rules in Chapter 10, has been expanded to include undertakings of decisive or significant importance to national security interests, even without a direct link to a fundamental national function. However, key Chapter 10 changes to the ownership control regime – including a 10% filing threshold, additional filing triggers, notification obligations for sellers and target undertakings in certain cases, a standstill obligation and restrictions on sharing sensitive information before closing – have not yet entered into force at the time of writing (July 2026). Investors should therefore verify the current position before signing and closing sensitive transactions.

Proposed Investment Control Act

A government-appointed committee has also recommended that Norway consider introducing a separate Investment Control Act, noting that the current Norwegian system is relatively narrow and fragmented. If pursued, such reform may result in a broader and more systematic sector-based screening regime for foreign investments, more closely aligned with European FDI screening developments.

Regulated Sectors

Separate approval or licensing requirements may apply in regulated sectors, including financial services, petroleum, energy and hydropower, fisheries and aquaculture. Norway is not an EU member state but participates in the EU internal market through the EEA Agreement. This supports a generally open investment regime, subject to proportionate restrictions based on national security or sector-specific regulatory objectives.

Norway does not have a single foreign investment authority for all foreign acquisitions. The investor must first determine whether the target is subject to the Norwegian Security Act or to sector-specific approval rules. This is normally assessed through due diligence into the target’s activities, licences, public-sector contracts, security classifications, customers, ownership structure and assets.

For acquisitions covered by the ownership control rules in the Security Act, the notification is submitted to the ministry responsible for the relevant sector or, if no ministry is responsible, to the Norwegian National Security Authority. The filing should describe the acquirer, the target, the transaction, the ownership chain and the security relevance of the target’s activities. The authority may request further information.

The review is based on national security considerations. The authority considers whether the acquisition may create a not insignificant risk that national security interests will be threatened. Under the current rules, the authority must normally inform the acquirer within 60 working days whether the acquisition is approved or referred to the government for further consideration. If further information is requested within the statutory period, the timeline may be suspended until the acquirer’s response is received.

The authorities may approve the transaction, impose conditions or prohibit it. Investors should confirm the rules in force at signing and closing and, where applicable, make approval a closing condition.

If a transaction is completed without required approval, or if it gives rise to national security concerns, the authorities may order remedial measures and, in serious cases, require the transaction not to be implemented or impose conditions. Criminal liability may apply for breach of orders or prohibitions issued under the Security Act, including under Sections 2-5 or 10-3. Adopted amendments, not yet fully in force, will introduce administrative fines for intentional or negligent breaches of the notification obligation once the relevant provisions enter into force. Sector-specific regimes, for example in financial services, petroleum, hydropower, fisheries and aquaculture, have their own procedures and sanctions.

The Norwegian authorities may approve a transaction subject to commitments where identified risks can be mitigated. In the foreign investment context, such commitments are most relevant under the Norwegian Security Act and in regulated sectors requiring licences or ownership approvals.

Under the Security Act, commitments are directed at national security concerns. They are not normally used to require foreign investors to give broad economic undertakings, such as maintaining a particular level of employment or investment in Norway merely because the acquirer is foreign.

Possible commitments may include restrictions on access to classified or sensitive information, requirements for Norwegian or security-cleared personnel in certain functions, ring-fencing of sensitive business areas, restrictions on information flows to the acquirer or its affiliates, enhanced cybersecurity and physical security measures, governance arrangements limiting influence over sensitive operations, and reporting obligations to the authorities.

Where the target operates critical infrastructure or provides services important to fundamental national functions, the authorities may also focus on continuity of supply, localisation of key systems or functions, resilience arrangements, emergency preparedness and the ability of Norwegian authorities to exercise supervision.

In sector-specific regimes, commitments depend on the relevant legislation. Financial-sector approvals may include requirements relating to the suitability and financial strength of the owner, governance and group structure. Energy, petroleum, hydropower, fisheries and aquaculture approvals may include licence-specific obligations, ownership limitations or conditions designed to safeguard resource management, security of supply or regulatory oversight.

If the authority considers that the risk cannot be adequately mitigated through commitments, the transaction may be prohibited.

The available remedies depend on the legal basis for the decision and the authority making it. Where an administrative appeal is available under general Norwegian administrative law, the ordinary appeal deadline is three weeks from receipt of the decision. The appeal is normally submitted to the authority that made the decision, and the written decision should state the applicable appeal route and deadline.

Under the current ownership control regime in the Norwegian Security Act, decisions are made within the sector-based administrative structure. Decisions may be made by the relevant sector ministry, with any administrative appeal generally handled by the government. Where the final decision is made by the government, administrative appeal will be limited in practical terms.

The validity of administrative decisions may generally be challenged before the ordinary courts. Norway does not have separate administrative courts for this type of case. Judicial review generally concerns the legal and factual basis for the decision, rather than the administration’s discretionary assessment. The courts decide whether the decision is valid or invalid, but do not make a new decision on the merits. In cases involving national security, classified information or sensitive state interests, access to evidence and the intensity of review may be affected by ordinary procedural rules on protected information.

The most common corporate vehicle in Norway is the private limited liability company, or aksjeselskap (AS). An AS is a separate legal entity, and the shareholders’ liability is limited to their contribution to the share capital. The minimum share capital is NOK30,000, which makes the AS accessible and flexible for most commercial purposes.

An AS may be established by one or more shareholders. Its main corporate bodies are the general meeting and the board of directors. The general meeting exercises shareholder authority, while the board is responsible for the management and supervision of the company. A general manager may be appointed and is common in operating companies. The AS is the standard form for Norwegian subsidiaries of foreign groups, holding companies, greenfield projects, private M&A transactions and many joint ventures.

A public limited liability company, or allmennaksjeselskap (ASA), is also a separate legal entity with limited shareholder liability, but is subject to more extensive governance and capital rules. The minimum share capital is NOK1 million. A Norwegian company whose shares are admitted to listing on a regulated market in Norway must be organised as an ASA. It is therefore normally used for listed companies, companies preparing for an IPO, or businesses requiring access to the public equity capital markets. For ordinary private investments, an ASA is usually unnecessary.

