Most foreign companies with assignments at Norwegian building or construction sites need specific ID cards for their workers. Without these ID cards their workers will be denied access to Norwegian building or construction sites. Below we will explain further what these ID cards are, why they are needed, and how to get them.
What are ID cards for building and construction sites?
ID cards for building and construction sites (“HSE cards” / “HMS-kort” / “byggekort”) are ID cards that workers must keep clearly visible while present on a building or construction site in Norway. These ID cards provide Norwegian authorities and clients with an overview of who is working at a building or construction site, and who they are working for. The ID cards are supposed to increase security, prevent social dumping and prevent illicit work.
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Why do foreign companies need ID cards for their workers?
Norwegian law requires all enterprises that carry out work on a construction or building site, to provide ID cards for their workers. Many contracts for assignments in Norway also require foreign contractors to get ID cards for their workers. Failure to comply with this requirement may have serious consequences.
Foreign workers without ID cards may simply be denied admission to the building or construction site, causing a delay to the assignment in Norway. A delay / failure to comply may lead to negative contractual and/or commercial effects for the foreign contractor. Additionally, Norwegian authorities may fine foreign contractors for failing to comply with the requirement.
How can foreign companies get ID cards for their workers?
The ID cards can only be ordered from a card issuer designated by the Ministry of Labour and Social Inclusion. Foreign companies may face several challenges when ordering ID cards for their workers, since quite a lot of requirements must be met before the ID cards can be ordered. Additionally, at times there may be long processing times with Norwegian authorities. Thus, a foreign company should prepare for ordering the ID cards as soon as possible. Below we will present the requirements that must be met before the cards will be issued.
Requirement 1: The foreign company must be registered in Norway
Before an ID card can be ordered the foreign contractor must register their company at the Central Coordinating Register for Legal Entities (“Enhetsregisteret”). Such registration is mandatory under the ID card regulations. By registering, the foreign company will get a Norwegian organisation number which provides unique identification of the company.
Staffing enterprises must also register at the Register of Staffing Enterprises. VAT liable companies are required to additionally register in the VAT register.
Requirement 2: The contract and workers must be reported
Before an ID card can be ordered, the foreign contractor must report the contract and workers to the Norwegian tax authorities. The contractor reports the contract and workers by filing RF-1198. The client will file RF-1199. The report can be filed through the online portal “Altinn”.
Correctly reporting the assignment and workers is very important. Any mistakes with the reporting, particularly with the reported dates of the assignment or working periods of the workers, may become a serious obstacle when ordering the ID cards.
Requirement 3: An orderer must be registered
An orderer must be registered once the company has been registered, the contract and workers have been reported, form RF-1198 processed, and the D-numbers have been assigned. The orderer is a person formally responsible for ordering the ID cards. The orderer must be selected from one of the workers reported on RF-1198, or each worker could be an orderer of their own ID card. It is important that the orderer has received a D-number and that he has an active employment in Norway at the time of registering him as an orderer.
If one worker orders ID cards on behalf of all workers, then this worker needs to have an active employment in Norway when ordering ID cards for the other workers. The orderer’s reported working period should be at least for the same periods (or longer) as the other workers. Thus, it may be preferable to make the worker with the longest working period reported on RF-1198 the orderer of the ID cards.
Requirement 4: The cards must be ordered correctly
Having registered an orderer, it is time for ordering the ID cards. At this time all workers must be successfully registered in Norway and have received their D-numbers.
The ID cards must be ordered through the online portal of a specific card issuer. When ordering the ID cards, a copy of each worker’s picture and signature must be uploaded to the online portal. A copy of each worker’s passport or national identity card must also be uploaded.
The documents uploaded must meet certain requirements, otherwise the order will be rejected. The copy of the pictures should meet the quality standards of a passport photograph (i.e. a clear, focused picture on a white background). Likewise, the copies of the passports, and the signatures should be clear and good quality. Any uploaded document, not in compliance with these requirements, may result in the order being fully or partially rejected.
When the documents have been uploaded, a small fee must be paid for the ID cards. The application can then be submitted. Sometime after having submitted the application, the orderer will receive a confirmation of order if the order was successful. If the order was unsuccessful, the orderer will receive a rejection specifying what is wrong or missing.
