1. Status of implementation
  2. National deviations
  3. Loan origination regime
  4. Regulatory guidance

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Norway
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Status of implementation

Norway is in the initial phases of the transposition process. The public consultation period ended on 9 January 2026, and a final proposal for an act of parliament can be expected after the EU/EEA discussions have been concluded, with a degree of implementation delay compared with the EU timetable. The proposal includes amendments to the Norwegian Act on Securities Funds and the Norwegian Act on Alternative Investment Fund Managers.

National deviations

There are a few areas where the initial proposal includes additional national rules, and those elements were criticised in the consultation process. The proposal may still be revised before the implementing act is finalised and passed by Parliament. The main points are as follows:

  • Non-professional investors: the proposed implementing act would require FSA approval not just for the marketing of AIFs to non-professional investors, but for any offering of AIFs to such investors. This would effectively ban primary investment by non-professional investors in AIFs without marketing permission, including investment based on reverse solicitation, subject to a limited exemption for certain employees of the manager.
  • Qualified non-professional investors: the proposal introduces a regime modelled on the EUVECA, EUSEF, and ELTIF Regulations. Authorised AIFMs would be allowed to apply for permission to offer investments in an AIF they manage to investors who commit at least EUR 100,000 and declare that they are aware of the risks. This option would not be available to registered AIFMs, whether in Norway or in other EU/EEA States.
  • Depositary rules: the proposed implementing act does not allow Norwegian AIFs to appoint a depositary established outside Norway.

Loan origination regime

The new loan origination regime entails a material regime change in Norway, where providing credit has so far been reserved for credit institutions, subject to limited exceptions. Provision of consumer loans is prohibited in the initial proposal and would remain reserved for licensed credit institutions. Because the Norwegian prohibition on non-bank lending also extends to secondary trading, the proposal would not allow AIFs to acquire existing loans or loan portfolios and would limit them to originating new credit. No other national requirements or jurisdiction-specific supervisory expectations are currently expected on top of the new regime.

Regulatory guidance

No guidance or supervisory position has been issued at this stage.