NORWAY Law and Practice Contributed by: Daniel Nygaard Nyberg, Karoline Ulleland Hoel, Ole Andenæs and Jens Fredrik Bøen, Wikborg Rein Advokatfirma AS
As of the end of 2024, assets under management (AUM) for Norwegian AIFMs reached NOK381.7 bil - lion, representing an increase of NOK70 billion from the end of 2023 (22.5% increase over the previous year). The increase is mainly due to the establishment of new funds. However, the number of AIFMs report - ing to the FSAN decreased to 225, down by six man - agement firms. This decline may, among other factors (such as the global market climate), be attributed to the ongoing trend of consolidation and concentra - tion of AUM among fewer and larger alternative fund managers, a pattern that has also been increasingly observed in Norway over the past few years, in line with global developments. There is a trend towards establishing more Norwe - gian fund structures (ie, onshoring), but the use of offshore jurisdictions such as Jersey, Guernsey and Luxembourg is also quite common. Figures show an increase of 43 Norwegian AIFs from 2023 to 2024. This domestic expansion has also spurred the growth of service providers in areas ranging from fund admin - istration and depositary services to compliance and risk management. In 2024, Norwegian companies received more than NOK60 billion in investments, mainly from foreign pri - vate equity funds, according to the Norwegian Venture Capital Association. It appears that the trend of acqui - sition by foreign funds will continue, highlighting Nor - way’s consistent appeal as an investment destination. Given the steadily increasing number of AIFs and growing number of AUM, Norway continues to be a compelling jurisdiction for alternative funds, managers and investors. 1.2 Key Trends ESG ESG considerations continued to play an important part in several aspects of alternative asset manage - ment in 2025, for example, in fund formation, invest - ment processes and especially in the marketing of funds. The FSAN requires specific documents to approve the marketing of AIFs to investors in accordance with the AIFM Act. Part of this marketing is to provide informa -
tion in relation to the EU Sustainable Finance Disclo - sure Regulation (SFDR). For example, SFDR Article 7 requires AIFMs to provide investors with information about whether the fund will take principal adverse impacts (PAIs) on sustainability factors into consid - eration. If not, the AIFM must give a clear and rea - soned explanation as to why it does not take PAIs into consideration. On a fund level, reporting on PAI mandates the col - lection of data from portfolio investments. Collecting data is challenging and this is why many AIFMs do not consider PAIs on sustainability factors. In fact, it often happens that AIFMs use the lack of data as the (sole) reason for not taking PAIs into consideration. Due to relevant data becoming more available, however, the regulatory authorities appear to have tightened up on the possibility of using “miss - ing data” considerations as the only reason for not assessing PAI indicators. There has been a substantial increase in the focus on ESG considerations when investing, with a growing number of investors only investing in so-called Article 9 funds. Beneficial Owners In recent years, the importance of adequate access to information regarding beneficial owners has been emphasised, both internationally and in Norway. The Register on Beneficial Owners Act was implemented in two stages: initial provisions took effect in 2021, and the full regime became operational on 1 October 2024, with a transitional period for registration until 31 July 2025. Most Norwegian companies and legal entities, includ - ing AIFs and AIFMs, have now filed their beneficial ownership information, while non-compliant entities face compulsory fines. Access to the register is lim - ited, and it is primarily available to public authorities, Norwegian financial and non-financial regulated enti - ties for KYC purposes, the media and education insti - tutions.
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