To show the complexity of the ID card procedure, it makes sense to exemplify:
NewCo Limited from Great Britain has won a contract in Norway, hiring out workers to install elevators in a new building in Oslo. The assignment will take approximately 2 months. According to the contract, all workers must have ID-cards to enter the building site.
The contract, that is signed on 10.10.2019, states that the work will start up on 10.12.2019.
The first step for NewCo Limited is to register with the Central Coordinating Register for Legal Entities. To register the company, a paper form must be used. The processing time at the Brønnøysund Register Centre varies greatly throughout the year – but a paper form could take 3-4 weeks to process. There is no need to wait, so in this example we would advise that the registration process is initiated as soon as the contract has been signed. It could make sense to register a Norwegian lawyer / accountant / advisor as a temporary contact person to save a week or two.
Simultaneously, NewCo Limited can report contract information through the RF-1199 / RF-1198 form. Although the start-up is 10.12.2019, it would make sense to use (for instance) 01.12.2019 as start date. The form can be corrected at a later point. The RF-1199 / RF-1198 form can be filed, per paper, as soon as the contract has been signed, and before the registration process at the Brønnøysund Register Centre has been finalized. There really is no reason to wait.
As already mentioned, the RF-1198 form includes basic employee information. Again, it would make sense to use 01.12.2019 as start date and change this later on.
The tax authorities will use some time to process the RF-1199 / RF-1198 paper form, but probably not more than two weeks.
By 15.11.2019, NewCo Limited has successfully registered in the Brønnøysund Register Centre, obtained a Norwegian business register number, and successfully registered a RF-1199 / RF-1198 paper form.
The Norwegian business register number also gives NewCo Limited access to Altinn, and the Altinn-based system called the “Assignment and employee register”. When accessing the system, you will most likely find a list of the workers reported, as well as their Norwegian ID-number.
As mentioned, NewCo Limited is hiring out their workers. Therefore, about 15.11.2019, we should also make sure that the foreign company is registered in the Register for Staffing Companies. It should take approximately 7-10 days to get this registration in order.
On 01.12.2019, the “start date” according to the RF-1199 / RF-1198, one of the employees – who has been elected as an “orderer” files the ID-card application, using an electronic service called www.byggekort.no. Obviously, the “orderer” can hand over this assignment to a Norwegian service provider, like an accountant or a lawyer. To order ID-cards, the “orderer” must have the ID-number of all employees, a picture and a signature of each worker.
The RF-1199 / RF-1198 form must cover the day when the orderer is ordering the ID-cards. This explains why using 10.12.2019 as a “start date” in the RF-1199 / RF-1198 will cause delays. If 10.12.2019 is used as a “start date”, ID-cards cannot be ordered until 10.12.2019.
ID-cards are issued by the Norwegian Labour Inspection Authorities. Before issuing the cards, they will check whether the company is:a) Registered in the VAT-register (relevant for foreign companies with a Norwegian
turnover exceeding NOK 50 000).
b) Registered in the Register for Staffing Companies – which should be relevant for foreign
companies hiring out their employees.
In our example, alternative b) is in order – and the Norwegian Labour Inspection Authorities should accept the ID-card application.
When the ID-cards have been ordered, they will probably be issued within a week. In other words, in our example, all ID-cards should physically be with the workers before 10.12.2019, and the workers can enter the building site as planned – eliminating the risk of delays and compulsory fines.
For the sake of good order, the workers should visit the tax office for an ID-check as soon as they arrive in Norway.
Find out more about how Magnus Legal can assist expats in Norway.
Foreign companies with workers at Norwegian building or construction sites need specific ID cards for their workers to avoid fines and workers being denied access to the sites. Before the ID cards can be issued, the foreign company must register with the Central Coordinating Register for Legal Entities, report their contracts and workers on RF-1198, register an orderer with the card issuer, and order the cards correctly using an online portal.
The process to order ID cards may take time, and there is the possibility that the order will be rejected. Thus, foreign companies with assignments at Norwegian building or construction sites, should register and report to Norwegian authorities as early and diligently as possible.
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Article first published 14 August 2018 - updated August 2019