Foreign companies operating in Norway are required to ensure that their employees at Norwegian building and construction sites hold specific ID cards (“HMS-kort” / “byggekort”). Failure to comply with this requirement may lead to fines for the company in question.
The ID cards must be ordered from a card issuer designated by the Ministry of Labour and Social Inclusion. The ID cards will only be issued if certain requirements are met. Unfortunately, there are several challenges foreign companies doing business in Norway may encounter in the process of ordering ID cards.
Requirements and challenges
The purpose of this post is it to make a general guideline for foreign companies needing ID cards for their employees. We will outline the requirements which must be met in order to obtain the ID cards, but we will focus on some practical challenges often encountered when ordering ID cards.
1. Registration of the foreign company in Norway
The ID card regulations require that the foreign company must be registered at the Central Coordinating Register for Legal Entities (“Enhetsregisteret”)
Once the foreign company is registered it will obtain a Norwegian organisation number for identification purposes.
Additionally, VAT liable companies must register at the VAT register. Staffing enterprises must register at the Register of staffing enterprises.
2. Registration at the Central Office for Foreign Tax Affairs (COFTA)
The next step in the process of ordering the ID cards is to complete an important form called RF-1199. The form is available at:
Form RF-1199 consists of 2 parts. Part 1 of the form is for reporting basic information about the foreign company’s contract in Norway. Part 2 of the form is for reporting the foreign employees, who will carry out work in Norway. The employees’ first day of work and last day of work are particularly important for the process of ordering ID cards. This is because ID cards will be issued only for employees, who are registered with an active employment in Norway.
Form RF-1199 must be filed to the Central Office for Foreign Tax Affairs (COFTA). Some foreign companies operating in Norway apply for simplified reporting as an alternative to filing RF-1199. Even companies with simplified reporting need to file RF-1199 before ordering ID cards. Thus, it should be noted that applying for simplified reporting may be superfluous or counterproductive if ID cards will be ordered at a later time.
Once RF-1199 has been processed by COFTA, the employees need to have their identities verified at a tax office carrying out identity verifications. Further information regarding ID verification offices is available at:
The employees will be provided with a D number (a Norwegian identification number) after their ID verification. The D number is essential for the ID card application process.
Foreign workers, who have previously worked in Norway, may already have a Norwegian D number. If the D number was assigned prior to the introduction of the identity verification requirement (before 01.04.2014), then the employee must complete an identity verification before an ID card can be successfully ordered.
3. Registration of an “Orderer” of ID cards
At this point, the foreign company has obtained a Norwegian organisation number, and contract information and employee information has been filed to COFTA on form RF-1199. Furthermore, all employees have carried out identity verification.
What is an Orderer?
Before ordering ID cards, an “Orderer” must be registered at the card issuer’s website. The “Orderer” is the person who orders the ID cards, and who has the responsibility to ensure that the information submitted to the card issuer is correct. The Orderer must be selected from one of the employees reported on part 2 of form RF-1199. This employee must have completed the ID verification and received a D number before registering as an Orderer.
When can an Orderer be registered?
At the time of registration of the Orderer, 48 hours must have passed after the employment was registered at COFTA, and the identity was verified. Attempting to register the Orderer before 48 hours have passed will reset the clock, and another 48 hour period will start to count from the last unsuccessful attempt to register.
How should the Orderer be reported?
Foreign companies often enter into contracts with Norwegian clients, requiring the presence in Norway of hundreds of foreign workers. Some foreign workers may travel to Norway on a rotation scheme. In such cases, issues may arise if the Orderer is not reported in Norway for at least the same working period as the other employees working here.
If for instance the Orderer is reported to COFTA with 10.12.2016 as his first day of work and 10.02.2017 as his last day of work, he will not be able to order ID cards for a worker who comes to Norway on 11.02.2017. The Orderer should be reported with a continuing working assignment in Norway so that he may provide his colleagues with ID cards. Consequently, it may be preferable that the Orderer is the person with the longest working assignment reported on Part 2 of form RF-1199. Some foreign companies choose to report the Orderer with a working assignment comprising the whole duration of the contract in Norway, making him able to order ID cards to all employees.
The actual presence in Norway of the Orderer, which is important for his taxable status, will be reported on a monthly basis through the so-called A-report scheme. The purpose of the A-report scheme is to report income and employment to the Norwegian Tax Administration, The Norwegian Labour and Welfare Administration (NAV) and Statistics Norway (SSB).
More information about Individual income tax in Norway
4. Ordering ID cards
Once the Orderer has been successfully registered, the ID cards can be ordered. Each cardholder must meet the same requirements as the Orderer. This means that they must have been reported on part 2 of form RF-1199, have completed an ID verification, and have received their D numbers. Furthermore, the same 48-hour time period applies to the cardholder as it does to the Orderer.
When ordering ID cards a copy of each cardholder’s signature, photo, and valid ID (passport, national ID card or similar) must be uploaded before submitting the application. The copies do not need to be certified but they must be of good quality and comply with the card issuer’s standards. In addition, copies of the signatures, photos and ID’s must be cropped and fitted.
It should be noted that if the ID cards are paid by invoice, the card issuer will only ship the ID cards to the company address that is registered in the Central Coordinating Register for Legal Entities. If they are paid by credit card, then there is an option to choose another address.
In conclusion there are several requirements and practical challenges that a foreign company may encounter when ordering ID cards. Furthermore, it is a fact that every step explained above takes some time.
Obtaining an organisation number takes a week or two, and COFTA will use some time to process form RF-1199. The ID verification should be quick enough, but it is our experience that it takes at least a couple of weeks for workers to get their D numbers. After the ID cards have been ordered, it will take another couple of weeks before they are issued and received per post. In the meantime, the employees should keep documentation at the building site, confirming that the ID card process has been started. In some cases, the foreign company could in fact have finalized their assignment in Norway before the ID cards are obtained.
It is of great importance that the ID card process is planned early, ideally as soon as the Norwegian contract is obtained. Nevertheless, the process is relatively bureaucratic, and foreign businesses operating in Norway, may save time and frustrations by engaging an advisor to deal with the process.
The law firm Visma Advokater has offices in Oslo, Kristiansand, Stavanger, Bergen and Trondheim. We are more than 35 professionals with extensive experience in corporate law – including TAX and VAT, real estate, labour law, public procurement, company law and contract law. Our lawyers are happy to assist you with any of the above subjects. Please do not hesitate to contact us should you have any questions.
Associate lawyer: Christian Lyngholm Fjeldsøe, phone +47 486 03 772, email.
Lawyer: Øivind Henrik von Mehren, phone +47 481 93 167, email.
Visit one of the following pages for more information about doing business in Norway: