Norwegian Cartel Enforcement 2026

Norwegian Cartel Enforcement 2026

An overview of Norwegian Cartel Enforcement

February 2026

Dear reader The most significant development in 2025 was the Competition Appeals Tribunal's decision to uphold the record-breaking EUR 420 million fine imposed on the three largest grocery chains in the 'Price Hunter case'.

Norway's first 'by effect' infringement concerns an agreement to provide mutual access for price collection, increasing market transparency. The novel theory of harm focuses on unilateral changes in incentives. The case has been appealed to the Court of Appeal.

The year 2025 also saw the conclusion of incumbent postal operator Posten's follow-on damages claim against the truck cartel participants, with Posten being awarded EUR 10 million in damages plus interest. The Court of Appeal undertook a detailed assessment of causation and quantification of damages, highlighting that there is no presumption of damage under Norwegian tort law.

The NCA's 2025 enforcement activity was limited, with no new decisions and one investigation closed following a Statement of Objections. It became public that the NCA reported individuals to the police in this case, demonstrating its use of all enforcement tools. Two new investigations will continue into 2026.

As of 1 January 2026, the new Director General, Mads Magnussen, took office following the previous Director General's mid-term resignation in January 2025. The new Director General has been granted a significant new tool: From 1 July 2025, the NCA can initiate market investigations and impose remedies. This tool has not yet been utilised.

The Competition Act Review Committee delivered proposed amendments on 1 December 2025, including oral hearings, fine reductions up to 20% in settlements, immunity from criminal sanctions for individuals, protection from damages claims in leniency cases, and a new chapter on private enforcement. Notably, the proposed new chapter includes a presumption of damage in follow-on cartel cases, harmonising with the EU Damages Directive (which has not been incorporated into the EEA Agreement). The consultation deadline is 27 March 2026.

This annual report provides an overview of recent developments in the Norwegian cartel enforcement system, offering guidance to practitioners, businesses and other stakeholders. We hope you find this interesting!

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1. Summary of 2025 2. The Norwegian Cartel Enforcement System 3. BAHR - EU & Competition Law

Price hunter: The CAT upholds the NCA's recordbreaking fines of EUR 420 million 'By effect' infringement concerning an agreement on mutual access for price collection, resulting in increased market transparency

11 April 2018: The NCA conducted unannounced inspections at the premises of the Norwegian grocery chains NorgesGruppen, Coop and REMA 1000.

21 August 2024: The NCA fined the chains MEUR 420 for cooperating to provide access to each other’s stores for extensive price surveillance. The agreement was considered anticompetitive ‘by effect’.

15 December 2020: The NCA issued an SO notifying the parties of fines of approximately EUR 1.8 bn. The cooperation to provide access to stores for extensive price surveillance was considered anticompetitive by ‘object’ and ‘effect’.

21 August 2025: The CAT upheld the NCA decision of an ‘by effect’ infringement and a fine of MEUR 420 for engaging in unlawful cooperation from 2011 to 2018.

10 April 2024: The NCA issued a new SO with revised fines based on the case now only being considered as an infringement ‘by effect’.

21 November 2025: The grocery chains appealed to the Court of Appeal.

To be continued

The case at a glance and key takeaways The NCA and CAT decisions represents landmark rulings in Norwegian competition law, marking the first-ever ‘by effect’ infringement decisions in Norway and resulting in the highest fines ever imposed.

The case concerns an agreement between the three largest grocery chains in Norway to provide access to each chain's stores for extensive price surveillance, which resulted in increased transparency on current prices between the chains.

In 2010, the grocery chains entered into an industry norm for comparative advertisement that included a provision stating: ‘In order for price comparisons to be practically feasible, it must not be difficult for competitors to collect prices in stores.’

This agreement was not considered to be contrary to the prohibition against anticompetitive agreements.

The unlawful agreements were subsequently entered into during meetings in 2011 and 2012, where the chains, according to the CAT, agreed to collect prices beyond the sole purpose of comparative advertisement and to allow the use of handheld scanners. Notably, the chains’ practice of price surveillance has been known to both the NCA and the public.

The CAT considered the real content of the agreements to be that of private exchange of strategic, competitively sensitive information. According to the CAT decision, the agreements gave the grocery chains increased certainty about competitors' responses compared to the counterfactual scenario.