Foreign companies may also operate in Norway through a Norwegian branch of a foreign enterprise, commonly referred to as an NUF. An NUF is not a separate legal entity from the foreign company. The foreign company remains liable for the branch’s obligations, and the branch is registered in Norway to obtain a Norwegian organisation number and conduct business. Foreign companies carrying on commercial activity in Norway are generally required to register in the Register of Business Enterprises, and there is no Norwegian equity requirement for establishing an NUF. An NUF may be suitable for temporary activity, early-stage market entry or projects where the investor does not wish to incorporate a Norwegian subsidiary, but it is less commonly used for acquisitions or substantial local operations.

Norwegian law also recognises partnerships. A general partnership, ansvarlig selskap (ANS), involves unlimited joint and several liability for the partners. In a partnership with divided liability, selskap med delt ansvar (DA), each partner has unlimited pro rata liability for an agreed share of the obligations. A limited partnership, kommandittselskap (KS), has at least one general partner with unlimited liability and one or more limited partners whose liability is limited to their committed contribution. KS structures are specialised and may be used in investment, shipping, real estate or project structures where tax, accounting or investor allocation considerations make a partnership vehicle appropriate.

For most foreign investors, the practical choice is between incorporating an AS and registering an NUF. The AS is normally preferred where the investor intends to conduct continuing business in Norway, employ personnel, hold assets, enter into local contracts or acquire a Norwegian target.

Procedure

The incorporation process in Norway is relatively straightforward and largely digital. For most foreign investors, the relevant vehicle will be a private limited liability company, or AS.

An AS may be founded by one or more individuals or legal entities. The company must have a Norwegian business address. The main steps are to choose a company name, prepare and sign the incorporation document, including the articles of association, appoint the board of directors, and subscribe for the shares. An AS must have share capital of at least NOK30,000. The share capital must be fully paid before the company is registered.

Where the contribution is made in cash, payment will normally be confirmed by a bank, auditor, lawyer or authorised accountant. If all or part of the contribution consists of assets other than cash, additional documentation is required, including a statement on the contribution and auditor confirmation, and the process will usually take longer.

The company is incorporated when the incorporation document has been signed and the shares have been subscribed for. It must, however, be registered in the Norwegian Register of Business Enterprises before it can operate as a fully registered company. Registration is normally submitted electronically through Altinn (an online portal for communication between businesses, private individuals and public agencies) to the Register Centre in Brønnøysund and signed electronically by the relevant signatories. Where foreign founders or role holders lack Norwegian electronic identification or D-numbers (which are temporary Norwegian identification numbers issued to those who do not qualify for a permanent one), additional steps or alternative filing procedures may be required. Once registration has been processed, the company receives a Norwegian organisation number, which is required for most practical purposes, including banking, tax registrations, contracts and employment.

The registration notification must be received by the Register of Business Enterprises within three months after the incorporation document has been signed. Registration is not a validity requirement for incorporation, but before registration the company has only limited capacity to acquire rights or incur obligations, except for obligations arising from the incorporation document or by law.

The process for incorporating a public limited liability company, or ASA, follows the same broad structure, but an ASA must have share capital of at least NOK1 million and its name must include the designation “ASA” or “allmennaksjeselskap”. ASA incorporations are more formalised and will normally be relevant only where the company is intended for listing, an IPO or public equity capital market access.

Partnerships are established on the basis of a partnership agreement and must have at least two partners. Both individuals and legal entities may be partners, and the partnership must have a Norwegian business address. A general partnership (ANS) or partnership with divided liability (DA) must be registered to obtain a Norwegian organisation number.

A Norwegian branch of a foreign enterprise, or NUF, is not incorporated as a separate Norwegian legal entity. The process consists of registering the Norwegian branch of the foreign company. This normally requires documentation from the foreign company’s home jurisdiction, including evidence of registration, together with the Norwegian registration form and any required documentation for persons holding registered roles.

Timing

For a simple AS with Norwegian electronic IDs or D-numbers for the relevant signatories and cash share capital, incorporation can often be completed within a few working days after the documents and capital confirmation are ready. For foreign investors, timing often depends less on the corporate registration itself and more on practical steps such as applying for Norwegian D-numbers, where required, and providing supporting identity documentation for foreign individuals who will sign filings or hold registered roles, completing bank KYC procedures, documenting foreign corporate founders and arranging capital payment. Contributions in kind, regulated activities, ASA incorporations or complex governance arrangements may also extend the timeline. As a practical matter, a straightforward AS is often established within one to two weeks, but more complex or cross-border establishments should allow additional time.

Corporate Registration and Governance

Private Norwegian companies are subject to several ongoing filing and reporting obligations, but they are not subject to the continuous market disclosure rules that apply to listed companies. For ordinary private companies, the key obligations relate to registration matters, annual accounts, annual tax returns, shareholder reporting and beneficial ownership. Additional VAT, payroll, employer, sector-specific and event-based reporting obligations may apply depending on the company’s activities, registrations, employees, industry and specific events.

A private limited liability company, or AS, must keep its registered information up to date in the Norwegian Register of Business Enterprises. Changes to the board of directors, general manager, business address, auditor, signature rights, powers of procuration and other registered matters must be filed. Amendments to the articles of association must also be registered. Certain corporate events, such as share capital increases or reductions, mergers, demergers, dissolutions and liquidations, require registration before they take effect or as part of the implementation process.

Accounts, Shareholder and Beneficial Ownership Reporting

An AS must prepare annual accounts. The annual accounts, and any directors’ report and auditor’s report where applicable, must be approved by the general meeting no later than six months after the end of the financial year and submitted to the Register of Company Accounts within one month after approval. For companies with a financial year corresponding to the calendar year, 31 July is normally the final filing date for avoiding late filing penalties. Filed annual accounts are publicly available, and failure to file on time may result in late filing penalties.

The company must also maintain a shareholder register. This is not the same as a public central securities register, unless the company’s shares are registered with such a system. In addition, private limited companies must submit an annual shareholder register statement to the Norwegian Tax Administration by 31 January each year, providing information about shareholders and relevant share transactions during the preceding year.

Norwegian companies subject to the beneficial ownership rules must identify and register their beneficial owners in the Norwegian Register of Beneficial Owners. The board is responsible for ensuring that the company obtains, maintains and registers correct information. Registration must generally be made within 14 days after the company is registered in a public register and within 14 days after new beneficial owners are identified or other changes occur. Failure to comply may result in coercive fines.

