Employers have until 30 June 2022 to comply with changes to Norway’s mandatory occupational pension (“OTP”) that took effect on 1 January 2022, and existing OTP rules apply until then. Nearly all Norwegian employers are subject to OTP requirements, and should consider their approach to implementing the legislation, as well as informing the steering groups of pension schemes with 15 or more members, before final decisions are made.

Highlights

• The minimum age for OTP enrollment is now 13 years. Seasonal workers are no longer subject to separate pension regulations and must be enrolled in a pension scheme.


• Employers must contribute a minimum 2% of employees’ income for employees earning NOK 1,000 or more. Contributions are calculated on all salary from NOK 1 up to NOK 1,276,788 (as of 1 May 2021). Scheme rules can also allow for employee contributions, but they cannot replace the employer’s mandatory minimum contribution.


• Contributions are not payable on one-time assignments valued at less than NOK 1,000. Employees in nongovernmental organizations are entitled to OTP membership if their salary is NOK 10,000 or more.


• Employers that do not comply will be subject to financial and criminal penalties. A daily enforcement fine of NOK 250 per employee will be levied until the employer establishes a pension scheme.


• Part-time workers will no longer have to fulfill a minimum requirement of 20% of full-time employment to be enrolled in a pension scheme, and now all employees must register for the scheme.

Related resources

Non-Mercer resources

• Government announcement (The Norwegian Tax Administration)

Mercer resources

• Changes in legislation for occupational pension (February 2022)