Norway updates wage and working rules for offshore and shipping

After several years of political consideration, debate and international opposition, the Norwegian Parliament has now adopted what is described as a historic piece of legislation for Norwegian shipping and offshore activities: Requirements for Norwegian wages and working conditions on all ships in domestic trade and on ships that provide services to industry in Norwegian waters and on the Norwegian continental shelf.

The amendments, which come into force on 1 July this year, have broad support from the trade union movement and a majority of the Norwegian Parliament, but have also been criticized, particularly in relation to EEA law and possible consequences for Norway's position as a maritime nation. For players in the maritime and offshore industry, the decision entails extensive obligations and new regulatory frameworks - and should be carefully considered now.

What does the amendment entail?

The decision includes amendments to the Public Employment Act, the Petroleum Act, the Aquaculture Act, the Marine Energy Act, and the Seabed Minerals Act. The purpose of the amendments is to ensure that work performed in Norwegian waters and on the Norwegian continental shelf is conducted under Norwegian wage conditions, regardless of the flag of the ship or the nationality of the crew.

The amendments are divided into two main tracks:

1. Domestic shipping: Norwegian wages on all ships travelling between Norwegian ports
   From 1 July 2025, universally applicable collective agreements can be applied to all ships in domestic traffic - including those registered in NIS or in foreign ship registers. This includes:
   1. Cargo ships and cruise ships operating exclusively between Norwegian ports. An important exception is cruise ships that combine Norwegian and foreign calls - these currently fall outside the scheme.
   2. Ships that provide services in Norwegian territorial waters, such as hotel ships, maintenance vessels, etc. The relevant universalized collective agreement for this industry is the "Regulations on partial universalization of the Industrial Agreement/VO section for the shipping and shipbuilding industry". It includes provisions on, for example, minimum wages and working hours. 
2. Offshore: Norwegian wage conditions on ships in service for commercial activities
   From 1 January 2026, a legal obligation will be introduced for licensees, i.e. operators and companies that have been granted public permits or licenses to operate offshore, to ensure Norwegian wage conditions for all employees on ships that provide services to their business. This applies to, among other things:
   1. Petroleum activities (platform support, seismic and maintenance)
   2. Offshore wind and other ocean-based renewable energy
   3. Carbon capture and storage
   4. Aquaculture and aquaculture
   5. Mineral extraction on the seabed

The obligation applies to everyone working on board, not just maritime personnel - precisely to prevent boundary problems and ensure real compliance.

The legal basis - what does the formal decision say?

Here are the main highlights of the legislation:

1. Extension of the Public Sector Notification Act (section 2 no. 2): The law states that the Public Sector Employment Act now also applies to:
   1. Ships registered in NIS and foreign ship registers if they operate in domestic traffic in Norway.
   2. This includes ships that carry cargo or passengers between Norwegian ports, cruise ships that sail exclusively between Norwegian ports, and ships that provide services in Norwegian territorial waters.
2. Clarification of what can be made universally applicable (section 6): Decisions on universalization may only apply to those parts of the collective agreement that regulate wage conditions for ships on domestic voyages.
3. The company's joint and several liability for wages (section 13, second paragraph): The shipping company is made jointly and severally liable with the employer for the payment of wages in accordance with the decision to make the agreement universally applicable - also in the event of hiring or use of third-party staffing.
4. Supervision and sanctions - Norwegian Maritime Authority (Sections 11, 56-57): The Norwegian Maritime Authority (NMA) is granted access to ships, may require documentation, make individual decisions, and impose infringement fees. In the event of a breach, ships may be detained in Norwegian harbors until the matter has been rectified.
5. New obligations for offshore license holders: The amendment entails additions to Section 10-18 of the Petroleum Act, Section 22a of the Aquaculture Act, Section 10-13 of the Offshore Energy Act (new second paragraph) and Section 9-16 of the Seabed Minerals Act, which state that the licensee (the operators and companies that have been granted public permits or licenses to operate offshore) must ensure that employees do not have poorer pay conditions than those that follow from applicable nationwide collective agreements.
6. Entry into force in two stages (VII):
   1. July 2025: Amendments to the Public Sector Employment Act and the Ship Safety Act (domestic shipping).
   2. January 2026: Amendments to sector laws (offshore) - applies to contracts entered after this date.

New legal and practical obligations for industry players

The decision will require significant restructuring, especially for operators and license holders in offshore activities:

• Contractual obligations: Requirements for wage levels and collective agreement coverage must be included in new and existing supplier contracts entered after 1 January 2026.
• Duty to monitor: Licensees must actively follow up that wage conditions are complied with - not only by direct suppliers, but also subcontractors and shipping companies.
• Joint and several liability: Shipping companies will be jointly and severally liable for the payment of wages in accordance with the generalization decision.
• Sanctions: In the event of a breach, the Norwegian Maritime Authority can impose an infringement fee and, in the worst case, prevent ships from leaving port.
  In other words, it's not enough to "expect" compliance - the players have an active follow-up and control obligation.

Tension under EEA law

ESA (the EFTA Surveillance Authority) has previously stated that similar proposals may conflict with the EEA Agreement - in particular the Cabotage Regulation and the rules on free movement. ESA believes that:

• Norway can to a limited extent regulate wages for foreign ships in Norwegian waters.
• It is unclear whether the measure is necessary and proportionate in relation to the objective of social protection.
• The proposal may create uncertainty and distort competition.

The government disputes this, pointing out that the measure is proportionate, not discriminatory, and that it ensures social justice. At the same time, the ministry allows for the possibility that this may be subject to further legal assessment or infringement proceedings by ESA.

A breakthrough in labor market policy - or a cost explosion?

The change in the law is described by the government and the majority as a victory for fairness, equal competition, and Norwegian maritime expertise. The Norwegian Seafarers' Union and the Norwegian Confederation of Trade Unions (LO) have been the driving forces behind the change, pointing out that differences in wage levels have been a systematic threat to recruitment and a well-organized working life at sea.

However, critics - including the Conservatives, FrP and the Norwegian Shipowners' Association - argue that:

• The costs for industry, especially within oil and gas, will be high (estimated at NOK 620 million annually).
• The consequences for the state's tax revenue have not been adequately analyzed.
• Norway could lose its attractiveness as an operations base for international players.

The debate illustrates the ongoing tension between labor fairness and competitiveness, and between national regulation and international obligations.

What should businesses do now?

For companies operating or involved in domestic shipping or providing services to the offshore sector, we recommend the following:

1. Review existing contracts - especially for ships operating in Norwegian waters and on the continental shelf.
2. Update procedures and contract templates with clauses on wage levels and duty of care.
3. Establish control routines and documentation to demonstrate compliance.
4. Keep up to date with the regulatory work - hearings have been announced for autumn 2025.

Do you have any questions or need assistance on how your organization should adapt to the new regulations? We are happy to help, please contact us for a non-binding dialogue.