Tax, Employment and Other Reporting Obligations

Other ongoing reporting obligations depend on the company’s activities. Companies carrying on business in Norway must generally report financial information through annual tax returns. VAT-registered businesses must submit VAT returns, and companies that pay salaries must submit monthly employer reports covering salary, employer’s national insurance contributions and tax withholding. Certain events, such as workplace accidents, share transfers or changes to the board or articles of association, may also trigger reporting or filing obligations. Regulated businesses and certain industries may be subject to additional sector-specific reporting, filing or publication requirements, including supplementary reporting to supervisory authorities.

In practice, most routine filings are made electronically through Altinn and the Brønnøysund Register Centre, although alternative procedures may be available. Foreign owners should ensure that the company has appropriate access arrangements, procedures to identify reportable changes, and personnel or advisers familiar with Norwegian accounting, tax and corporate filing requirements.

Norwegian private and public limited liability companies do not fit neatly into either a pure one-tier or a classic two-tier board model. The structure is best described as a board-based model, with a general meeting, a board of directors and, where appointed or required, a general manager.

For both private limited liability companies (AS) and public limited liability companies (ASA), the general meeting is the company’s supreme shareholder body. It elects the board of directors, unless this power lies with a corporate assembly or other special arrangement. It also approves the annual accounts, elects the auditor where applicable, adopts amendments to the articles of association and decides other matters reserved to the shareholders. The general meeting does not manage the company’s business.

The board of directors is responsible for the overall management and supervision of the company. The board also represents the company externally and may assign signatory powers or powers of procuration to board members, the general manager or named employees. The board is therefore not merely a supervisory body; it has both managerial and oversight functions.

An AS must have a board of directors, which may consist of one or more members. A general manager may be appointed, but is not required. Where a general manager is appointed, he or she is responsible for day-to-day management within the framework set by the board.

An ASA is subject to stricter governance requirements. It must have a board of directors with at least three members, a general manager and an auditor. Where the company has a corporate assembly, the board must have at least five members. The ASA form is therefore more formalised and is generally used for listed companies or companies seeking access to the public capital markets.

A corporate assembly is mainly relevant in companies with more than 200 employees, unless validly waived. Where a corporate assembly exists, it sits between the general meeting and the board for certain purposes, including election of the board in many cases. In practice, however, many private companies do not have a corporate assembly.

Partnerships have more flexible management structures, depending on the partnership agreement and the type of partnership. A Norwegian branch of a foreign company (NUF) is managed by the foreign legal entity, although the foreign company may appoint a local general manager or establish a Norwegian branch board.

For most foreign investors using an AS, the practical governance structure is simple: shareholders act through the general meeting, the board has overall responsibility, and the general manager handles daily operations if appointed.

A Norwegian private or public limited liability company is a separate legal entity. As a starting point, shareholders are not personally liable for the company’s obligations beyond their contribution to the share capital. This limited liability is one of the main reasons why the AS is the standard corporate vehicle for foreign investors in Norway.

Board members and the general manager may, however, incur personal liability. The basic rule is fault-based. A board member, general manager, member of the corporate assembly, investigator or shareholder may be liable for loss that they have intentionally or negligently caused to the company, a shareholder or a third party in that capacity. The same may apply to a person who has intentionally or negligently contributed to such damage. Liability requires the ordinary conditions for damages to be met, including fault, financial loss and causation.

The board is responsible for the overall management and supervision of the company, while the general manager is responsible for day-to-day management within the framework set by the board. The board must also keep itself informed of the company’s financial position and ensure that the company has adequate equity and liquidity, assessed in light of the risks and scope of its business. If the equity or liquidity position becomes inadequate, the board must consider the matter and take appropriate action.

In practice, liability risk often arises where the board or management fails to act with sufficient care in financial distress, enters into obligations when the company has no realistic ability to perform, makes unlawful distributions, provides misleading information, fails to maintain proper accounts or internal controls, or disregards statutory requirements or creditors’ interests. Passivity may be problematic where the company’s financial position has deteriorated and the board fails to investigate, propose or implement corrective measures.

Shareholders are generally protected by limited liability, but they are not immune from personal liability for their own conduct or contribution to wrongful conduct. A shareholder may be liable where it has acted intentionally or negligently and caused or contributed to loss, for example by participating in unlawful distributions, giving improper instructions, abusing its influence over the company, misleading creditors or otherwise contributing to conduct that gives rise to liability. Mere ownership, ordinary group-level contact or ordinary exercise of shareholder rights will not normally be sufficient.

“Piercing the Veil”

Norwegian law does not recognise a broad or clearly defined doctrine of “piercing the corporate veil” in the same sense as some common law jurisdictions. The question has been debated, and the courts are generally reluctant to disregard the separate legal personality of a limited liability company. Any such liability would be exceptional and would typically require circumstances making it unjustifiable to uphold limited liability, such as abuse of the corporate form, serious misconduct, commingling of interests, or a company structure that does not deserve protection. In practice, similar results are more commonly analysed under statutory liability rules, contribution liability or general tort law, particularly where a shareholder or other controlling person has acted culpably and caused or contributed to a specific loss.

Damages liability under the Norwegian Companies Acts may be reduced in exceptional cases under the general statutory rules on mitigation of damages. For foreign investors, however, the practical point is that passive share ownership in an AS or ASA normally gives strong limited liability protection. Personal liability risk increases where an owner, director or officer takes an active role in management, gives instructions, extracts value from a distressed company or allows the company to continue trading when it is no longer responsibly capitalised or liquid.

The legal framework governing employment relationships in Norway is based on statutory law, case law, collective agreements and individual employment contracts.

Statutory law is the primary source of regulation, in particular the Working Environment Act, which is the central protective statute in Norwegian employment law. The Act applies broadly to undertakings that employ workers, subject to certain statutory exemptions and sector-specific rules. Its provisions are generally mandatory and may not be derogated from to the detriment of the employee.

Other statutes regulate specific aspects of employment, including holidays, collective labour law, non-discrimination, pensions and data protection. State employees are also subject to specific rules under the State Employees Act, although large parts of the Working Environment Act also apply to employment in the state sector.

Collective labour law plays a central role in the Norwegian model. Collective agreements at different levels supplement statutory legislation and may set binding wage and working conditions for employment relationships falling within their scope. Such agreements are concluded between trade unions and employers or employers’ organisations. The Labour Disputes Act governs collective labour disputes and the legal framework for collective agreements.

Individual employment contracts constitute a further layer of regulation, operating within the framework established by mandatory legislation and any applicable collective agreements.

Norwegian employment law is also developed and interpreted through case law. Disputes concerning individual employment relationships are heard by the ordinary courts, while the Labour Court has jurisdiction over disputes of a collective nature.

