What happened

The Ministry of Digitalisation and Public Governance opened consultation on a new Norwegian AI Act. The proposal would incorporate Regulation (EU) 2024/1689 and regulate national supervision, coercive fines, administrative penalties and appeals.

The consultation was a proposal, not enacted law. It gave Norwegian organisations a concrete basis for considering supervision, sanctions and national processes, but the final law could change after consultation and EEA processing.

Legal status in Norway

Norwegian bill under consultation, deadline 30 September 2025. The EU AI Act was not yet incorporated or in force in Norway.

What the sources clarify

The consultation proposal was based on Regulation (EU) 2024/1689 and set out a proposed Norwegian supervisory structure, administrative fines and appeals. It gave organisations a concrete view of who might supervise duties, but Parliament had not adopted the model. The consultation closed on 30 September 2025. Preparation therefore needed to separate stable work, such as system inventories and role mapping, from points depending on the final Norwegian text. Organisations offering systems or services in the EU also had to assess the regulation's territorial reach independently of Norway's legislative timetable.

Organisations can use the consultation to create a traceable gap list: which EU obligations already follow from activity in the EU, which Norwegian supervisory and penalty provisions remained proposals, and who owns each action. This separation avoids both late compliance in the EU and treating a Norwegian consultation draft internally as enacted law.

Practical implications

Management should approve two separate roadmaps: one for duties already capable of reaching EU activity and one for Norway's legislative process. Every action should state its source, status and next review point. Supplier and inventory work can then proceed without presenting consultation provisions as current Norwegian law.

Sources

Norwegian Government: “Høring av forslag til norsk KI-lov,” 30 June 2025.

Norwegian Government: “Lov om kunstig intelligens i Norge sendes på høring,” 30 June 2025.

For discussion

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