Norway International Update Q2 2026

Norwegian Tax Commission proposes broad tax reform

On 24 June 2026, the Norwegian Tax Commission submitted its report with recommendations for changes to the Norwegian tax system. The Commission’s mandate was to propose a reform that would contribute to a competitive tax level for Norwegian businesses and command broad support in the Storting (the Norwegian Parliament).

The report proposes a broad package of measures. The Commission’s recommendations include reductions in personal income tax, changes to the net wealth tax, adjustments to the taxation of equity investors, changes to the Norwegian exit tax rules and a broadening of the VAT base. For international companies and investors, the report is relevant for several reasons, some key points are set out below:

• Norwegian net wealth tax: The Commission does not recommend abolishing the tax, but proposes to reduce the rate and remove certain valuation discounts. The Commission suggests a new rate range of 0.25% to 0.75%, compared with the current 1.0%, while removing the current valuation discounts for shares, housing and other assets. Whether this will imply a substantial reduction of the net wealth tax or not will depend on the rate and the basic allowance applied. There are substantial differences between the political parties on net wealth tax in particular and the fate of this proposal is highly uncertain.
  
• Exit tax: The Norwegian exit tax rules have been heavily debated, particularly following recent tightening of the regime. The Commission proposes adjustments to make the rules less restrictive while preserving the Norwegian tax base. Key proposals include reducing the instalment payment triggered by dividend distributions from 70% to approximately the tax rate on share income, currently 37.84%, granting credit for Norwegian withholding tax, and exempting individuals with only temporary residence in Norway. The tax claim would still have to be settled within 12 years after emigration, so the total tax payable over time would remain broadly unchanged. The aim of these changes is to make Norway more attractive for entrepreneurs and investors. The key message is that it should be possible to establish and build up value in Norway without being subject to an unreasonably harsh tax charge if one later chooses to move abroad.

The package of proposals reflects concerns about capital flight. The Commission is seeking to strike a balance between protecting the tax base and taking account of mobility and competitiveness.

Although the Commission’s proposals are extensive, it remains highly uncertain whether they will be implemented. The mandate was to identify a compromise capable of securing broad political support, but developments so far reveal clear political divisions. Two parties in the Storting have already distanced themselves from the process: the Progress Party (FrP) did not participate, while the Red Party’s (Rødt) appointed member withdrew in protest shortly before finalisation.

The Commission’s recommendation therefore remains only a proposal at this stage. The report has been submitted for public consultation, with a deadline of 24 September 2026. This will be followed by political negotiations on the Commission’s recommendations, and it remains unclear whether the government will be able to secure a majority for this proposal, but there could be that agreement is reached on some of the suggestions.

For businesses and international investors, this means continued uncertainty. The Storting’s consideration should be monitored closely, as the outcome may affect the framework conditions for investment, ownership and business activities in Norway.

OECD consultation on Chapter VII of the Transfer Pricing Guidelines

On 1 June, OECD launched a public consultation process on the revision of Chapter VII of its Transfer Pricing Guidelines. This chapter concerns the pricing of intra-group services within multinational enterprise groups. The purpose of the revision is to align the guidance on intra-group services with the fundamental principles set out in Chapters I to III of the OECD Guidelines and to provide greater clarity on practical application through new examples.

The OECD emphasises that the revision is not intended to change the underlying principles of arm’s length pricing, but rather to provide clearer and more practical guidance. The discussion draft contains proposed amendments and raises a number of specific questions on which the OECD invites input from businesses, industry organisations and other stakeholders. The consultation deadline is 22 July 2026, after which the OECD will review and process the feedback received. This is worth noting for international companies, including those with operations in Norway.

For now, the proposals remain at the draft stage, but developments should be monitored closely. The consultation signals that tax authorities globally, including in Norway, are likely to place increased emphasis on the correct pricing of intra-group services, with revised guidelines serving as a key point of reference.

VAT on cross-border intra-group services

As previously noted in our Norwegian International Update for Q1, the new rules on VAT on purchases of remotely deliverable services from abroad will enter into force with effect from 1 July 2026. The amendments mean that VAT must be calculated on remotely deliverable services purchased from abroad, even where the services are supplied between different branches of the same legal entity.

