Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2025

Norway

Norway joined the Global Forum on 1 September 2009. Norway underwent its Second Round of EOIR Peer Review in 2017 (Norway’s 2017 Report),1 which assessed its legal and regulatory framework in force as at 30 May 2017 and its practical implementation, including in respect of EOI requests received and sent, during the review period from 1 April 2013 to 31 March 2016. Norway received an overall rating of Compliant and the individual Elements were rated as follows:

 

	A.1	A.2	A.3	B.1	B.2	C.1	C.2	C.3	C.4	C.5	Overall
Determinations	i.p.b.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	n.a.	C
Ratings	LC	C	C	C	C	C	C	C	C	C

Status of implementation of recommendations issued in the peer review report

Norway received two in-box recommendations in relation to Elements A.1 and A.3.

This monitoring report assesses the actions taken by Norway to address the recommendations issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.

The report concludes that both recommendations are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”. However, the report also notes that the measures taken to address the recommendation on Element A.1 have some gaps. Moreover, the implementation of the new measures needs to be demonstrated. Accordingly, the report adds two new recommendations and advises on actions required.

Element A.1: Availability of ownership information

1. Availability of beneficial ownership information for all relevant entities

 

Recommendation (A.1, framework)	Norway should ensure that beneficial owners of all relevant entities are required to be identified in line with the standard.
Underlying factor	Obligation to identify beneficial owners does not cover all relevant entities as required under the standard because such obligation is contained in the AML law and not all relevant entities, except for foundations, are required to engage an AML obligated person. It is nevertheless noted that considerable amount of beneficial ownership information is available and that the scope of the AML coverage of relevant entities is broad. (see paragraphs 70 et seq. of Norway’s 2017 Report for more information).
Summary of actions reported	In June 2021, Norway enacted a new Beneficial Ownership Act and related regulations introducing obligations on a wide range of relevant entities to identify their beneficial owners. These obligations came into force on 1 November 2021.The requirements cover most legal entities, with some exceptions like small foundations and certain highly transparent entities such as government-owned entities. The obligations require all entities to identify their beneficial owners and all relevant persons to cooperate and provide the required information to the entity to facilitate the process of identifying beneficial owners. The entities were also obliged to provide the beneficial ownership information to competent authorities, upon request. Further, since 1 October 2024, entities are required to submit their beneficial ownership information to a central register.
Conclusion	Norway appears to have taken appropriate actions to address the legal issue regarding the coverage of beneficial ownership obligations. Norway has refined its legal framework by introducing obligations on a wide range of entities to identify their beneficial owners, through the new Beneficial Ownership Act and regulations. There are exceptions on some entities to not identify beneficial owners under this new Act; however, such entities are already obliged to engage persons and professionals who are obliged by the anti‑money laundering laws to conduct customer due diligence and to identify beneficial owners of their customers. The new Beneficial Ownership Act and anti‑money laundering laws, taken together, require that beneficial ownership information be available for all relevant entities. Although the obligations address the issue of coverage of beneficial ownership requirements as raised in the 2017 Report, the legal and regulatory framework does not fully enable the availability of up‑to‑date beneficial ownership information as entities may not be aware of changes in their beneficial ownership and are not required to check for changes periodically. Consequently, Norway is recommended to ensure that up-to-date beneficial ownership information is available for all relevant entities, in line with the standard. Further, the obligations for entities to identify their beneficial owners and to submit beneficial ownership information to a central register are recent. The implementation of these obligations has started with Norway sending notices and reminders to entities to submit their beneficial ownership information and conducting preliminary checks on the submitted information. Therefore, Norway is recommended to monitor the implementation of the new beneficial ownership register, carry out suitable supervisory mechanisms and enforce compliance by all relevant entities in order to ensure the availability of accurate, adequate and up-to-date beneficial ownership information in line with the standard.
Status determined	Existing recommendation: Considered provisionally addressed in the context of the monitoring process, subject to detailed validation. Two new recommendations issued.
Actions required	Existing recommendation: No immediate action required. New recommendations: In its next self-assessment, Norway should- Provide an update on the obligations to ensure that the beneficial ownership information reported by entities shall be kept up to date. Provide further updates on the actions taken to implement relevant measures and conduct supervisory actions to ensure that the beneficial ownership information submitted to the central register is accurate, adequate and up to date. Report on the follow-up on non-compliance with the obligations related to identification of beneficial owners and reporting the information to the central register, and the pursuant sanctions issued, if any.

