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.
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
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 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
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.
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.
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.
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.
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.
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:
Correct income statements to NAV — quality assured before submission
Systems for continuous tracking and reconciliation of reimbursement claims
Written repayment agreements with each employee
Control routines to verify that conditions are met before payment
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.