Euronext Growth Oslo – Consultation on New Information Document Requirements

The consultation is now open. Issuers, advisers and other market participants are encouraged to engage with the proposed changes. The consultation paper is available under «Consultations» here: Oslo | euronext.com.

The proposed changes are driven by an ambition to simplify and modernise the Information Document regime. Below we set out the principal features of the proposals.

A Single, Harmonised Notice Replacing Notice 2.3

The content requirements for Information Documents are proposed to in the future be governed by a single, consolidated notice issued under Rulebook I (section 3.1.2). The existing Notice 2.3 to Rulebook II, which currently sets out the content requirements for Euronext Growth Oslo, will be removed. This move towards harmonisation across Euronext growth markets – covering Oslo, Paris, Dublin, Lisbon, Brussels and Milan – means that issuers and advisers working across multiple Euronext markets will benefit from a single, consistent set of requirements, reducing complexity and administrative burden.

Simplified and Streamlined Content Requirements

The new framework has been designed with simplification at its core. Importantly, a number of specific content requirements that issuers previously had to address in their Information Documents will no longer be required as standalone items. These include, among others:

• Material contracts
• Related party transactions
• Information on statutory auditors
• Board practices
• Issuers without documented earnings capacity
• Historical information on directorships, bankruptcies and receiverships

This rationalisation removes requirements that were perceived as disproportionately burdensome for SMEs and growth market issuers. The general principle is maintained that the Information Document must address any significant matters that investors need to make an informed assessment of the issuer and its securities.

Incorporation by Reference for the Operating and Financial Review and Financial Statements

A particularly welcome development is the new flexibility around financial disclosures. Under the proposed new framework:

The Operating and Financial Review may be satisfied by incorporating the management report by reference, rather than requiring a standalone narrative within the Information Document itself.

The financial statements may similarly be incorporated by reference into the Information Document, rather than being reproduced in full.

This is a meaningful and practical improvement, reducing document length and preparation costs while preserving full transparency for investors.

What Happens Next?

The new requirements are expected to enter into force in the late third quarter or early fourth quarter of 2026, following completion of the separate local implementation processes across the relevant Euronext markets. 

Comments may be submitted to [email protected] by 31 July 2026. We strongly encourage all interested parties to participate.

We will keep you updated as the process progresses.

Wikborg Rein, acting regularly for issuers and financial advisers on Euronext Growth admission processes, views the proposed developments as a constructive evolution of the Euronext Growth Oslo framework, making the listing process and drafting of disclosures more efficient and better suited to the needs of companies pursuing a Growth listing.

Please do not hesitate to contact us if you have any questions or would like to discuss the implications of the proposed changes or if you have views on the proposed new requirements that we could reflect as part of our response to the consultation paper.