Altinn rewrites bank and insurance filing guides; 100 firms in scope

Brønnøysundregistrene has rewritten the Altinn filing guides for annual accounts in banking and finance (RR-0003), non-life insurance (RR-0004) and life insurance (RR-0005)Altinn. All three guides now state that from the 2024 financial year, large public-interest undertakings with over 500 employees must file the management report (årsberetning) with sustainability reporting together with the annual accountsAltinn — and that this sustainability-reporting duty covers about 100 undertakings, up from the about 60 previously statedAltinnAltinn. Filers in that group must state in the form which sustainability reporting standard was used (mandatory); they may state which taxonomy was used (optional) with its version number where given, and the LEI number (optional). Where a taxonomy is given, the management report including sustainability reporting must be in iXBRL and XHTML formats packed in a zip file as a file attachment; otherwise it is filed as a text or image attachment such as Word or pdf.

The rewritten guides add a dedicated Vedlegg section spelling out which attachments to add. Small undertakings complete the notes in the form and need not attach the management report or cash-flow statement; where they also have no audit duty (see revisorloven § 2-1 for exceptions), no file attachment is needed at all. Undertakings not following the small-undertaking accounting rules must attach notes, the management report, the cash-flow statement and in most cases the auditor's report as file attachments. The life-insurance guide (RR-0005) lists the attachments to be delivered as notes (notar), the annual report (årsmelding), the cash-flow statement (kontantstraumsoppstilling) and the auditor's report (revisjonsmelding).

The guides also restate the standing rules for special cases. A Norwegian-registered foreign undertaking (NUF) filing for both the foreign undertaking and the Norwegian branch enters the foreign undertaking's figures in the form and attaches the branch accounts as a file attachment; the NUF contact person may complete and sign. A parent using a foreign group account where the Norwegian business is included — permitted within the EEA, or outside the EEA with a Skattedirektoratet dispensation — attaches it as a file attachment without entering the foreign group figures, marking this in the main form. Dispensations from the Norwegian-language requirement (regnskapsloven § 3-4 third paragraph) and from preparing own group accounts (regnskapsloven § 3-7 fourth paragraph) must be attached each year. There is no requirement to scan originals; image and text files are accepted, security resting on the filer's Altinn role and confirmation that competent-body adoption took place, so no signature is required — and only documents relevant to the annual accounts may be attached.

Filing mechanics are reorganised around a new flow: after entering figures the filer reviews a summary before signing (Før innsending), then chooses Til signering and Signer og send inn. The guides drop the old-version passages on adding schedules and attachments from the Oversikt tab — though a transition rule on using roles from gamle Altinn is kept; on the life-insurance page the IFRS-rule sentence and the § 3-4/§ 3-7 dispensation-filing paragraphs fall away, while the reworded rule on using a non-EEA parent's consolidated accounts with a Skattedirektoratet dispensation is kept. The bank and non-life guides add that e-mail addresses on page two trigger processing notifications, including to Altinn notification addresses or by SMS where only a mobile number is registered.

Legal basis: the filing guides for RR-0003, RR-0004 and RR-0005 (Brønnøysundregistrene via Altinn); regnskapsloven §§ 3-4 and 3-7 on dispensations; revisorloven § 2-1 on audit-duty exceptions.