Under the current rules, transfers of services between a foreign head office and a Norwegian branch are regarded as internal transfers within the same legal entity and therefore do not trigger an obligation to calculate VAT under Norwegian VAT rules.

This will change from 1 July. Financial undertakings with an establishment abroad that purchase remotely deliverable services for use by their Norwegian branch will be required to calculate Norwegian VAT under the reverse charge mechanism on the proportion of the services used in Norway. The VAT liability applies to externally purchased services and therefore does not include services produced in-house by the head office.

Stricter Gatekeeping of Grid Capacity

Norway’s grid connection regime is becoming stricter, as grid capacity has become a scarce resource for production and consumption of electricity. Maturity assessment rules in regulations under the Energy Act require grid companies to assess whether projects are sufficiently mature before the projects receive a capacity reservation or a place in the capacity queue. The aim is prioritising projects that are likely to be realised and preventing immature projects from blocking access to scarce grid capacity.

Statnett’s new maturity criteria

The Norwegian TSO, Statnett, has recently adopted stricter maturity requirements and closer follow-up of progress for consumption projects of 100 MW or more. The new requirements affect both new projects and projects that already have a reservation or a place in the capacity queue.

The most important changes include reducing the maximum period from reservation to commissioning from ten years to six years, requiring necessary land-use and zoning plans to be in place, and imposing more detailed documentation requirements for project descriptions, capacity budgets and financing plans. Statnett also proposes clearer thresholds for material deviations in project progress, where delays of more than one year for circumstances directly attributable to the customer, or more than two years for circumstances for which the customer indirectly bears responsibility or risk, may trigger withdrawal of capacity. Statnett justifies the tightening by reference to equal treatment, more realistic projects in the queue and better utilisation of available grid capacity.

The changes will have significant consequences, particularly because some requirements are substantially stricter than current practice and may affect projects already assessed as mature. The most controversial elements are likely to be the requirement that municipal zoning clarification must be in place as a new minimum requirement for maturity , and the use of fixed delay thresholds rather than a case-by-case assessment of project progress. The new maturity criteria were adopted 25 June and enter into force on 1 July 2026. Transitional rules apply for projects that already have a reservation or a place in the capacity queue.

Renewables Norway’s Best Practice guidance

Renewables Norway (Fornybar Norge), an interest organisation for the renewable energy industry, has published a new version of its Best Practice guidance for grid connection and maturity assessments. This updated Best Practice document has been prepared in close cooperation with a number of regional grid companies and Statnett. In the same way as Statnett’s new maturity criteria, Renewables Norway’s updated Best Practice applies from 1 July 2026.

It is used by local and regional grid companies in their handling of grid connection requests from consumption projects with a power need of less than 100 MW. While it is not quite as strict as Statnett’s new criteria, the new Best Practice guide does signal stricter gatekeeping also for sub-100 MW projects going forward, inter alia with regard to municipal land-use approval.

RME interventions in Statnett capacity reservation cases

While Statnett tightens its grid connection process by adopting stricter maturity criteria, the Norwegian Energy Regulatory Authority (RME) has found in favour of the grid customer in two recent decisions in individual dispute cases against Statnett. In one case, RME found that Statnett had applied a maturity criterion on securing land use rights that was too strict when applied on a complex mining project. In the other case, RME has issued a preliminary finding that Statnett unlawfully withdrew a 200 MW capacity reservation because the project – an industrial park – had not documented agreements with specific end customers and did not show sufficient progress.

RME underlines that Statnett cannot apply its maturity criteria and manage the capacity queue in a way that creates disproportionate barriers for complex industrial projects. RME also stressed that decisions on withdrawal of reservations must be nuanced and take into account matters which the grid customer does not control, such as processing time for necessary public permits.

Together with Statnett and Renewables Norway’s new and stricter maturity requirements, these cases illustrate that grid access is an increasingly controversial subject in Norway. As grid access is material for new data center and other industrial projects, we expect to see more dispute cases before the regulatory authorities and in the courts going forward.

