Mandatory occupational pension – when does a business have to have one?

The duty arises when at least one of three conditions is met: two people each in at least 75% positions, one employee without an ownership interest in at least a 75% position, or people in at least 20% positions who together make up two full-time equivalents. The scheme has to be set up within six months. The minimum contribution is 2% of salary up to 12 G, from the first krone – the old 1 G floor is gone.

Separate two questions

The most important thing is to keep these apart: When does the business become obliged to have a scheme? Who has to be included once the duty has arisen? The answer to the first is not the answer to the second, and that is where most older guides go wrong.

The three thresholds

A business has to set up a scheme where at least one of these is met: 1. Two people work and are paid for at least a 75% position each 2. At least one employee without an ownership interest works and is paid for at least a 75% position 3. People each working and paid for at least a 20% position together perform at least two full-time equivalents One condition is enough. Two active owners in 80% positions each therefore trigger the duty on their own. One owner-employee in a 100% position normally does not.

The 20% threshold is no longer a membership threshold

This is the most common error in older guidance. The 20% threshold is still used in one of the conditions for whether the employer becomes obliged to have a scheme. But once a scheme exists, there is no longer a general requirement of at least a 20% position to receive pension. Following the «pension from the first krone and the first day» reform, very small part-time positions can be covered too.

Pension from the first krone

The minimum contribution is 2% of salary up to 12 G. The old 1 G floor is gone. The pension plan can still lawfully leave certain items out, including overtime, some benefits in kind and expense allowances. What the plan actually says decides – not what the pay type is called in the system.

A six-month deadline

The pension scheme has to be set up within six months of the conditions being met. Six months is not a pension-free period. Employees have to be given the accrual they are entitled to from the right date – the deadline is about when the scheme has to be in place, not when accrual starts.

Owner-employees are covered once the duty arises

Where an external employee in an 80% position makes the company liable, the scheme does not apply only to that external employee. Owner-employees are covered too where the membership conditions are met. Hiring the first employee therefore triggers a pension cost for the owner as well – a cost often forgotten in the budget for that first hire. The whole set-up around it is in Your first employee.

Foreign workers

The statutory duty is tied to compulsory membership of the Norwegian National Insurance scheme. A1 documentation or a social security agreement can show that a foreign worker still belongs to another country's system. Foreign employers can in some cases have a foreign pension scheme approved as meeting the Norwegian requirements. See also A foreign company setting up in Norway

Employer's contributions come on top

Employer's national insurance contributions are also calculated on the pension contribution and on relevant administration and management costs. A pension contribution of NOK 20,000 in zone I alone gives NOK 2,820 in employer's contributions at 14.1%. The real cost of the scheme is therefore higher than the contribution.

The pension provider in the a-melding

Employers with a scheme have to state the pension provider's organisation number in the a-melding. Correct reporting of start dates, end dates, percentage of full-time and leave therefore matters for the pension too – not only for pay and tax. See Missed an a-melding

If the business falls below the thresholds

The scheme does not necessarily end the day an employee leaves. For defined contribution schemes there are rules that look at whether the business is still below the thresholds at the end of the year and the following year, before the scheme is wound up or continued voluntarily.

Not having a scheme can be expensive

Skatteetaten supervises the duty. In 2026 the enforcement fine is NOK 250 per employee per day, and it runs until the business can document that a scheme is in place. For a business with five employees that is NOK 1,250 a day. The fine comes on top of the duty to give employees the accrual they should have had. Greenleaf can check when the headcount triggers the duty, which employees have to be included, the pension basis and employer's contributions, and make sure the a-melding is correct.

This is general guidance, not advice on your specific case. Deadlines, rates and amounts change – always check the current rules, or get in touch with us.

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