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NorwayArbeidstilsynet

AMU guidance drops top-management rule for employer deputies

The rewritten deputy paragraph keeps one deputy per AMU member but no longer says the employer deputy must come from top management, and says worker deputies are elected with the members.

By Taxxa AI OyPublished 18 September 2026

Payroll & Labour

Industry: Across industries

Every member of the working environment committee (arbeidsmiljøutvalg, AMU) must have a deputy (vara): «Hvert medlem i arbeidsmiljøutvalget må ha en stedfortreder (vara)». That one-deputy-per-member starting point is unchanged in substance from the previous «Hvert medlem i arbeidsmiljøutvalget skal ha personlige stedfortredere (vara)».

What changed is who the deputies are and how they are chosen. The previous text required the employer deputy to be designated by the employer and to come from the top management of the businessArbeidstilsynet («Stedfortreder for arbeidsgiver skal utpekes av denne og være fra virksomhetens øverste ledelse»). That top-management condition is goneArbeidstilsynet: the new text says only that the employers designate their representatives and deputies, who may step in when members are absent («Arbeidsgiverne utpeker sine representanter og stedfortredere som kan tre inn ved medlemmenes fravær»Arbeidstilsynet). Employers running AMU elections should therefore no longer treat top-management membership as a stated eligibility condition for an employer deputy on the basis of this guidanceArbeidstilsynet.

On the worker side, the previous text said deputies for the employee representatives shall be elected or designated under the same rules as AMU members («Stedfortredere for arbeidstakernes representanter skal velges eller utpekes etter de samme reglene som AMU-medlemmer»). The new text narrows this to election: the employee representatives are elected, and at the election both members and personal deputies are elected («Arbeidstakernes representanter velges. Ved valget velges både medlemmer og personlige stedfortredere»). The «or designated» alternative no longer appears in the paragraphArbeidstilsynet.

The regulation behind the paragraph still states both rulesLovdata. Section 3-11 of the forskrift om organisering, ledelse og medvirkning provides that members of the committee shall have deputies; that the employer deputy shall be designated by the employer and come from the top management of the businessLovdata; and that deputies for the employee representatives shall be elected or designated under the rules in §§ 3-9 and 3-10Lovdata, with employee representatives and deputies elected together where an election is held. The guidance text and the regulation therefore now differ on these two points: the guidance no longer reproduces the top-management condition or the designation alternative. The guidance text does not state that the regulation has changed; on the regulation text fetched here, § 3-11 still contains bothLovdata.

The surrounding AMU frame is unchanged. Businesses with at least 30 employees must establish a committee, and businesses with between 10 and 30 employees must have one if either party so requires. Members are elected for two years at a time, and the committee leader is elected for one year, alternating between the employer and employee sides. The committee advises the employer on working-environment matters, takes part in planning the safety and working-environment work, and has decision-making authority in three specific cases: ordering the employer to implement concrete measures necessary to protect life or health, ordering measurements or investigations to clarify health hazards, and having external actors investigate occupational accidents.

In practice, employers should check election procedures and deputy appointments against the current guidance wording and the regulation text, and not rely on the removed top-management sentenceArbeidstilsynet or the removed «or designated» alternativeArbeidstilsynet when composing the committee.

Legal basis: composition and deputies of the working environment committee under forskrift om organisering, ledelse og medvirkning §§ 3-7 to 3-11.

Check AMU election procedures and deputy appointments against the current guidance wording and forskrift om organisering, ledelse og medvirkning § 3-11 before the next election or appointment.

Sources