Offshore Wind Update: Norway’s Offshore Wind Programme Faces Renewed Uncertainty

Norway’s two flagship offshore wind processes remain active, but both are now facing greater timing and execution risk. For the floating wind project Utsira Nord, the Norwegian Parliament (Stortinget) has asked the Government to ensure external quality assurance of the project and the use of up to NOK 35 billion in state aid. For bottom-fixed Sørlige Nordsjø II, developer Ventyr has asked the Ministry of Energy for a one-year extension of the deadline for submitting its licence application.

Utsira Nord is Norway’s main track for floating offshore wind. In May 2025, the Ministry of Energy launched a competition for three project areas, each with an installed capacity of up to 500 MW. The allocation model is structured in two stages. Project areas are initially awarded based on qualitative criteria, followed by a project development phase and a later competition for state aid. The support competition is based on an investment support model.

The economics of Utsira Nord are particularly sensitive because only one project will ultimately receive support. The maximum support framework is NOK 35 billion. In December 2025, the Ministry announced that project areas would be awarded to two separate groups. Both groups must proceed with project-specific impact assessments and submit licence applications before they can participate in the state aid competition.

The Storting’s request for external quality assurance therefore goes to the core of the Utsira Nord model. The project is important for technology development in floating offshore wind, but it also involves a substantial public financial commitment. External quality assurance may strengthen the decision basis, test cost assumptions and reduce the risk of overcompensation. At the same time, it causes delay and introduces another process layer into a sector already affected by cost pressure, cautious investors and demanding supply chains.

Sørlige Nordsjø II is further advanced but is now also facing a possible delay. Ventyr, the developer of Sørlige Nordsjø II, has applied to extend the licence application deadline from 15 October 2026 to autumn 2027. Ventyr links the need for postponement primarily to landfall and grid connection challenges in Agder County. The company has encountered issues relating to access to properties, permits for field surveys and exemptions in landscape and bird protection areas. Ventyr is now considering an alternative landfall and grid connection solution near Alcoa’s aluminium plant and estimates that a further 12 months may be needed to mature that option. The company also points to challenging project economics and increased commercial risk in the offshore wind sector and has put major supplier contracts on hold to limit running costs. The project is planned with a total capacity of 1,500 MW, approximately 90 turbines and expected completion in 2030.

The overall picture is that the route to realisation of Norway’s offshore wind ambitions has become more demanding, and projects will require stronger documentation, more robust cost assumptions and greater tolerance for delay risk.

The Ministry of Finance proposes that fewer companies should be required to report on sustainability (CSRD)

On 19 June 2026, the Norwegian Ministry of Finance submitted Prop.106 L (2025–2026), proposing amendments to the Norwegian Accounting Act to implement the changes in CSRD introduced by the Omnibus I Directive. The proposal would significantly narrow the scope of companies required to prepare sustainability reporting in Norway.

Under the proposal, from 2027, only companies that have both sales revenues exceeding NOK 5 billion and more than 1,000 full-time equivalent employees will be subject to the sustainability reporting requirements. The Ministry estimates that, from the 2027 financial year, the obligations will apply to approximately 120–160 Norwegian companies, compared to more than 1,000 Norwegian companies under the current rules. The Ministry also proposes to exempt approximately 40 Norwegian companies currently subject to sustainability reporting requirements from reporting for the 2026 financial year. The proposal also includes minor amendments to several other acts.

The Norwegian sustainability reporting requirements are supplemented by reporting standards set out in the Regulation on Sustainability Reporting Standards, which correspond to the EU standards (ESRS). On 6 May 2026, the European Commission launched a public consultation on draft amendments to the ESRS. The Ministry of Finance has stated that it aims to adopt corresponding regulatory amendments in Norway following any formal adoption by the Commission, so that Norwegian companies may also apply the revised standards for the 2026 financial year.

The Førdefjorden case and changes to the EU Water Framework Directive

On 17 June 2026, the Norwegian Supreme Court delivered its judgment in the Førdefjorden case, and ruled against the State. The proceedings were brought against the State in 2022 by environmental organisations. The case concerned permits granted for deposition of mining waste in Førdefjorden, in connection with extraction of rutile and garnet at Engebøfjellet.

