Norway


Adopted amendments to the Immigration Act

Impact date: 15 September 2026

The Norwegian Parliament has adopted amendments to the Immigration Act intended to strengthen the protection of foreign workers who are vulnerable to exploitation.

Under the current rules, it is a criminal offence to exploit a foreign worker in an improper manner in connection with the provision of work or housing. The amendment extends criminal liability so that employers may also be penalized for exploitation within the employment relationship itself.

The amendment raises the maximum penalty from two years' imprisonment to three years' imprisonment. For serious offences, the maximum penalty will be six years' imprisonment. The purpose of the amendment is to strengthen the protection of foreign workers, while also helping to combat labor market crime and social dumping.

Employer implications/action needed Employers using foreign labour should review pay, working time, housing and recruitment practices to ensure compliance.

Employer risk The new rules extend criminal liability for exploitation within the employment relationship, with significant sanctions for serious breaches.

Links Norwegian Parliament Committee Report (Norwegian only)

Norwegian Government Bill (Norwegian only)

Proposal for amendments to the National Insurance Act and the Working Environment Act

Impact date: Awaited

The Ministry proposes amendments to the National Insurance Act and the Working Environment Act relating to the duties of cooperation, activity, and workplace accommodation in cases of sickness absence.

The main elements of the proposal are to:

  • clarify the employee's duty during sick leave to provide information and to cooperate, both under the National Insurance Act and the Working Environment Act, and to extend the duty to cooperate under the National Insurance Act to include an obligation to temporarily perform work other than that stipulated in the employment contract
  • maintain the obligation under the National Insurance Act to participate in work-related activity in a new provision, and clarify that the employee's duty during sick leave to remain active applies to the greatest extent possible
  • clarify in the Working Environment Act that the employer's duty to provide reasonable accommodation for employees with reduced work capacity, in principle, also encompasses permanent accommodation measures
  • bring forward the employer's obligation to submit the follow-up plan to the Norwegian Labor and Welfare Administration no later than after four weeks of sick leave. This corresponds to the same deadline by which the employer must submit the follow-up plan to the doctor certifying the sick leave

The consultation deadline of 15 March 2026 has passed, and the consultation responses have been published. Sickness absence and measures to reduce it have attracted considerable attention. In May 2026 the Government issued new guidelines on sickness absence practice, including that graded sick leave should be the norm. No further action has otherwise been taken in respect of the proposal, and current legislation is still unchanged.

Employer implications/action needed Employers may need to:

  • consider longer-term, including potentially permanent, workplace adjustments as part of their accommodation duty
  • bring forward internal timelines so the follow-up plan is prepared and sent to NAV no later than four weeks after the start of sick leave, matching the deadline of the doctor certifying the sick leave

Employer risk N/A

Link Consultation on Proposed Amendments to the National Insurance Act and Working Environment Act (Norwegian only)

Overtime pay for part-time work exceeding the agreed working time percentage

Impact date: Awaited. The working group is due to propose its solutions by 1 September 2026.

In light of EU case law, a key issue in Norway is whether part-time employees are entitled to overtime pay for work performed in excess of their agreed working time percentage. A working group has been appointed to assess overtime pay for part-time employees.

While the working group has been considering this issue, several judgments have been handed down by lower courts. Although these judgments are not legally binding as precedents, they appear to have made it necessary to amend the group’s mandate. Going forward, the working group will therefore proceed on the assumption that the Norwegian rules on compensation for additional work will be amended. It will no longer consider whether the current rules are compatible with EEA law.

Among other things, the working group will propose regulatory amendments intended to prevent discrimination between part-time and full-time employees in relation to payment for additional work and overtime.

Employer implications/action needed Employer organizations encourage employers to consider entering into temporary supplementary agreements with part-time employees who wish to increase their working time percentage in connection with the absence of other employees. Employers should also consider whether some of the additional work can be covered by using on-call staff.

Employer risk Employers should be aware that using part-time employees to perform additional work may result in extra costs in the form of overtime supplements.

Link Regjeringen endrer mandatet for gruppa som skal se på overtid for deltidsarbeid (Norwegian only)

Proposals for changes to parental rights in working life sent out for consultation

Impact date: Awaited. The proposal has been circulated for consultation. The consultation deadline was 1 August 2026.

The Ministry of Children and Family Affairs has circulated NOU 2026: 2 Policy for new generations for consultation. The report was submitted on 9 February 2026 and includes proposed measures to help increase birth rates in Norway, including proposals concerning parental rights in working life.

