NORWAY Law and Practice Contributed by: Harald Sætermo, LexOslo
Decisions by Datatilsynet may generally be appealed to the Norwegian Privacy Appeals Board and may ultimately be challenged before the ordinary courts.
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 consulta - tion on draft AI Act implementation was published in 2025. Businesses using or providing AI systems in Norway should monitor the timing of EEA incorpora - tion and Norwegian implementation. Corporate compliance has also become more trans - parent. 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 regula - tion and continued tax compliance developments.
9. Looking Forward 9.1 Upcoming Legal Reforms
There are several legal developments that foreign investors should monitor, although Norway is not cur - rently undergoing a single comprehensive business law reform. The most important development is in foreign invest - ment control. Norway already has ownership control rules under the Norwegian Security Act, and amend - ments 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 consulta - tion 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 simplifi - cation, 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.
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