Advance payment of sick pay in Norway: What employers must know

From 1 January 2027, new Norwegian collective agreement provisions will require employers to advance payments of sick pay, parental benefits and care benefits (advance payment obligation). This entails more responsibility than many employers expect, and the regulations impose requirements on both administration and documentation. In this article, we explain what you need to do in practice and highlight important pitfalls to be aware of. 

Who does the advance payment obligation apply to?

The obligation applies to companies that are bound by a collective agreement – either concluded following a demand from a trade union or through a direct agreement with employee representatives. Merely being a member of an employer organization is not sufficient.

The rules come into force on 1 January 2027 and apply to employees who have been continuously employed for at least six months and are covered by the collective agreement.

Even companies without a collective agreement should familiarize themselves with the rules. The scheme will likely have a spillover effect due to competition, recruitment and internal HR policies.

Also read: Sick pay regulations for employers in Norway

What does advancing sick pay mean in practice?

Advancing payment means that the employer pays the benefit after the employer period has ended. For sick pay, this means from day 17 – i.e., the day after the 16 days that the employer must always cover themselves. You then claim reimbursement from NAV.

The scheme is limited to four months per calendar year – including the employer period.

An important limitation: You are only obligated to cover what NAV reimburses. Any difference beyond the reimbursement basis is not your risk.

The advance payment obligation – five things you as an employer must have in place

1. Correct income statement to NAV

The income statement forms the basis for the entire reimbursement. Errors here may result in direct financial loss.

NAV proposes a monthly income automatically – but this is only a starting point, not the final answer. Salary changes, holidays, leave, changes in position and bonuses are not always captured in the calculation. You must verify this yourself.

If you advance full salary but report a lower amount, you bear the difference. Therefore, establish clear routines for:

When the income statement should be submitted Who is responsible for submission How the information is verified before submission

2. Ongoing follow-up of reimbursement

The liquidity burden lies with you until NAV pays out, and this requires active follow-up. You need systems to:

• Track reimbursement claims

• Reconcile payments against received reimbursements

• Manage discrepancies quickly

This will not resolve itself.

3. Written repayment agreement

You must have a written repayment agreement with the employee before advancing payments begins. If NAV rejects or reduces the benefit, you must be able to reclaim the excess, and a clear agreement is essential.

Collective agreements assume that the employee enters into such an agreement. The clearer the terms, the easier it is to manage any disputes.

4. Verification of conditions

The advance payment obligation does not apply automatically. You must ensure that the conditions are met before making payments. Check that:

• The employee meets the eligibility requirements

• A valid sick note or decision from NAV is in place

• The employee fulfills their duty to cooperate

If any of these conditions fail, the obligation to advance payments ceases.

5. Adaptation of payroll systems

Your payroll system must handle advance payments correctly, both for tax purposes and in relation to NAV’s reimbursement basis. This requires specific adjustments in payroll and HR systems, which should be in place well before January 2027.

When does the advance payment obligation cease?

The obligation ceases if NAV rejects the reimbursement claim or if the employee does not meet their obligations. You are not expected to bear the risk of a lack of entitlement to benefits – but only if you have acted diligently throughout the process.

Is your business ready for the Norwegian advance payment obligation?

Advancing payments is not just a payout arrangement. It is an administrative process that requires solid routines, clear agreements and close follow-up with NAV.

From 1 January 2027, you must have the following in place:

1. Correct income statements to NAV — quality assured before submission

2. Systems for continuous tracking and reconciliation of reimbursement claims

3. Written repayment agreements with each employee

4. Control routines to verify that conditions are met before payment

5. Payroll systems adapted to advance payments — both for tax purposes and in relation to NAV’s reimbursement basis

Do you have the necessary routines in place? If not, now is a good time to start. Feel free to contact us for a review of what the regulations specifically require of your business.