This site provides template texts for EU/EEA citizens who wish to file complaints to the EFTA Surveillance Authority (ESA) regarding Norway’s citizenship acquisition residence requirements.
Norway has stricter residence requirements for EU/EEA citizens seeking citizenship than it does for citizens of other nationalities. Specifically, EU/EEA nationals cannot have stayed outside Norway for more than two months per calendar year during the three years before citizenship is granted. The rationale for this restriction is to ensure that applicants have a genuine connection to Norway. This practice may violate EEA law.
Private persons, NGOs and companies may lodge complaints with ESA against Iceland, Liechtenstein or Norway if they consider national legislation or administrative measures to be incompatible with a provision or principle of EEA law. Read more here: Internal Market complaints | ESA
Mara (23) has lived in Norway since the age of 18 months. She was denied citizenship because she studied abroad for one semester in Germany. Read her story here(in Norwegian).
Thijs (23) was born and raised in Norway. He was denied Norwegian citizenship due to his international study exchange in the Netherlands.Read his story here(in Norwegian).
The template includes suggested texts for key sections of the ESA complaint form:
Question 8: Detailed account of the facts
Question 9: Relevant EEA law provisions
Question 15: Supporting documentation list
This template is freely available for EU/EEA citizens (and others) to use and modify. You will need to add your personal circumstances and details to the texts, particularly in Question 8.
Question 8: Norway’s Nationality Act (Statsborgerloven, sbl) §14 requires EU/EEA applicants to have resided in Norway for the last three years with a right of residence. Under current legislation, applicants cannot be abroad for more than two months per calendar year during this period and throughout UDI’s processing time (averaging 30 months). This creates stricter limitations for EU/EEA citizens compared to other applicants, affecting thousands of people, particularly those who need to travel for work, studies, or family emergencies.
Question 9: The complaint argues that Norway’s citizenship residence requirements under Nationality Act (Statsborgerloven; sbl) §14 and Nationality Regulations (Statsborgerforskriften, sbf) §3-4 violate EEA law in three main ways:
They discriminate against EU/EEA citizens (violating Article 4 EEA Agreement) by imposing stricter residence requirements compared to Nordic citizens and third-country nationals.
They breach fundamental EEA freedoms (Articles 21, 28, and 36) by restricting movement to just 2 months per year under sbf §3-4, which disproportionately limits rights to work, establish business, and receive services in other EEA countries.
Norwegian authorities incorrectly claim EEA law doesn’t apply to citizenship requirements, contradicting established EU/EEA case law which confirms that while states can set citizenship rules, these must comply with EEA law and proportionality principles.
Question 15: A comprehensive list of official Norwegian legal documents, regulations, and administrative guidance that serve as evidence supporting the complaint’s arguments about discriminatory citizenship requirements for EU/EEA citizens. This list (with hyperlinks) is also available here.
