Hvitvask filing opens to Enhetsregisteret roles; legacy roles kept in transition

AIF managers (AIF-forvaltere) and fund management companies (forvaltningsselskap), including branches of foreign firmsAltinn, report information about anti-money-laundering work to FinanstilsynetAltinn once a yearAltinn through form KRT-1189, "Hvitvask"Altinn. The filing carries no attachmentsAltinn and is submitted from the form's inbox entry point. Undertakings under supervision must give Finanstilsynet all information it requiresLovdata and hand over documentation and information in the manner Finanstilsynet prescribesLovdata, under Finanstilsynsloven § 3-1Lovdata; this annual filing is one such prescribed reportAltinn.

Access to the filing has changed. A filer previously needed an authorisation (fullmakt) for the single service or for the Dokumentbasert Tilsyn access packageAltinn, obtained by delegation from someone entitled to delegateAltinn. Now the first qualifying route is holding a role in the EnhetsregisteretAltinn: anyone with such a role may fill in and submit the form without any separate delegationAltinn. The two authorisation routes remain as alternatives: a fullmakt for the single service or for the Dokumentbasert tilsyn packageAltinn.

Alongside the permanent routes, a transition period keeps the form available to anyone who already holds one of these roles from old Altinn — Regnskapsmedarbeider, Daglig leder, Utfyller/Innsender. A reporter who already holds one of those legacy roles can therefore still file while the transition lasts, even without a new-model register role or a fresh authorisationAltinn. No end date for the transition period is givenAltinn, so it should not be treated as open-ended: undertakings should move their reporting staff onto a permanent route rather than rely on the legacy roles.

For the coming annual round, the practical question is who at the firm holds what. A compliance officer with an Enhetsregisteret role is already qualifiedAltinn; anyone else needs a fullmakt for the single service or for the Dokumentbasert tilsyn package before the filing windowAltinn. Administrators should check each intended filer's register role now, arrange the missing authorisations through delegation by someone entitled to delegate themAltinn, and confirm that holders of the three legacy roles have a migration plan. The filing itself is unchanged — annual, no attachments — and questions go to Finanstilsynet's reporting pages or post@finanstilsynet.no.

The change mirrors the wider Altinn access transition, in which legacy roles give way to register roles, single-service authorisations and access packages. For this form the Dokumentbasert tilsyn package survives as an explicit alternativeAltinn, so firms that already administer access through that package need no change.

Legal basis: Finanstilsynsloven § 3-1 on supervised undertakings' duties to provide informationLovdata, applied through Finanstilsynet form KRT-1189 "Hvitvask" with its "Tilgang og fullmakter" section.