International and European legal sources are significant. Under the EEA Agreement, Norway is required to implement relevant EU legal acts as adapted within the EEA framework. Many provisions of the Working Environment Act implement EU directives incorporated into the EEA Agreement, which may be relevant when interpreting the Act.

Norwegian law requires a written employment contract in all employment relationships, regardless of duration or scope. However, under general contract law principles, verbal agreements are generally binding. The requirement is therefore that the agreed terms of employment must be documented in writing.

As a general rule, employment is permanent. Permanent employment means that the employment is ongoing and time-unlimited, that the statutory rules on termination apply, and that the employee has predictability as to work in the form of a genuine scope of employment. Part-time employment is permitted. Fixed-term employment contracts are subject to stricter conditions and may only be used where statutory requirements are met.

The written employment contract must include information on matters of material importance to the employment relationship, including the identity of the parties, place of work, position or work description, start date, salary, working time, breaks, holiday and holiday pay, notice periods, any probationary period, any applicable collective agreements, and, for fixed-term employment, the expected duration and legal basis for the fixed-term arrangement. Additional information requirements apply where relevant, including in relation to variable working hours, overtime arrangements, training rights, employer-paid social security benefits and agency work.

Several of these requirements may be satisfied by reference to applicable legislation, regulations or collective agreements.

As a general rule, normal working hours must not exceed nine hours in a 24-hour period and 40 hours in a seven-day period. Specific rules apply to shift work, on-call duties and work of a passive nature.

Working time may be calculated on an average basis over a period of up to 52 weeks, subject to statutory limits and procedural requirements. In such cases, working hours may be higher in certain periods, provided the statutory average limits are observed.

Overtime requires a specific and time-limited need. Work exceeding the statutory limits on normal working hours qualifies as overtime. Overtime must be compensated by a salary supplement of at least 40% in addition to the employee’s ordinary pay. The parties may agree in writing that overtime hours are compensated by time off, but the statutory overtime supplement must generally be paid.

There is currently legal uncertainty regarding overtime compensation for part-time employees. Under Norwegian law, part-time workers are generally not entitled to overtime pay until they exceed the statutory threshold applicable to full-time employees. However, two judgments from the Court of Justice of the European Union indicate that this may constitute unequal treatment. Similar reasoning has been adopted in two non-final district court judgments.

The Norwegian government has therefore appointed a working group to assess potential legislative amendments aimed at preventing differential treatment between full-time and part-time employees. The group is expected to submit its recommendations by September 2026, and legislative clarification or amendments may follow.

Collective agreements and individual agreements may provide for alternative working time arrangements, provided they comply with mandatory statutory requirements and are not to the detriment of the employee.

Norway is not an employment-at-will jurisdiction. Termination of employment is regulated by the Working Environment Act, which sets a high threshold for an employer’s right to dismiss an employee. Any dismissal must be objectively justified on the basis of circumstances relating to the undertaking, the employer or the employee. The requirement of objective justification has been developed through case law, and the courts have full jurisdiction to review both the factual and legal basis for dismissal.

Before any decision is made, the employer must normally hold a consultation meeting with the employee. A concrete assessment must be carried out, balancing the interests of the employer and the employee. Termination must be reasonable and appropriate in light of the circumstances.

In redundancy situations, the employer must consider whether other suitable work is available and apply objective selection criteria. There is no general statutory principle requiring selection by seniority alone; selection must be based on an overall objective assessment.

Formal requirements apply to notices of termination, including requirements as to written form and proper delivery. The notice must include information on the employee’s right to request negotiations, initiate legal proceedings and remain in the position in certain circumstances. It must also include information on the applicable time limits and identify the employer and the correct defendant in any dispute. Where termination is based on circumstances relating to the undertaking, the notice must include information on any statutory preferential rights.

Fixed-term employment relationships normally terminate at the expiry of the agreed period or completion of the agreed work, unless otherwise agreed in writing. During the fixed-term period, the ordinary rules on termination and dismissal apply.

For other employment relationships, the length of the notice period is primarily governed by statute. As a general rule, the statutory notice period is mutual and must be at least one month. For employees with longer periods of continuous service, the statutory minimum notice period is extended in accordance with the thresholds set out in the Working Environment Act. Longer notice periods may also follow from the employment contract or an applicable collective agreement.

Certain categories of employees enjoy enhanced dismissal protection, including employees who are pregnant, on parental leave, on sick leave or performing military service.

Disputes concerning unfair dismissal are heard by the ordinary courts and may result in the dismissal being declared invalid or in compensation being awarded. Compensation is assessed on a discretionary basis, taking into account the employee’s financial loss, the conduct of the parties and the circumstances of the case.

Collective redundancies are subject to additional information and consultation requirements where at least ten employees are dismissed within 30 days for reasons not related to the individual employees. The employer must consult employee representatives as early as possible and provide relevant information, including the reasons for the redundancies, the number of employees affected, the timeframe and the selection criteria.

The Working Environment Act contains provisions on the employer’s duty to provide information and consult with employee representatives. The general obligation applies to undertakings that regularly employ at least 50 employees, with both full-time and part-time employees included in the calculation.

In matters of significance for employees’ working conditions, the employer must inform and consult employee representatives. Norwegian law also requires information and consultation in a number of specific situations, including significant changes affecting employees, collective redundancies and transfers of undertakings.

The obligation covers information concerning the current and anticipated development of the undertaking’s activities and financial situation. It also extends to the current and expected staffing situation and to decisions that may lead to significant changes in work organisation or employment conditions. In such cases, information and consultation must take place as early as possible.

Exceptions apply where disclosure or consultation would clearly cause significant harm to the undertaking. Employee representatives may also be subject to a duty of confidentiality where necessary.

Employees working in Norway are generally taxable on salary earned for work performed in Norway. Individuals who are tax resident in Norway are generally taxable in Norway on worldwide income and wealth, subject to applicable tax treaty relief. An individual becomes tax resident in Norway if he or she stays in Norway, over one or more periods, for more than 183 days during a 12-month period, or more than 270 days during a 36-month period. Non-residents may still be subject to limited tax liability in Norway on Norwegian-source employment income, including salary for work performed in Norway.

Employment income is taxed through ordinary income tax, bracket tax and employee national insurance contributions. For 2026, the employee national insurance contribution on salary is 7.6%, and the maximum effective marginal tax rate on salary income, excluding employer’s national insurance contributions, is 47.4%.