The Supreme Court concluded that the discharge permit was invalid under the Norwegian Water Regulation, which implements the Water Framework Directive. In the view of the Court, the considerations on which the 2016 discharge permit was based did not satisfy the derogation requirement of imperative reasons of overriding public interest, as interpreted by the EFTA Court. As the discharge permit was invalid, the other decisions challenged in the case were also invalid.

The Supreme Court largely acceded to the EFTA Court’s legal assessment, among other things, stating that economic considerations, whether public or private, may only be relevant insofar as they are a means to achieve other overriding public interests. Further, the Court accepted that several considerations, taken together, could be considered “overriding public interests” and indicated that the consideration of supply security for critical raw minerals may be a relevant consideration. The Court did not accept that the permits had been “repaired” by the State’s renewed assessment in 2025.

In parallel, the European Commission is assessing possible amendments to the Water Framework Directive. The Commission has requested input on a revision of the directive, and the revised directive is expected to be presented in the second quarter of 2026. The Commission also published new guidance on the interpretation of the Water Framework Directive in relation to mining activities on 22 May 2026. Further, EU Directive 2026/805 entered into force on 11 May 2026, amending the Water Framework Directive, the Environmental Quality Standards Directive and the Groundwater Directive to update the lists of water pollutants, strengthen monitoring requirements and support the EU’s zero-pollution and water-resilience objectives.

The Norwegian Ministry of Climate and Environment has stated that it will assess whether any legislative proposals from the European Commission require amendments to Norwegian rules, in particular the Regulation.

Norway joins the EU’s 20th sanctions package against Russia

On 27 March 2026, Norway introduced further sanctions against Russia, mirroring the measures in the EU’s 19th sanctions package. On 15 May 2026, the Norwegian Government announced that Norway will also align itself with the EU’s 20th sanctions package. The Government is currently working to implement these measures into Norwegian law.

The EU adopted the 20th sanctions package on 23 April 2026. The package includes measures targeting, among other things, the Russian energy sector, the shadow fleet and oil exports, the financial sector and crypto services, the Russian defence industry, and exports of several categories of industrial goods. In addition, several individuals involved in the systematic abduction of Ukrainian children from occupied territories are added to the sanctions list.

In summary, the package includes the following sanctions and measures:

• 120 new individual listings.
• The EU introduces measures against actors in the Russian oil and energy sector, including entities involved in oil exploration, extraction, refining and transport.
• An additional 46 vessels are made subject to prohibitions on port access and services related to maritime transport. This brings the total number of listed vessels to 632.
• The package includes transaction bans against 20 Russian banks and four financial institutions in third countries.
• The EU introduces measures targeting crypto platforms and digital currencies that may be used to circumvent sanctions or carry out international transactions on Russia’s behalf.
• The EU lists 58 companies and associated individuals involved in the development and production of military equipment, including drones.
• 60 new entities are made subject to enhanced export restrictions for goods and technology that could strengthen Russia’s defence sector.
• The EU prohibits the export of certain machinery and radio equipment to Kyrgyzstan, where there is considered to be a high risk of re-export to Russia.
• The export ban is expanded to include, among other things, laboratory glassware, lubricants, chemicals, steel products, rubber products and industrial tractors. The EU also introduces new import restrictions on goods that could generate significant revenues for Russia.
• The EU lists individuals and entities linked to the abduction and forced transfer of Ukrainian children, the seizure of Ukrainian cultural heritage and the dissemination of pro-Russian propaganda.
• The package also includes new sanctions relating to Belarus’ role in supporting Russia’s war. The sanctions regime against Belarus has been extended until 28 February 2027.

Establishment of a new joint civil-military clearance authority

On 15 June 2026, the Norwegian Parliament adopted amendments to the Norwegian National Security Act to facilitate the establishment of a joint civil-military clearance authority and to provide for more flexible regulation of clearance authorities at statutory level.

The new Norwegian Clearance Directorate (Klareringsdirektoratet, KDIR) is expected to be established by 1 January 2027. The Directorate will comprise the current Norwegian Civil Security Clearance Authority (Sivil klareringsmyndighet, SKM), clearance cases currently handled by the Norwegian Defence Security Department (Forsvarets sikkerhetsavdeling, FSA), and certain user-facing clearance-related tasks currently carried out by the Norwegian National Security Authority (Nasjonal sikkerhetsmyndighet, NSM).