Element A.3: Availability of banking information

2. Availability of identity and beneficial ownership information on bank accounts of trusts

 

Recommendation (A.3, framework)	Norway should ensure that banks are required to identify all of the beneficiaries (or class of beneficiaries) of the trusts which have an account with a bank in Norway as required under the standard.
Underlying factor	Banks are required to identify natural persons who ultimately own or control the trust as part of their customer due diligence measures. However, they are not required to identify all of the beneficiaries (or class of beneficiaries) of the trust as only the natural persons who are beneficiaries of 25% or more of the assets of a trust have to be identified in all instances. (see paragraphs 70 et seq. of Norway’s 2017 Report for more information).
Summary of actions reported	Since June 2018, Norway adopted a new Anti-Money Laundering Act which entered into force on 15 October 2018. The new Act amended the criteria to be used when identifying beneficial owners of trusts and similar legal arrangements. According to the revised criteria, the following persons or groups of persons shall be considered beneficial owners: "a) settlor, b) trustee, c) the protector, d) the beneficiaries or, where individual beneficiaries have yet to be determined, the class of beneficiaries in whose main interest the trust or similar legal arrangement is set up or operates, and e) any other natural person which through direct or indirect ownership or through any other means executes control over the trust or the similar legal arrangement".
Conclusion	Norway appears to have taken appropriate actions to address the recommendation. The definition and methodology to identify participants and beneficial owners of bank accounts associated with trusts have been updated to remove the reference to only identify the beneficiaries of 25% or more of the assets of a trust. Moreover, additional guidance requires looking through each of the parties of the trust if such parties were not natural persons, as required by the standard. Norway reported that the banking sector regulator has conducted supervision to ensure that AML related obligations are well implemented and that they have not come across issues regarding the identification of beneficial owners of trusts. Norway is no longer required to report on this recommendation.
Status determined	Considered provisionally addressed in the context of the monitoring process, subject to detailed validation.
Actions required	No immediate action required.

EOIR experience

Over the monitoring period 2023-2024, Norway received 325 requests and sent 275 requests. Sweden, Poland and Denmark were the top three treaty partners from which Norway received requests. Lithuania, Sweden and the United Kingdom were the key partners in respect of outgoing requests. Norway reported providing full and final responses in all the received requests.

Fifteen members provided peer input on their EOIR relationship with Norway. Peers reported satisfaction in respect of their EOIR experience with Norway.

New developments having a bearing on the EOIR standard

No recent developments that have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Norway or have otherwise come to light.

Next steps

Norway should continue taking actions towards implementing the standard effectively.

Under the first round of enhanced monitoring, two new recommendations have been issued to Norway.

3. Ensuring availability of up‑to‑date beneficial ownership information

 

Recommendation (A.1, framework)

Norway is recommended to ensure that up‑to‑date beneficial ownership information is available for all relevant entities, in line with the standard.

Underlying factor

Norway has introduced obligations on a wide range of entities to identify their beneficial owners, through the new Beneficial Ownership Act and regulations. Although entities are required to report changes to beneficial ownership information within 14 days of a change, the legal and regulatory framework only requires any beneficial owners to disclose information to be registered upon request by the entity (they are not obliged to inform the entity spontaneously), and there is no penalty imposed for a beneficial owner who does not respond to the entity. Moreover, entities are not obliged to check for changes periodically. Therefore, the legal and regulatory framework does not fully enable the availability of up‑to‑date beneficial ownership information as entities may not be aware of changes in their beneficial ownership.

4. Monitoring the implementation of beneficial ownership requirements

 

Recommendation (A.1, practice)

Norway is recommended to monitor the implementation of the new beneficial ownership register, carry out suitable supervisory mechanisms and enforce compliance by all relevant entities in order to ensure the availability of accurate, adequate and up-to-date beneficial ownership information in line with the standard.

Underlying factor

Since October 2024, relevant entities are required to report beneficial ownership information to a central register of beneficial owners. The implementation of these obligations is recent, with Norway sending notices and reminders to entities to submit their beneficial ownership information and conducting preliminary checks on the submitted information. The deadline for submission of information was 31 July 2025 and, thereafter, more robust verification processes, including implementing discrepancy reporting and sanctioning non-compliance, are planned to be implemented.

The following next steps are expected from Norway:

• Submit its next self-assessment, including on the new recommendations issued, in 2028 under the second round of enhanced monitoring.

• See also Chapter 1 (Scope and methodology), section on “PRMG decisions – Statuses determined and actions required”, which explains the next steps expected on recommendations that are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”.

Views/response of the monitored jurisdiction

Norway has not provided a response to the report.

Note

← 1.  OECD (2017), Global Forum on Transparency and Exchange of Information for Tax Purposes: Norway 2017 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/9789264280021-en.