Employers must withhold tax from salary payments and report salary, benefits and withholding on a monthly basis through the “A-melding” system. From 2026, withholding tax must generally be paid no later than the first working day after salary payment.

Employers must also pay employer’s national insurance contributions. The rate is geographically differentiated by municipality; the ordinary rate in central areas is 14.1%, but lower rates apply in certain regions. Employer’s contributions are calculated on gross salary and relevant benefits.

Foreign workers may, in some cases, be taxed under the simplified PAYE scheme. For 2026, the PAYE rate is 25%, or 17.4% where the employee is exempt from Norwegian national insurance contributions. PAYE is mainly relevant for shorter stays or the first year of Norwegian tax residence, subject to an income threshold of NOK725,050 (2026) and other conditions.

Corporate Income Tax

A company incorporated in Norway or effectively managed from Norway is generally tax resident in Norway and taxable on its worldwide income. A foreign company may be subject to limited tax liability in Norway on Norwegian-source business income, including income from business carried on in or managed from Norway, subject to applicable tax treaty rules, including permanent establishment requirements. The ordinary corporate income tax rate is 22%. Certain financial-sector companies are taxed at 25%, while special tax regimes apply to sectors such as petroleum, hydropower, aquaculture and shipping.

Value Added Tax (VAT)

Norway has a value added tax system. The standard VAT rate is 25%, with reduced rates of 15% for foodstuffs and water and wastewater services, and 12% for certain services including passenger transport, accommodation and admission to certain cultural and leisure activities. Businesses must register for VAT when turnover of taxable goods and services exceeds NOK50,000 within a 12-month period. Registered businesses generally charge output VAT on taxable supplies and may deduct input VAT on purchases used in the VAT-liable business. VAT is therefore normally intended to be borne by the final consumer rather than by VAT-registered businesses.

Withholding Tax

Dividends distributed from a Norwegian company to a foreign shareholder are generally subject to 25% withholding tax, unless reduced under a tax treaty or exempt under domestic rules, including exemptions for qualifying corporate shareholders within the EEA. Norway does not generally levy withholding tax on ordinary arm’s length interest or royalty payments, but a 15% withholding tax applies to interest, royalties and certain lease payments to related parties resident in low-tax jurisdictions, subject to treaty relief and EEA exemptions for genuine establishments.

Transfer Taxes and Stamp Duty

Norway does not have a general capital duty or stamp duty on share transfers. Acquisitions of shares in Norwegian companies are therefore not subject to transfer tax.

Registration of a transfer of title to Norwegian real estate is normally subject to stamp duty of 2.5% of the property’s sale value at registration. The duty is calculated on the higher of the purchase price and market value at the time of registration and is payable upon registration with the Norwegian Mapping Authority. Certain exemptions apply, including transfers carried out as part of qualifying mergers or demergers under the Companies Act. Share deals involving property-owning companies are commonly used because the transfer of shares does not trigger stamp duty, although other tax and commercial implications should be assessed.

Pillar Two

Norway has implemented Pillar Two through the Global Minimum Tax Act, effective from 1 January 2024, for groups within the OECD/GloBE scope. Norway has introduced a domestic minimum top-up tax. The OECD central record lists Norway’s domestic minimum top-up tax as having QDMTT safe harbour status, effective 1 January 2024.

Norway has relatively few broad tax incentives. The main generally available tax incentive is the SkatteFUNN research and development scheme. Norwegian companies and Norwegian branches of foreign companies may apply for a tax deduction of 19% of qualifying R&D project costs approved by the Research Council of Norway. The deduction applies to qualifying project costs, subject to the applicable annual cost cap, currently NOK25 million. If the company has no taxable income, the tax value may be refunded.

The scheme is rights-based and available across sectors, provided the project qualifies as research and development and the applicant is subject to Norwegian tax. Where R&D services are purchased from a third-party provider, the deduction only applies to costs incurred with providers established in the EEA or in countries with which Norway has concluded a tax treaty or tax information exchange agreement.

Norway also has a special tonnage tax regime for qualifying shipping companies. Companies within the regime are not taxed under the ordinary corporate income tax rules. Tax liability is instead calculated based on the net tonnage of relevant vessels and days in operation, irrespective of actual profits or losses. The regime is intended to provide predictable taxation for qualifying shipping activities.

There are also favourable tax rules for employee share options in qualifying start-up and growth companies, intended to support recruitment and retention of key personnel. The scheme generally defers taxation until the shares are sold, at which point any gain is normally taxed under the rules for share income rather than as salary. The scheme is subject to detailed conditions, including requirements relating to the company, the employee, the option terms and the timing of exercise and sale.

Norway does not have a formal tax consolidation or fiscal unity regime under which group companies are taxed as a single taxpayer. Each company is taxed separately.

In practice, tax equalisation within Norwegian groups may be achieved through group contributions. A Norwegian company may generally deduct a group contribution to another Norwegian group company, provided the recipient includes the contribution as taxable income. The rules require, broadly, more than 90% common ownership and voting control, directly or indirectly, at the end of the income year.

Group contributions are commonly used to offset taxable profits and losses within Norwegian groups. The contribution must be lawful under company law, including rules on distributable equity, and must be properly approved and documented.

The rules also contain limited EEA-related exceptions, but the practical scope is significantly narrower than for domestic Norwegian group contributions and depends on detailed conditions. For most foreign investors, the key point is that Norwegian subsidiaries are taxed separately, but Norwegian group companies can often achieve tax equalisation through deductible group contributions.

Norway does not have traditional thin capitalisation rules based on a fixed debt-to-equity ratio. Instead, interest deductions may be limited under statutory interest limitation rules and general transfer pricing principles.

The interest limitation rules are complex, but in simplified terms they apply where net interest expenses exceed statutory thresholds. For companies that are not part of a group, the threshold is NOK5 million and only net interest expenses on debt to related parties may be restricted. For group companies, the ordinary threshold is NOK25 million, calculated on a combined basis for the Norwegian part of the group, and the limitation may apply to both related-party and third-party interest.

Deductible net interest expenses are generally capped at 25% of tax EBITDA. Group companies may, in certain circumstances, rely on an equity escape rule, broadly where the equity ratio at company level or for the Norwegian part of the group is sufficiently aligned with the equity ratio in the consolidated group. However, the equity escape rule does not necessarily protect against limitation of interest paid to related parties outside the consolidated group.

Disallowed net interest expenses may be carried forward for up to ten years. Related-party financing must also comply with the arm’s length principle under the transfer pricing rules, and withholding tax may apply to certain interest payments to related parties in low-tax jurisdictions.

Foreign investors should assess acquisition financing and intra-group debt carefully, particularly where the Norwegian borrower has material related-party debt or a weaker equity position than the group as a whole.

Norwegian tax law applies the arm’s length principle to transactions between parties in a community of interest, including related-party transactions. The rules allow the tax authorities to adjust income, deductions and other tax positions where the prices or conditions agreed between such parties differ from those that would have been agreed between independent parties under comparable circumstances.

The Norwegian rules refer to, and generally follow, the OECD Transfer Pricing Guidelines. They are particularly relevant for cross-border controlled transactions, including sales of goods and services, intra-group financing, guarantees, royalties, management fees, cost-sharing arrangements and business restructurings.

Norwegian companies and permanent establishments may be required to prepare transfer pricing documentation if they meet the relevant size thresholds. The documentation should describe the group, the Norwegian entity, the controlled transactions and the comparability analysis, including functional analysis, method selection and benchmarking or other support for the pricing applied. Large multinational groups may also be subject to country-by-country reporting.

Transfer pricing is an important audit area for the Norwegian Tax Administration, particularly in relation to intra-group services, financing, intangibles and restructurings. Foreign investors with Norwegian subsidiaries or branches should ensure that intra-group arrangements are documented and implemented consistently with the arm’s length principle.

Norway has both a statutory general anti-avoidance rule and several specific anti-avoidance or protective rules. The general anti-avoidance rule may apply where, viewed objectively, the main purpose of a transaction or arrangement appears to be to obtain a tax advantage and, after an overall assessment, it would be contrary to the purpose of the tax rules to respect the arrangement for tax purposes.

The rule is aimed at tax avoidance rather than ordinary commercial tax planning. In practice, the assessment will consider the commercial rationale and non-tax effects of the arrangement, the size of the tax advantage, the degree of tax motivation, the legal and economic effects of the transaction, and whether the arrangement produces a tax result inconsistent with the relevant legislation.

Norway also has specific anti-avoidance or protective rules in areas such as interest limitation, transfer pricing, controlled foreign companies, withholding tax, loss utilisation, reorganisations and dividend taxation. Tax treaties may also include limitation-on-benefits provisions or principal purpose tests.

Taxpayers are subject to general disclosure obligations, and the tax authorities may request information and documentation. Incorrect or incomplete reporting may result in additional tax, interest and administrative penalties. Serious cases involving intentional or grossly negligent tax evasion may result in criminal liability.

For foreign investors, the practical point is that Norwegian structures should have commercial substance and be supported by contemporaneous documentation, particularly in cross-border financing, holding, IP and reorganisation structures.

Norway has a relatively liberal tariff regime. Most goods imported into Norway are duty-free, and customs duties are now mainly imposed on agricultural products, clothing and certain other textile products.

Customs duties are payable on importation into the Norwegian customs territory and are calculated by reference to the Norwegian Customs Tariff, which is adopted annually on the basis of Parliament’s customs duty resolution. Preferential treatment may apply under the EEA Agreement, Norway’s free trade agreements, including agreements concluded together with the other EFTA States, and the Generalized System of Preferences for developing countries, provided that the relevant product coverage and origin requirements are satisfied.

The most significant tariff protection applies to agricultural products that compete with Norwegian production, including meat, dairy products, grain and certain plants, vegetables and fruit. Agricultural tariff protection is an important element of Norwegian agricultural policy. Agricultural imports may, however, benefit from tariff reductions, tariff quotas or preferential arrangements, and processed agricultural products may be subject to special rules.

Importers should verify tariff classification, origin, quota availability and any applicable end-use or administrative reduction requirements before import. Norway’s tariff regime is shaped by WTO commitments and free trade agreements. While Norway has not recently adopted broad-based tariff increases, global trade tensions and security-related trade measures may increase the practical importance of origin documentation and supply-chain planning.

Under the Norwegian Competition Act, mergers and acquisitions may constitute concentrations subject to merger control.

A concentration must be notified to the Norwegian Competition Authority (NCA) if the undertakings concerned have combined annual turnover in Norway of NOK1 billion or more, and at least two of the undertakings concerned each have annual turnover in Norway of NOK100 million or more.

The NCA may require notification of a concentration below the Norwegian thresholds if there are reasonable grounds to assume that competition may be affected, or if particular considerations indicate that the transaction should be examined more closely. Transactions below the thresholds may also be notified voluntarily to clarify whether intervention may be relevant.

Concentrations with an EEA dimension may be subject to the EEA merger control rules.

A notifiable concentration is subject to a standstill obligation and must not be implemented before the Norwegian Competition Authority has received the notification and completed its review.

The statutory review periods start to run only once the notification requirements have been satisfied, including requirements relating to confidential information. In Phase I, the NCA must, within 25 working days after receiving a complete notification, inform the parties if intervention may be relevant. If no such notice is issued, the NCA may not intervene.

If the NCA proceeds with further review, it must, as soon as possible and no later than 70 working days after receiving the notification, either adopt a decision accepting remedies proposed by the notifying parties or issue a reasoned preliminary decision to prohibit the transaction. The parties have 15 working days to respond to a preliminary prohibition decision. The NCA must then adopt its final decision within 15 working days after receiving the parties’ response. If remedies are proposed after the preliminary prohibition decision, the deadline for the final decision may be extended by 15 working days.

The NCA may intervene where a concentration would significantly impede effective competition, in particular as a result of the creation or strengthening of a dominant position. Remedies may extend the statutory deadlines. An intervention decision may be appealed within 15 working days.

Section 10 of the Norwegian Competition Act prohibits anti-competitive co-operation between undertakings. The provision corresponds to Article 53 of the EEA Agreement and Article 101 of the TFEU, and covers agreements, decisions by associations of undertakings and concerted practices that have as their object or effect the prevention, restriction or distortion of competition.

The prohibition applies to both horizontal co-operation between competitors and vertical co-operation between undertakings at different levels of the supply chain. It covers, among other things, price-fixing, market-sharing, limitations on production, markets, technical development or investment, discriminatory trading terms and tying obligations.

The Norwegian Competition Act applies to conduct carried out in Norway, as well as conduct that has, or is capable of having, effects in Norway. The Act does not require an effect on trade between EEA states. Where conduct may affect trade within the EEA, Article 53 of the EEA Agreement applies in parallel.

Restrictive co-operation may nevertheless be exempt where the relevant conditions for exemption are met, including where the co-operation produces efficiencies, allows consumers a fair share of the benefits, does not impose unnecessary restrictions and does not eliminate competition for a substantial part of the relevant products.

Intentional or negligent infringements may be sanctioned by administrative fines. Leniency may be available in cartel cases.

Section 11 of the Norwegian Competition Act prohibits the abuse by one or more undertakings of a dominant position. The provision corresponds to Article 54 of the EEA Agreement and Article 102 of the TFEU, and EEA and EU law provide guidance when the rule is applied.

Holding a dominant position is not unlawful in itself. The prohibition concerns abusive conduct by a dominant undertaking. Examples include imposing unfair prices or trading conditions, limiting production, markets or technical development to the prejudice of consumers, applying dissimilar conditions to equivalent transactions, and tying unrelated obligations to contracts.

The Norwegian Competition Act applies where the conduct has, or is capable of having, effects in Norway. Where the conduct may affect trade within the EEA, Article 54 of the EEA Agreement applies in parallel.

Intentional or negligent infringements may be sanctioned by administrative fines. The NCA may also order the infringement to cease or impose necessary measures.

Norwegian patent law is governed by the Patents Act. Patent protection is available for inventions that provide a practical solution to a technical problem. The invention must have technical character and effect, be reproducible, be novel and involve an inventive step. Mere discoveries, scientific theories, mathematical methods, aesthetic creations, business methods and computer programs “as such” are not patentable.

Patent rights are obtained by application. National patents are granted by the Norwegian Industrial Property Office, while European patents may be granted by the European Patent Office and made effective in Norway. The application must include a description of the invention and patent claims defining the scope of protection sought. The invention must be disclosed sufficiently clearly and completely for a person skilled in the art to carry it out.

A granted patent may normally be maintained for up to 20 years from the filing date, subject to payment of annual fees.

Patent rights are enforced before the ordinary courts. Remedies for patent infringement may include injunctions, reasonable compensation, damages and measures to prevent further infringement. In serious cases, patent infringement may also give rise to criminal liability.

A trade mark may consist of any sign capable of distinguishing the goods or services of one undertaking from those of others. Trade mark rights are governed by the Trademarks Act and may be established by registration or through use.

National trade mark rights may be obtained by registration in the Norwegian trade mark register. To be registrable, the mark must be capable of distinguishing the applicant’s goods or services and must have distinctive character. Descriptive or generic signs should generally remain available for use by others. The Norwegian Industrial Property Office examines whether the statutory conditions for registration are met, including both absolute and relative grounds for refusal.

Trade mark rights may also be established without registration where the mark has become established through use. A mark is established through use where, and for as long as, it is well known in the relevant Norwegian market as a distinctive sign for particular goods or services. If the mark is established only in part of Norway, protection is limited to that area.

Trade mark protection gives the holder an exclusive right to use the mark as a sign for goods or services in the course of trade. The right covers use of identical signs for identical goods or services and use of identical or similar signs for identical or similar goods or services where there is a likelihood of confusion. Well-known marks may enjoy broader protection against unfair exploitation or impairment of their goodwill.

A registered trade mark is protected for ten years at a time and may be renewed indefinitely, subject to payment of renewal fees. Registered marks may be vulnerable to cancellation if they are not put to genuine use for a continuous five-year period without proper reason.

Trade mark rights are enforced before the ordinary courts. Infringement may give rise to reasonable compensation, damages or an account of profits, depending on the circumstances. In serious cases, trade mark infringement may also give rise to criminal liability.

Design rights are governed by the Design Act. Design protection covers the appearance of a product or part of a product, including features such as lines, contours, colours, shape, texture, materials or ornamentation.

A design must be new and have individual character to qualify for protection. A design is new if no identical design has been made available to the public before the filing date or priority date. Individual character depends on whether the overall impression produced on the informed user differs from that produced by earlier designs, taking into account the designer’s freedom in developing the design.

Design rights are obtained by registration. Applications must be filed in writing with the Norwegian Industrial Property Office and must identify the applicant, the product or products to which the design relates, and include images clearly showing the design. The application fee must be paid.

The Norwegian Industrial Property Office examines formal filing requirements, whether the application concerns a design within the meaning of the Design Act, and certain public interest grounds for refusal. It does not generally examine whether the design is new or has individual character before registration. A registered design may therefore later be challenged and declared invalid or revoked if the substantive requirements are not met.

A registered design is protected for five years from the filing date and may be renewed in five-year periods for a maximum term of 25 years, subject to payment of renewal fees.

Design rights are enforced before the ordinary courts. Remedies for design infringement may include injunctions, reasonable compensation, damages and measures to prevent further infringement. In serious cases, design infringement may also give rise to criminal liability.

Copyright is governed by the Copyright Act and protects original literary and artistic works. Protection arises where the work is the result of an individual creative effort, regardless of its form of expression.

Copyright gives the author an exclusive right to exploit the work by making copies and by making the work available to the public.

As a general rule, copyright lasts for the lifetime of the author and for 70 years after the end of the year of the author’s death. Special rules apply to certain categories of works, including films, anonymous and pseudonymous works and works of unknown authorship.

No registration is required to obtain copyright protection. Protection arises automatically when an original work is created.

Copyright is enforced before the ordinary courts. Infringement may give rise to reasonable compensation and damages. In certain circumstances, infringement may also result in criminal liability, including fines or imprisonment.

Computer programs may be protected as copyright works under the Copyright Act, provided that the general requirements for copyright protection are met.

Databases may be protected by copyright where they qualify as original works. Databases that do not qualify for copyright protection may nevertheless benefit from separate database protection where substantial investment has been made in obtaining, verifying or presenting their contents.

Trade secrets are not registered. They may be protected under trade secrets legislation against unlawful acquisition, use and disclosure, including industrial espionage and unauthorised disclosure of confidential business information.

The main data protection framework in Norway is the EU General Data Protection Regulation (GDPR), as incorporated into Norwegian law through the Norwegian Personal Data Act. Norway is not an EU member state, but participates in the EU internal market through the EEA Agreement. The GDPR was incorporated into the EEA Agreement and has applied in Norway since 20 July 2018. Norway is therefore bound by the GDPR in substantially the same way as EU Member States.