The Norwegian Civil Security Clearance Authority has stated that it will provide ongoing information to entities with clearance needs in both the military and civilian sectors.

New regulation on cybersecurity certification

A new regulation on cybersecurity certification entered into force in Norway on 23 June 2026. The regulation implements the EU Cybersecurity Act into Norwegian law. The implementation of the framework in Norway aims to raise the overall level of cybersecurity, resilience and trust in digital products and services. It establishes a common European framework for voluntary cybersecurity certification of ICT products, ICT services and ICT processes. The regulation facilitates access for Norwegian businesses to cybersecurity certifications that will be valid throughout the EEA.

Entry into force of the Crowdfunding Regulation

As discussed in the previous quarterly update, the Norwegian Parliament has adopted a new act on crowdfunding, which implements Regulation (EU) 2020/1503) (the “Crowdfunding Regulation“) and supplementary provisions. The implementation means that Norwegian crowdfunding service providers will be subject to a fully harmonized and comprehensive framework for loan and investment-based crowdfunding of business activities. The new act will apply from 1 August 2026.

Amendments to the Financial Institutions Act

A number of amendments to the Norwegian Financial Institutions Act will enter into force on 1 July 2026, including:

• Amendments to the rules on confidentiality in the Norwegian Financial Institutions Act section 16-2. The aim of the new rules is to facilitate sharing of confidential information between financial institutions, to the police, and to certain e-ID and trust service providers to prevent and detect fraud and misuse of electronic identities. The new rules will allow information sharing for economic crimes and, in special cases, other serious crime, but with a higher threshold and only where the disclosure is necessary.
• Amendments to the exemptions from the licensing requirements for financing activity to allow for the provision of credit to associated companies, i.e.,where the creditor has an ownership interest amounting to at least 20 % of the voting rights of the company.
• Amendments to the rules in the Financial Institutions Act section 5-1 which clarifies that subsidiaries of EEA financial institutions have the same requirements in relation the number of directors of the board as Norwegian financial institutions.

Other amendments presented in the proposal, notably the implementation of CRD VI, have not yet received a date for entry into force.

First batch of CASP authorisations

The transitional period under Regulation 2023/1114 (“MiCA“) applies until 1 July 2026, meaning that unauthorised service providers must wind down their services. The first MiCA authorised Crypto-Asset Service providers (“CASP“) incorporated in Norway received their authorisation during the course of Q2 2026. In addition to other regulated financial entities who may provide crypto-asset services pursuant to MiCA art. 60 and CASPs licensed in another EEA member state who have already notified cross-border services into Norway pursuant to MiCA art. 65, this marks the first batch of Norwegian licensed CASPs who have received authorisation from the Norwegian Financial Supervisory Authority.

Guarantee scheme for non-life insurance

In December 2025, amendments were adopted to extend the Norwegian guarantee scheme for non-life insurances. The amendments have not yet entered into force. At present, membership of the scheme is limited to Norwegian licensed non-life insurers and Norwegian branches of foreign EEA-insurers. The amendments extend the scheme to cover non-life insurance policies when sold in Norway by EEA insurers on a cross-border on a FoS-basis without a Norwegian branch. This will entail new reporting requirements to the NFSA for foreign insurers operating in Norway on a FoS-basis. 

On 18 June 2026, the Ministry of Finance published for consultation a paper addressing certain aspects of the guarantee scheme, such as access to legal proceedings and calls for funds. The consultation paper is available here (Norwegian only), and the consultation deadline is 18 September 2026. The draft regulation itself leaves the commencement date open, but assuming the Ministry’s consultation letter governs this point, the changes are intended to enter into force on 1 January 2027.

Public consultation on amended ownership rules for financial institutions

In judgment E-24/24 of last year, the EFTA Court held that it is contrary to EEA law to maintain an administrative practice requiring notification and approval of acquisitions at thresholds other than those set out in the CRD IV Directive and the Solvency II Directive. It is also contrary to EEA law to maintain a practice that restricts the ability of individual owners to own more than 20 to 25 per cent of the ownership interests in banks or insurance companies unless the refusal is based on a specific assessment of whether the owner is suitable. On 24 June 2026 the Norwegian Financial Supervisory Authority published a draft public consultation paper proposing certain amendments to the rules in the Norwegian Financial Institutions Act on (i) ownership assessment in connection with the granting of authorisation, (ii) subsequent acquisitions of qualifying holdings, and (iii) orders and coercive measures that may be used against qualified owners. More information can be found in our newsletter on this matter, available here.

The Norwegian M&A market remained resilient in H1 2026, despite changing macroeconomic conditions, geopolitical uncertainty and shifts in investor sentiment. Buyers have continued to be selective and price-disciplined, but activity levels indicate that high-quality Norwegian assets still attract interest, particularly in sectors supported by long-term structural drivers.

Interest rate expectations, inflation, currency movements and global uncertainty have all affected market conditions. Even so, investors appear more comfortable operating in this environment than they were in the recent past. Strategic buyers and financial sponsors continue to pursue transactions where the case for growth, consolidation or long-term value creation is clear.

The public markets presented a mixed picture in H1 2026. Public M&A activity was selective and lower by deal value than in recent years, with a limited number of announced transactions driven by clear strategic or financial rationale. By contrast, IPO and listings activity showed renewed momentum, with 13 listing events across Euronext Oslo trading venues, including two IPOs on Oslo Børs, several new admissions on Euronext Growth Oslo, uplistings and alternative listing routes such as reverse takeovers and spin-offs.

Overall, the Norwegian M&A market enters the second half of 2026 with a constructive outlook, supported by international interest, active financial sponsors and continued demand for businesses positioned within technology, industrial capacity, energy, infrastructure and other strategically important sectors.

Key market observations:

Deal activity: The Norwegian M&A market declined in H1 2026 compared to the same period in 2025, with 442 registered transactions, compared with 537 transactions in H1 2025. The figures are consistent with our observation of a more selective market environment, with investors and strategic buyers placing greater emphasis on transaction quality, industrial logic and long-term value creation.

Sector focus: Sector activity was diversified during the first half of the year. We continue to see high deal volumes in business services and construction, driven by PE-backed buy-and-build plays. Although technology-related M&A continues to play an important role, volumes are lower than in the previous year, partially driven by a drop in software deals. We have also observed strong interest in assets linked to industrial capacity, maritime technology, energy security, infrastructure, defence-adjacent capabilities and seafood-related businesses, supported by heightened geopolitical uncertainty and increased emphasis on robust supply chains.

Cross-border activity:  The market continues to be heavily reliant on inbound M&A, with foreign buyers accounting for 43% of registered Norwegian transactions in H1 2026. The figure is up from 38% in 2025 and underlines the continued importance of international capital to the Norwegian market. It is worth noting that the United States was a notable driver of this trend, with both transaction volume and reported deal value increasing significantly, while Sweden maintained its position as the most active foreign investor country by number of transactions.

Private equity and venture capital: Financial sponsors continued to play an important role in the Norwegian M&A market in H1 2026, particularly through PE-backed buy-and-build strategies in fragmented markets. Professional services remained an area of notable activity, while technology continued to attract both PE and VC investment, especially where businesses have recurring revenues, scalable models and clearer paths to profitability. Sponsor-to-sponsor transactions and other private market liquidity solutions also remained relevant in a market where IPO exits are limited and trade buyers remain selective.

IPO and listings market: The IPO and listings market showed renewed momentum in H1 2026, with 13 listing events across Euronext Oslo trading venues. Activity consisted primarily of new admissions on Euronext Growth Oslo and uplistings to Oslo Børs, supplemented by reverse takeover and spin-off activity, while traditional main-market IPO activity remained selective with two IPOs completed on Oslo Børs. Aggregate transaction value across the recorded listing events amounted to approximately NOK 9.2 billion.

Public M&A: Public M&A activity was selective in H1 2026 and lower by deal value than in recent years, with six public M&A events relating to five targets and announced transaction value of approximately NOK 10 billion. Activity was concentrated around transactions with clear strategic or financial rationale, including Zalaris, Vantage Drilling, MatvareExpressen and Elmera, with the latter becoming a competitive process in late June.