Digital Payments & Fintech · Norway
Fintech & digital payments rules in Norway (2026)
Norway shaded by its digital payments & fintech status
Norway operates a clear, EEA-aligned licensing regime for digital payments and fintech. Payment institutions and electronic money institutions must be licensed by Finanstilsynet under the Financial Institutions Act, which transposes PSD2/EMD2; the private-law and consumer-protection aspects (including PSD2 conduct rules and consumer credit) sit in the Financial Contracts Act. Open banking is live via PSD2 APIs, while the EU's newer Instant Payments Regulation and Payment Services Regulation are not yet incorporated into Norwegian law.
Key points
Finanstilsynet is the financial supervisory authority; it assesses and grants (or recommends to the Ministry of Finance) licences for payment and e-money institutions, with a statutory three-month decision period and an NOK 30,000 application fee.
Payment institutions (full and limited) and electronic money institutions are licensed under the Financial Institutions Act (2015). As at 31 December 2021, 33 payment institutions and 6 e-money institutions held Norwegian licences.
As an EEA member Norway implemented the revised Payment Services Directive (PSD2) into national law in April 2019 (live September 2019); banks and PSPs provide account-access and payment-initiation APIs, largely on Berlin Group NextGenPSD2 standards, supervised by Finanstilsynet.
A new Financial Contracts Act (finansavtaleloven) entered into force on 1 January 2023, carrying the private-law part of PSD2 plus consumer-credit and creditworthiness-assessment obligations on lenders.
The EU Instant Payments Regulation (adopted March 2024, incl. Verification-of-Payee) has not yet been incorporated into the EEA Agreement or transposed into Norwegian law; incorporation is anticipated around 2026–2027, and a domestic VoP duty for NOK transfers would likely follow only with the future EU Payment Services Regulation (PSR).
Buy-now-pay-later and similar deferred-payment products are treated as consumer credit under the Financial Contracts Act, requiring lender creditworthiness assessment; lending practices are further constrained by the lending regulation (utlånsforskriften), with EU Consumer Credit Directive II tightening rules going forward.
Timeline - major decisions & events
The act incorporating EU Regulation 2022/2554 (Digital Operational Resilience Act) took effect 1 July 2025, replacing Finanstilsynet's existing ICT regulation for all supervised financial entities including payment institutions and e-money institutions. It mandates ICT risk-management frameworks, incident reporting, resilience testing, and oversight of third-party ICT providers, with fines up to NOK 50 million for breaches.
Finanstilsynet ↗The Ministry of Finance tabled the bill 'Lov om kryptoeiendeler (kryptoeiendelsloven)' to incorporate EU Markets in Crypto-Assets Regulation (MiCA) into Norwegian law via an EEA incorporation clause. Entry into force was anticipated from 1 July 2025 with a 12-month transitional period for the approximately 13 virtual-asset service providers already registered with Finanstilsynet.
Wiersholm (covers Prop. 55 LS 2024–2025) ↗Parliament passed the Cybersecurity Act on 23 December 2023 implementing EU NIS Directive obligations on operators of essential digital services, including payment infrastructure. It imposed mandatory security measures and incident-notification duties for fintech and payment firms, complementing PSD2's existing security requirements.
Global Legal Insights — Norway Fintech 2025 ↗A wholly rewritten Financial Contracts Act took effect, fully implementing PSD2's private-law provisions and extending strong consumer-protection rules to all digital payment services. It tightened liability rules for unauthorised transactions, capped consumer liability, and brought investment services within scope, replacing the 1988 Act.
Signicat (covers Act of 18 Dec 2022 no. 146) ↗Following a 2019 government green light, Finanstilsynet opened its regulatory sandbox with a February 2020 application deadline, allowing fintech firms to test innovative payment and financial products under supervisory guidance before full licensing. The sandbox provided a structured route to identify required licences and compliance obligations for novel digital-payment business models.
Finanstilsynet ↗A modernised Central Bank Act took effect 1 January 2020, reinforcing Norges Bank's statutory mandate for licensing and oversight of interbank payment systems and financial market infrastructure. It clarified the division of supervisory responsibilities between Norges Bank and Finanstilsynet for systemic payment systems.
Norges Bank ↗From 14 September 2019, Norwegian banks were required to provide standardised API interfaces to licensed third-party payment service providers, and strong customer authentication became mandatory for online transactions. This operationalised open banking in Norway, enabling authorised fintech payment-initiation and account-information services to access bank accounts on customers' behalf.
Finanstilsynet ↗Amendments to the Financial Institutions Act and Payment Systems Act (Prop. 110 L 2017–2018) and the new Regulation on Payment Services Systems (forskrift 15 Feb 2019 no. 152) created two new Finanstilsynet licence categories: payment initiation service providers (PISP) and account information service providers (AISP), transforming Norway's payment-services licensing regime.
Lovdata — Forskrift om systemer for betalingstjenester ↗Norway's new Anti-Money Laundering Act (implementing EU's 4th and 5th AML Directives) took effect 15 October 2018, requiring all virtual-currency exchange and custodial-wallet providers to register with Finanstilsynet and conduct customer due diligence. This was Norway's first formal AML regulatory requirement specifically targeting crypto-asset businesses.
Finanstilsynet — Annual Report 2020 ↗Act of 10 April 2015 no. 17 created a single, modern licensing and prudential framework for all financial entities — banks, payment institutions, and e-money institutions — supervised by Finanstilsynet. It became the primary vehicle for transposing subsequent EU directives (PSD2, EMD2) and established the capital and governance requirements for fintech licence categories.
Lovdata — Finansforetaksloven ↗Act No. 48 of 19 June 2009 (in force 21 December 2009) transposed EU Payment Services Directive 2007/64/EC, introducing for the first time a dedicated Finanstilsynet payment institution licence allowing non-bank entities to provide payment services. This broke the bank monopoly on payment services and laid the licensing groundwork that PSD2 later built upon.
Finanstilsynet — Banking and Finance Laws ↗Act of 17 December 1999 no. 95 established Norges Bank's authority to license and oversee interbank payment systems and financial market infrastructure, setting Norway's foundational legal framework for systemic payment oversight. It remains the primary statute governing systemically important payment systems and the legal basis for Norges Bank's ongoing oversight role.
Norges Bank — Payment Systems Act ↗Norway - other topics
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