The theory of harm concerns unilateral change in incentives, whereby price cuts became less tempting because each chain as a result of the agreement expected its competitors to match their price reductions. Conversely, price increases became more tempting because each chain expected its competitors to quickly follow suit.

According to the CAT, this created pressure towards higher price levels.

The CAT decision notes that this theory of harm ‘is based on economic principles and results that are each well established within economic theory.’ The CAT decision clearly delineates against coordinated effects.

The CAT dismissed the parties' procedural arguments, including the requirement for a supplementary statement of objections due to an alleged shift in theory of harm.

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Regarding sanctions, the CAT agreed with the NCA's calculation of fines. The NCA set the gravity of the infringement at 5%, but the overall fines were reduced by 90% due to the fines reaching the maximum level of 10% of annual turnover and proportionality considerations given the shift from 'by object' to 'by effect’.

The case has been appealed by all three grocery chains to the Court of Appeal, although a hearing date has not yet been set. The CAT decision is published on the CAT website (in Norwegian only).

Conclusion in favour of Posten in landmark follow-on damage case following the truck cartel 2016: The Truck manufacturers cartel settlement agreements with the EU Commission (except Scania).

2017: Posten filed a damage claim to the Oslo District Court.

2017: The damage claim was put on hold due to several procedural questions pending in the courts.

28 February 2023: Oslo District Court dismissed Posten’s damage claim.

17 March 2025: The Court of Appeal ruled in favour of Posten granting Posten damages of MEUR 10 plus interests.

September 2025: The Supreme Court dismissed the truck manufacturers appeal, bringing the case to a legally binding conclusion.

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Posten’s damage claim against the truck manufacturers following the EU Commission settlement decision in 2016 has been concluded with Posten being awarded EUR 10 million in damages and interest. The EU Damages Directive (2014/104/EU) has not been incorporated into the EEA Agreement, meaning Norwegian tort law applies.

The Court undertook a detailed assessment and concluded, based on inter alia the statement of objections and the Commission decision against Scania, that the cooperation was broader than acknowledged in the settlement decision, involving also coordination of future pricing behaviour aimed at achieving higher net prices.

Despite Volvo Norge AS being unaware of the cartel, it could still be held liable under EEA and Norwegian law due to the 'specific link' between Volvo Norge AS and AB Volvo's infringement, as held in case C-882/19 Sumal.

The Court highlighted that there is no presumption of damage under Norwegian tort law. Despite noting that regression analyses are uncertain, the Court ultimately relied on Posten's experts acknowledging a causal link between the illegal conduct and the alleged overcharge. The Court set the overcharge at 10% for Norway, but 5% for Sweden and Slovakia due to a weaker evidentiary basis in these markets.

The Court relied on various forms of evidence, including the Commission's findings, economic meta-studies and empirical studies presented by Posten. However, whilst meta-studies suggest these cartels affect end-prices, the extensive resources devoted to empirical regression analysis (16 expert reports at first instance, 11 on appeal) did not justify their limited evidential value.

The Court rejected the manufacturers' claim that Posten had passed on the overcharge, noting that establishing an actual causal link would be difficult where the end-price is affected by several factors. For further details, please see our newsletter.

With the Supreme Court's dismissal of the truck manufacturers' appeal, the Court of Appeal's ruling is final and legally binding. The case confirms established principles regarding the assessment of causation and quantification of damages relevant to future follow-on damage claims. Norwegian dairy producer Tine settled a separate claim related to the same cartel after the Court of Appeal's decision. Additionally, Telia has launched a follow-on damage claim against Telenor following EFTA Surveillance Authority and NCA decisions for abuse of dominance, with the damages case awaiting clarification on limitation period.

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Legislative updates The Competition Act Review Committee delivered its proposed amendments on 1 December 2025 The Competition Act Review Committee delivered its proposed amendments on 1 December 2025. The majority proposes several changes relevant to cartel enforcement.

The majority proposes a new time limit of 12-18 months for the issuance of an opening decision thereby establishing more predictability for companies under investigation. The proposal also introduces certain procedural rights, notably the right to an oral hearing in NCA proceedings where the NCA has issued a statement of objections. Settlement incentives are further strengthened as the proposal includes enhanced fine reductions of up to 20% for cartel cases. The proposal provides for leniency protections including immunity from criminal sanctions for individuals where a leniency application has been submitted, and protection from damages claims where leniency is granted. Notably, the proposal also includes an extension of the leniency system to also cover abuse of dominance cases. Finally, the proposal introduces changes to CAT procedural rules and a change of appeal court.

The proposal also includes a new chapter on private enforcement, harmonising some of the rules with the EU Damages Directive (which has not been incorporated into the EEA Agreement). This includes presumption of damage in cartel infringements, establishing final decisions by the NCA, EFTA Surveillance Authority, EU Commission and appeal courts as uncontested grounds in damages claims relating to the same violation, and rules on passing-on of overcharge. In addition, the proposal includes rules on access to third-party financing in class actions.

The proposal has been circulated for public consultation with a deadline of 27 March 2026. Included are also many minority proposals, and the outcome of the hearing will be of utmost importance as to what amendments are made. The proposal will likely not be considered by the Parliament until 2027.

The market investigation tool entered into force 1 July 2025 The market investigation tool, which entered into force on 1 July 2025, enables the NCA to intervene against conduct or market conditions that significantly restrict competition. The NCA may impose both structural and behavioural remedies, including divestiture of business units. To date, the NCA has not initiated any investigations under this tool.

For a more detailed description of the market investigation tool, please see our indebth newsletter.

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Investigation update: No new NCA decisions, one investigation closed and two new investigations Investigation in the market for moving services closed following SO notifying fines of EUR 429 000 and reporting of individuals The dawn raid took place in February 2021, and the allegation concerned illegal cooperation. In April 2024, the NCA issued an SO notifying fines of EUR 429 000. One year later, in June 2025, the NCA closed its investigation following 'an overall assessment'. Subsequently, it has become public that two individuals from one of the companies involved were reported to the police in this case. Although this did not result in any proceedings, it shows that the NCA is willing to report individuals for criminal sanctions to the public prosecutor's office.

One investigation ongoing in the market for driving schools In November 2024, the NCA carried out a dawn raid at the premises of several driving schools. The alleged infringement is illegal cooperation. The case is still ongoing, and it is not public which driving schools are involved.

Two new investigations in the markets for veterinary clinics and digital platforms Market for veterinary clinics In February 2025, the NCA carried out dawn raid at the premises of several veterinary clinics. The alleged infringement is illegal cooperation.

Digital platform market In January 2026, the NCA announced that it had carried out a dawn raid at the premises of companies in a digital platform market. The suspected infringement is illegal cooperation.

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1. Summary of 2025 2. The Norwegian Cartel Enforcement System 3. BAHR - EU & Competition Law

Two sets of rules: The Norwegian Competition Act and the competition rules in the EEA Agreement

01 02

Anticompetitive agreements Abuse of dominant position

The Norwegian Competition Act

The EEA Agreement

Competition Act Section 10

EEA Agreement Article 53

Competition Act Section 11

EEA Agreement Article 54

Two sets of rules Two competition law regimes applicable • The Norwegian Competition Act of 2004 • The Agreement on the European Economic Area (EEA Agreement) of 1994 Both sets of rules are fully harmonised with the corresponding provisions in the Treaty on the Functioning of the European Union (TFEU) Articles 101 and 102.

Agriculture and fishery products are outside the scope of the EEA Agreement.

The rules have partly overlapping geographical scope: • The Norwegian Competition Act applies when effect in Norway • EEA Agreement Articles 53 and 54 apply when effect on trade between EEA Member States 16

Different enforcers, depending on rules applicable

01 02

The Norwegian Competition Act

The EEA Agreement

Anticompetitive agreements Abuse of dominant position

Enforcement by the NCA, the ESA and the EU Commission The Norwegian Competition Act The Norwegian Competition Authority (NCA) has sole enforcement jurisdiction.

The EEA Agreement The Norwegian Competition Authority is empowered by the EEA Competition Act section 6. The EEA Competition Act is a unilateral Norwegian implementation.

If EFTA Surveillance Authority (ESA) or the European Commission (EC) initiates proceedings under the EEA Agreement Article 53, the NCA is relieved of its competence to apply Article 53.

Attribution of cases between the ESA and the EC regulated by EEA Agreement Article 56.

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The NCA has wide powers of investigation The NCA’s Dawn Raid powers are similar – but not identical – to the European Commission’s

Unannounced inspections (dawn raids) Unannounced inspections may be carried out at all locations and premises of the undertaking, as well as at private homes if there are particular grounds to assume that evidence is kept there.

Inspections require a decision by the District Court.

As a general rule, the NCA should take copies of documents. However, originals may be seized if the originals are deemed to have particular value as evidence. The EFTA Surveillance Authority/European Commission on the other hand cannot seize original documents.

The NCA will regularly take copies of electronic material, including servers, electronic devices and similar items.

The parties, or their representatives, have the right to be present when the NCA starts examination of electronic material in order to clarify whether the information is protected by legal privilege.

Power to take statements The NCA has the power to take statements from any natural or legal persons. The NCA may also make audio recordings of the statements.

Correspondence with in-house lawyers is considered legally privileged under Norwegian law, unlike for the EFTA Surveillance Authority/European Commission. Inhouse lawyers are considered legally privileged also where the NCA enforces the EEA Agreement. This was confirmed by the Court of Appeal in the KLP case of 26 June 2025.

Requests for information Information can be requested from any individual or undertaking. Non-compliance or providing wrongful or misleading information can be sanctioned.

The parties have the right to receive copies of seized documents and electronic data, provided there is no risk of harm to the investigation.

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The EFTA Surveillance Authority’s powers to conduct Dawn Raids in Norway ESA’s own investigations in Norway

ESA’s Dawn Raids on behalf of the EC

The EFTA Surveillance Authority (ESA) has the power to conduct dawn raids in its own investigations pursuant to EEA Competition Act section 3. ESA's dawn raid powers are identical to the EC's dawn raid powers. There is no need for approval from a national court if the dawn raid is carried out by ESA. ESA's decision to carry out a dawn raid can be reviewed by the EFTA Court.

The European Commission (EC) can request ESA to conduct inspections in EFTA States in cases where the EC has jurisdiction pursuant to EEA Agreement Protocol 23 article 8(2) (adopted as regulation in Norway).

ESA shall consult the NCA before conducting a Dawn Raid and the NCA officials may actively assist ESA, upon request from the NCA or ESA.

All information obtained will be transmitted from ESA to the EC.

The dawn raid is carried out in accordance with the rules that apply for ESA's dawn raids, and the EC is entitled to take an active part in the Dawn Raid.

ESA also has the power to request the EC to conduct Dawn Raids in cases where ESA has jurisdiction.

If reasonable suspicion exists, ESA also has the power to inspect other premises than the undertaking’s premises.

The NCA can conduct Dawn Raids on behalf of ESA (or another EEA EFTA State).

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The NCA’s toolbox: Several possible outcomes of investigation cases

Cease and desist order

Commitment Decisions

The NCA may order undertakings to bring illegal agreements to an end.

An undertaking under investigation can offer commitments. No admission of guilt is required.

The order may include any measure necessary, including structural measures.

So far one commitment decision in one § 10 case concerning alleged concerted practice (price signalling).

Administrative fines

Criminal sanction for individuals

Administrative fines can be issued for up to 10% of the undertaking’s total annual turnover. The NCA follows the same calculation method for setting fines as the European Commission. The fines will be indicated in the SO.

Criminal sanctions are normally initiated by the NCA through the reporting of individuals for prosecution.

Cartel Settlement

Leniency

Settlements may lead to a reduction of maximum 10% of the fine. The SO is issued first.

Settlement requires admission of guilt (opening for follow-on claims).

Leniency may lead to full immunity from administrative fines. Similar system as in the EU.

The NCA has reported two individuals to the public prosecutor's office.

Applications to NCA, ESA and EC may be needed if EEA Agreement Article 53 is applicable.

Cartel settlements have not yet been applied by the NCA.

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The NCA’s fines have increased over the last decade Four highest cartel fines per case:

01

Price Hunter (2024)

02

Alarm (2019/2020)

03

Book Publishers II (2022)

Acess to stores – restriction by effect* NorgesGruppen: MEUR 198 REMA 1000: MEUR 110 Coop: MEUR 112

MEUR 420

Market sharing – restriction by object Sector Alarm: NCA’s fine accepted Verisure: CAT upheld NCA’s decision. Not appealed.

MEUR 106

Information exchange through third party – restriction by object CAT overturned NCA’s decision in 2023 and the fine was annulled

MEUR 47

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Bid rigging – restriction by object NCA: Veidekke MEUR 18.9, NCC MEUR 12 Asphalt (2013) Appeals Court: NCC MEUR 12.9 Veidekke granted full immunity

Figures based on Norges Bank (Central bank of Norway) average exchange rate 2025 NOK/EUR 11.7177 *Appealed to the Court of Appeal

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MEUR 31

The NCA applies the EC’s guidelines on method of setting fines

01

BASIC AMOUNT VALUE OF SALES related to the infringement

02

GRAVITY (0-30%)

x

DURATION (years)

+

Addition for DETERRENCE (15-25%)

=

BASIC AMOUNT

ADJUSTMENTS

AGGRAVATING /MITIGATING circumstances

03

x

SPECIFIC DETERRENCE individual adjustment

LEGAL MAXIMUM 10% of total turnover

DECISION

FINAL FINE

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LENIENCY up to 100%

CARTEL SETTLEMENT 10% reduction of final fine

INABILITY TO PAY

Cartel fines imposed by the NCA, 2016-2025:* The NCA has consistently held the gravity of 'by object' infringements to be 15-19% regardless of the form of conduct. The Price Hunter case is the exception, as it concerns an infringement 'by effect’.

NORVA, LINDUM (2016)

BOOK PUBLISHERS I (2017)

EL-PROFFEN et al.

(2017)

INFRINGEMENT

Bid Rigging

Collective Boycott

Bid Rigging

VALUE OF SALES (MEUR)

2.5

8.8

10.1

x GRAVITY

17%

19%

15%

x DURATION

[1]*

0.5

[1]**

+ DETERRENCE

17%

19%

15%

= BASIC AMOUNT (MEUR)

0.6

2.9

2.5

± AGGR./ MITIGATING etc.

+ High turnover

MAXIMUM LIMIT (10%)

N/A

N/A

Met for 3 parties

FINAL FINES (MEUR)

0.6

2.7

1.6

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HOME SECURITY (2019/21)

BOOK PUBLISHERS II (2022)

PRICE HUNTER (2024)

INFRINGEMENT

Market Sharing

Information Exchange

Information Exchange

VALUE OF SALES (MEUR)

111.4

133.2

12 470

x GRAVITY

16%

16%

5%

x DURATION

6 / 5.8

8/5

7.2

+ DETERRENCE

16%

16%

-

= BASIC AMOUNT (MEUR)

140.9

182.1

4 239

± AGGR./ MITIGATING etc.

- 90 %***

MAXIMUM LIMIT (10%)

Met for Sector Alarm

Met for all parties

N/A

FINAL FINES (MEUR)

106

46.9

420

Figures based on Norges Bank (Central bank of Norway) average exchange rate 2025 NOK/EUR 11.7177 *The fines listed are the fines from the NCA decision and not necessarily the final result in the appeals process **In individual bid rigging cases – the value of the tender has been used as basis ***One chain was granted a reduction of 3 % due to cooperation in the investigation concerning malfunctions in the data seizure

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Cartel settlements and commitment decisions Cartel settlements

Commitments

The cartel settlement system provides for a reduction of fine with a maximum 10% reduction. This will normally require an SO. The system is modelled after the EU/EEA system.

The NCA may accept commitments offered by undertakings under investigation. The NCA will adopt a decision making the commitments binding upon the undertaking. The decision can be reached before the NCA has made a full assessment of whether the requirements for the finding of an infringement are fulfilled.

There have been no cartel settlements since the introduction of the system in 2016. In order to enter into a cartel settlement procedure, the NCA must find the case suitable and will invite the undertaking to settlement discussions. The NCA must present (i) the case and the evidence in its possession, (ii) its preliminary assessment and (iii) the estimated amount of the administrative fine to be issued.

Commitments require no admittance of the infringement.

Settlement requires the undertaking to admit the infringement. If the undertaking refrains from settlement, the investigation will continue as if settlement proceedings were not initiated. Documents relating to the settlement negotiations cannot be used as evidence.

The new legislative proposal, includes enhanced fine reductions of up to 20 % in cartel cases.

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There has been one commitment decision under the prohibition against anticompetitive agreements/concerted practices so far: Circle K and YX Norge AS (2020) concerning price signalling through publication of list prices for retail fuel on the internet.

Criminal sanctions for individuals: Imprisonment for up to 6 years

Individuals may be charged with criminal sanctions following an infringement of the Norwegian Competition Act Section 10 concerning anticompetitive agreements.

Criminal sanctions also apply for procedural infringements, such as failing to comply with information requests or inspections at premises or in homes.

Imprisonment for up to six years may be imposed for anticompetitive agreements with severely aggravating circumstances.

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Between 2004 and 2025, the NCA has reported at least two individuals to the public prosecutor's office. These did, however, not result in criminal charges related to an infringement of the Norwegian Competition Act Section 10.

Norway has a long history of criminal sanctions in competition law matters, although these have not resulted in any sanctions for several decades.

Criminal sanctions, including imprisonment and fines for individuals, have been available in Norway since 1960. Between 1986 and 2004, 41 cases were reported to the public prosecutor. Fines were issued in 24 of these cases, but no imprisonment was imposed.

Leniency Norwegian Competition Act: Undertakings The leniency system in Norway follows a similar (but not identical) procedure as in the EU. The NCA administers and enforces the leniency system in Norway. Full leniency is granted to the first applicant that submits sufficient evidence of a possible infringement and cooperates with the NCA in the investigation.

The undertaking may apply for a leniency marker to ensure a 'place in line' whilst gathering evidence. The SO reveals the identity of the leniency applicant.

Norwegian Competition Act: Individuals There is personal criminal liability for individuals under the Norwegian Competition Act. Individuals are not formally protected by the undertaking's immunity. From July 2022, reports from the NCA to the public prosecutor's office are no longer a condition for criminal charges which means that the public prosecutor may initiate prosecutions independently.

However, it remains probable that most prosecutions for violations of the Competition Act will be initiated after a report from the NCA. The NCA will normally not report individuals who disclose unlawful cooperations and fully cooperate with the NCA during their case handling.

EEA Competition rules: No one-stop shop When EEA Agreement Article 53 applies, leniency applications to the NCA, ESA and EC may be required. This is especially relevant if jurisdiction between the enforcers is not yet clarified.

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Follow-on damage claims: Several procedural questions decided by the courts

Norwegian tort law The EU damages directive (2014/104/ EU) is not incorporated into the EEA Agreement.

National tort law applies: 1.

2.

3.

4.

Economic loss required – damages normally limited to direct loss; no presumption of harm Basis of liability – intention or negligence Causal link between the economic loss and the basis for liability Cartel members jointly and severally liability for damages

Specific regulation of limitation period in the Norwegian Competition Act The limitation period is 1 year after final decision or judgement.

This supplements the Limitation Act. The new legislative proposal includes several amendments that are relevant to private enforcement.

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Procedural questions: Foreign defendants can be held liable in Norwegian Courts Foreign defendants can be held liable in Norwegian courts. This was confirmed by the Norwegian Supreme Court in Posten v. Truck Manufacturers, where only Volvo Norge AS had domicile in Norway whilst the other defendants were domiciled in other countries.

However, since all countries were parties to the Lugano Convention, the foreign defendants argued that the Lugano Convention Article 6 No. 1 was not fulfilled.

The Norwegian Supreme Court decided that the cases were sufficiently ‘closely connected’ and allowed the case to be decided by the Norwegian courts.

Plaintiffs have the right to get access to the Statement of Objections The Court of Appeal decided in 2020 in Posten v Truck Cartel that the defendants are obliged to disclose the European Commission's statement of objections.

Opt-out class action damage claims (a claim representing all end-users unless they actively withdraw) cannot be financed by third parties in exchange for a share of the total compensation awarded The Norwegian Supreme Court dismissed an alarm customer organisation's follow-on claim against the two alarm companies, Sector Alarm and Verisure. The claim followed cartel decisions from the NCA and CAT. The Supreme Court's decision puts restrictions on the financial structuring of opt-out damage claims.

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Review of the NCA’s decisions

The Norwegian Competition Authority

The Competition Appeals Tribunal (CAT)

Full review of all aspects of the case

32

Gulating Court of Appeal

Supreme Court of Norway

Scope of review determined by the Appeals Committee of the Supreme Court

Full review of all aspects of the case

Referrals to the EFTA Court Can be made by the CAT, Court of Appeal and Supreme Court

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1. Summary of 2025 2. The Norwegian Cartel Enforcement System 3. BAHR - EU & Competition Law

BAHR – your trusted antitrust advisor throughout the entire process

Compliance We ensure compliance in accordance with your business needs We ensure that conduct and agreements are compliant with the competition rules, including compliant information sharing. We provide compliance sessions, including mock dawn raids, and dawn raid / compliance manuals – off the rack or tailor made for your business.

Review In close cooperation with our litigation department, BAHR Competition Litigation Team helps you with review processes We handle review cases before the CAT and Norwegian courts, full-service with antitrust, litigation and in-house economic resources. We are experienced working closely with external economic expertise.

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Investigation We are experienced in handling all aspects of on-going investigations This includes dawn raids and leniency applications before the NCA, ESA and the EC. We handle dialogue and submissions with enforcers, as well as handling extensive requests for information. We also provide assistance with cartel settlements and commitments decisions.

Follow-on litigation In close cooperation with our litigation department, BAHR Competition Litigation Team helps you with your damage claims We handle follow-on damage claims before Norwegian courts, providing full-service with antitrust, litigation and in-house economic resources. We are experienced working closely with external economic expertise.

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“The team has extremely knowledgeable, strategic and effective advisers.

They are exemplary lawyers with deep experience in Norway and globally.”

Chambers 2025 “Extremely experienced team that quickly pinpoints the central legal issues involved and makes this understandable to the client, so practical business implications immediately are brought to the surface.”

Legal 500 2025

BAHR: Consistent Top Ratings

•

Top ranked in 16 categories by Chambers Europe • 2025

Firm of the Year: Norway, IFLR European Awards 2023, 2024 and 2025

•

Ranked in all categories by Chambers Global 2025 •

•

Top ranked as Tier 1 in fourteen categories in the 2025 edition of Legal 500 •

Net-Zero Transition Award, IFLR European Awards 2024 and 2025

•

Top ranked as Tier 1 in all categories by IFLR 1000 2024 •

•

Top ranked as Tier 1 in all categories by World Tax 2025 •

•

Top ranked as “Elite firm” in the category Competition Law by GCR100 2025

•

Ranked in three categories by IP Stars 2024

•

Top ranked as “Gold firm” in the category Litigation and transactions by IAM Patent 1000 2024

•

Norway Tax Firm of the Year, ITR Awards 2024

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Team of the Year for M&A: Regional, IFLR European Awards, 2025 Deal of the Year for Private Equity, IFLR European Awards, 2025 Norway Patent Disputes Firm of the Year, Managing IP Awards EMEA 2024

•

Europe Patent & Regulatory Team of the Year, Managing IP Awards EMEA 2024

•

European Cross-Border Patent Litigation Team of the Year, Managing IP Awards EMEA 2024

•

Norway M&A Legal Adviser of the Year, Mergermarket European M&A Awards, 2023

BAHR’s EU & Competition team: Consistent top Tier rankings

2025

Band 1

Tier 1

Elite

2024

Band 1

Tier 1

Elite

2023

Band 1

Tier 1

Elite

2022

Band 1

Tier 1

Elite

2021

Band 1

Tier 1

Elite

2020

Band 1

Tier 1

Elite

Helge Stemshaug is ranked Band 1 and Beret Sundet Band 2 in Competition / Antitrust by Chambers Europe 2025 Helge Stemshaug and Beret Sundet named as Thought Leader 2025

by Lexology Index: Competition Beret Sundet ranked in “Hall of Fame”, Helge Stemshaug ranked as “Leading Partner” and Ylva Kolsrud Lønvik as “Leading Associate” in EU and Competition by Legal 500 2025

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Contact details

Helge Stemshaug

Beret Sundet

Arne Torsten Andersen

PARTNER +47 928 81 396 hst@bahr.no

PARTNER +47 928 81 385 bsu@bahr.no

PARTNER +47 971 47 338 ata@bahr.no

Elin Moen

Olav Kolstad

PARTNER +47 415 26 541 emo@bahr.no

PARTNER | DR. JURIS +47 478 71 010 olk@bahr.no

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Disclaimer This publication is provided for general information purposes only and does not constitute legal advice. You should not rely upon it as a substitute for specific legal advice tailored to your particular circumstances. If you require legal advice on any matter addressed in this publication, please contact a BAHR partner.

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