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Til horingen: Høring – Endringer i folketrygdloven – lovvalg og medlemskap i folketrygden for ...

Chane Corp, Communications Officer, Royal Norwegian Embassy in Washington DC

Departement: Familiedepartementet
Dato: 12.11.2025 Svartype: Med merknad Although the proposed amendment may not immediately affect locally employed staff in the U.S. who are mandatory members of the Norwegian National Insurance Scheme, our group has already experienced significant unpredictability and changes regarding social security, health insurance, and other benefits that are considered part of the compensation package in the U.S. Colleagues who are not members of the Norwegian National Insurance Scheme have gone from 100% health insurance coverage to paying 20% for themselves and their families—amounting to several thousand kroner per month. Reimbursement for home office internet expenses has been discontinued. Members of the Norwegian National Insurance Scheme can no longer obtain dental insurance through the employer. Vision insurance through the employer has been removed for all locally employed staff. To date, non-EEA locally employed staff have been hardest hit by these changes. This proposal now raises serious concerns among those of us who are members of the Norwegian National Insurance Scheme, reinforcing a sense of unpredictability in our employment relationship and signaling that the employer places limited value on locally employed staff as a group. If locally employed staff who are currently mandatory members of the Norwegian National Insurance Scheme lose this status, the MFA and foreign missions will become significantly less attractive employers for this group. Embassies benefit greatly from locally employed staff who speak Norwegian and understand Norwegian systems. Some positions even require Norwegian citizenship and eligibility for security clearance. Removing the ability to maintain mandatory membership in the Norwegian National Insurance Scheme will weaken the MFA’s attractiveness as an employer for EEA citizens abroad and risk losing qualified and experienced personnel. Locally employed staff, both EEA citizens and others, provide continuity, share knowledge and experience, and play an essential and critical role in enabling foreign missions to represent Norway and its interests effectively worldwide. Repeated changes to legislation or its interpretation, reductions in health insurance and benefits, and ongoing unpredictability in employment conditions undermine trust and damage the employer’s reputation. This process and any resulting legislative change will likely have a highly negative impact on recruitment. The Ministry of Labour and Social Inclusion (AID) has specifically requested comments on the need for transitional rules. Transitional measures are essential if any change to the current legislation is adopted. The absence of such provisions, combined with the lack of thorough impact assessment, renders the proposal unjustifiable under Sections 2-1 and 2-2 of the Instructions for Official Studies. The proposal should therefore be rejected. Alternatively, a new, supplementary consultation including concrete transitional measures must be conducted before the proposal proceeds. Arbeids- og inkluderingsdepartementet Til høringen Til toppen <div class="page-survey" data-page-survey="133" data-page-survey-api="/api/survey/SubmitPageSurveyAnswer" data-text-hidden-title="Tilbakemeldingsskjema" data-text-question="Fant du det du lette etter?"