Among other things, the committee proposes a review of the rules on parental leave, parental benefits, and the duty to accommodate parents with young children. It also proposes a pilot scheme for reduced working hours for parents of young children within the parental benefit scheme. The scheme is aimed at occupational groups with limited flexibility.

Employer implications/action needed If adopted, it may affect future framework conditions.

Employer risk Low at this stage, as no changes have been adopted. Future follow-up may, however, affect parental leave planning and working time flexibility for parents of young children.

Links Politikk for nye generasjoner - Årsaker, konsekvenser og tiltak knyttet til lave fødselstall (Norwegian only)

Høring av NOU 2026:2 Politikk for nye generasjoner (Norwegian only)

NOU 2026: 2 Policy for new generations (English summary)

Proposal to authorize regulations requiring contracting authorities to monitor suppliers’ compliance with HSE card requirements

Impact date: The Norwegian Parliament has considered the matter at first and second reading. It is now awaiting its third reading.

In Prop. 78 L (2025-2026), the Ministry of Labor and Social Inclusion proposes amendments to the National Insurance Act and the Working Environment Act.

The proposed amendment to the National Insurance Act would provide a statutory basis for the Norwegian Labor and Welfare Organisation (NO: NAV) to deduct trade union fees from certain benefits, including sickness benefit, parental benefit, pregnancy benefit, care and training benefit. This is already established practice, but the proposal would ensure a clear legal basis for making such deductions.

The Ministry also proposes amending section 4-1, seventh paragraph, of the Working Environment Act, which already authorizes the adoption of regulations on HSE card requirements in selected industries. The amendment would make it possible to issue regulations requiring contracting authorities to follow up contractors’ compliance with HSE card requirements, including through contractual terms and monitoring of compliance.

Employer implications/action needed Employers should note the NAV deduction clarification. Contracting authorities should prepare for possible HSE card follow-up duties.

Employer risk Mainly linked to increased contractor monitoring obligations.

Links Endringer i folketrygdloven og arbeidsmiljøloven (trekk av fagforeningskontingent i ytelser og hjemmel for oppdragsgiveransvar for å sikre overholdelse av krav om HMS-kort) (Norwegian only)

Endringer i folketrygdloven og arbeidsmiljøloven (trekk av fagforeningskontingent i ytelser og hjemmel for oppdragsgiveransvar for å sikre overholdelse av krav om HMS-kort) (Norwegian only)

Reimbursement of sickness benefit from NAV

Impact date: Awaited. The proposal has been circulated for consultation. The consultation deadline was 30 August 2026.

Under the National Insurance Act, sickness benefit is paid directly to the person on sick leave. In some cases, however, it is agreed that the employer will advance the payment. The employer may then claim reimbursement from the Norwegian Labor and Welfare Organisation (NO:NAV), and the current deadline for submitting such a claim is three months. During this year's wage negotiations between Fellesforbundet and Norsk Industri, the Minister of Labour and Social Inclusion announced that the Government would propose extending the deadline from three to six months. To follow up the negotiations, an amendment to the National Insurance Act is required.

Employer implications/action needed If adopted, the change only gives employers more time to claim reimbursement from NAV. Payroll and HR routines should be updated to reflect the new six-month deadline.

Employer risk N/A

Link Consultation on Proposed Amendments to Section 22-13 of the Norwegian National Insurance Act (Norwegian only)

Health and safety at work

Impact date: Awaited. The proposal has been circulated for consultation. The consultation deadline is 28 August 2026.

The Ministry proposes to implement Regulation (EU) 2023/1230 on machinery (the EU Machinery Regulation) by means of new regulations, while repealing the current Regulations of 29 December 2009 on machinery (the 2009 Machinery Regulations). This also requires an amendment to the authority to issue regulations in section 5-5, seventh paragraph, of the Working Environment Act.

Employer implications/action needed If implemented, employers that manufacture, import, sell, rent out or lend machinery and other work equipment must comply with the new requirements.

Employer risk N/A

Link Norwegian Government Consultation on Proposed New Machinery Regulations and Amendments to the Working Environment Act (Norwegian only)

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Sten Foyn Partner


E: s.foyn@haavind.no T: +47 928 35 278

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Martin Haukland Senior Lawyer


E: m.haukland@haavind.no T: +47 414 61 776

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