The Norwegian Personal Data Act supplements the GDPR with national provisions where the GDPR allows local regulation, including certain rules on processing in employment relationships, research, freedom of expression, access to documents, children’s consent and administrative fines. It does not replace the GDPR; it makes the GDPR applicable in Norway and adds limited national rules.

The Norwegian Data Protection Authority, Datatilsynet, is the national supervisory authority. It supervises compliance, handles complaints, issues guidance and may impose corrective measures and administrative fines. Datatilsynet participates in the European Data Protection Board, although Norway’s EEA status means that it does not have the same voting position as EU supervisory authorities.

Other rules may also be relevant. Electronic marketing is regulated by the Marketing Control Act, and cookies and similar technologies are regulated through electronic communications rules. Sector-specific confidentiality, security and record-keeping rules may also apply, for example in financial services, healthcare, telecoms and employment.

In practice, businesses operating in Norway should treat GDPR compliance as the core data protection requirement, supplemented by Norwegian national rules and Datatilsynet guidance.

The geographical scope of Norwegian data protection law follows the GDPR. The rules apply to controllers and processors established in Norway where personal data is processed in the context of that establishment’s activities, regardless of whether the processing itself takes place in Norway.

The rules may also apply to a foreign company with no establishment in Norway or the EEA if it offers goods or services to individuals in Norway or monitors their behaviour in Norway. Relevant indicators may include use of Norwegian language, pricing in Norwegian kroner, delivery to Norway, marketing directed at Norwegian customers, or tracking and profiling of users in Norway.

A non-EEA controller or processor subject to the GDPR under these rules may need to appoint an EU/EEA representative, unless an exemption applies. The representative may be contacted by supervisory authorities and data subjects on GDPR matters.

International transfers of personal data from Norway to countries outside the EEA are subject to Chapter V of the GDPR. Transfers may take place on the basis of an adequacy decision, or, in the absence of such a decision, where appropriate safeguards are provided, such as the EU Standard Contractual Clauses or Binding Corporate Rules, unless a specific derogation applies. For transfers to the United States, the EU–US Data Privacy Framework currently permits transfers to US organisations certified under the framework, while transfers to non-certified US recipients require another valid transfer mechanism. Businesses using non-EEA service providers should map relevant data flows, including remote access, cloud services, sub-processors and onward transfers, and assess whether the chosen transfer mechanism is effective in practice. Where necessary, supplementary technical, contractual or organisational safeguards must be implemented.

For practical purposes, a foreign business actively targeting Norwegian customers should assume that GDPR compliance may be required even without a Norwegian subsidiary or branch.

The Norwegian Data Protection Authority, Datatilsynet, is the supervisory authority responsible for enforcing data protection rules in Norway. It is an independent administrative authority and supervises compliance with the GDPR and the Norwegian Personal Data Act.

Datatilsynet’s role includes providing guidance, handling complaints from individuals, conducting investigations and inspections, assessing data breach notifications, and supervising controllers and processors. It may also issue opinions and guidance on new legislation, technology and processing practices.

Datatilsynet has the enforcement powers provided by the GDPR. It may order a controller or processor to bring processing into compliance, require information, impose temporary or permanent processing bans, order rectification or deletion of personal data, issue reprimands and impose administrative fines. The maximum GDPR fines are the same as in the EU: up to EUR 20 million or 4% of worldwide annual turnover, depending on the nature of the infringement.

Datatilsynet also co-operates with other European supervisory authorities through the GDPR co-operation and consistency mechanisms. As Norway is part of the EEA, Datatilsynet participates in the European Data Protection Board system, although Norway is not an EU member state.

Decisions by Datatilsynet may generally be appealed to the Norwegian Privacy Appeals Board and may ultimately be challenged before the ordinary courts.

There are several legal developments that foreign investors should monitor, although Norway is not currently undergoing a single comprehensive business law reform.

The most important development is in foreign investment control. Norway already has ownership control rules under the Norwegian Security Act, and amendments adopted in 2023 are expected to enter into force with supplementary regulations in 2026. These changes are expected to broaden the scope of the regime, lower notification thresholds and introduce a clearer standstill obligation for notifiable transactions. In addition, the government has announced work on a possible new Investment Control Act, with a consultation paper expected in 2026. If adopted, this would represent a more general Norwegian FDI screening regime alongside the existing Security Act rules.

In tax, the 2026 budget contains relatively limited structural changes. The government has indicated that the 2026 tax programme is focused on simplification, closing loopholes and adapting the system to other regulatory developments. Norway has already implemented Pillar Two rules, including an income inclusion rule and domestic minimum top-up tax from 2024, so further developments are expected mainly through guidance and technical adjustments rather than a new primary regime.

In data and digital regulation, Norway is expected to continue aligning with EU digital legislation through the EEA Agreement. The EU AI Act is expected to be implemented in Norway, and a Norwegian consultation on draft AI Act implementation was published in 2025. Businesses using or providing AI systems in Norway should monitor the timing of EEA incorporation and Norwegian implementation.

Corporate compliance has also become more transparent. The obligation to register beneficial owners is now in force, and the register is a practical compliance point for Norwegian companies and branches. This is not a future reform in itself, but enforcement and practical implementation remain relevant for foreign-owned Norwegian structures.

Overall, the main near-term reform risk for foreign investors is not ordinary company law, but investment screening, security-related regulation, digital regulation and continued tax compliance developments.

LEXOSLO Advokatfirma AS

Fridtjof Nansens plass 7
P.O. Box 1765 Vika
NO-0122
Oslo
Norway

+47 22 75 25 00

lexoslo@lexoslo.no www.lexoslo.no
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LexOslo is a Norwegian boutique business law firm based in Oslo. The firm advises corporates, investors, banks and other financial undertakings on business law matters in Norway, with a particular focus on finance law and international business in Norway. Its work includes transactions, regulatory questions, commercial matters and disputes, often where Norwegian law must be understood in a broader commercial or cross-border context. LexOslo was founded by attorney Harald Sætermo and reflects a practice developed over more than 25 years in private practice and senior in-house legal roles in the banking sector. The firm’s boutique format allows for direct senior involvement, continuity and close attention to the client’s business and legal position. For international clients, LexOslo provides advice grounded in Norwegian law, market practice and practical commercial judgement. The firm’s approach is focused and personal, with an emphasis on clear responsibility, efficient execution and legal advice that supports sustainable business growth.

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