Norges Bank Account Management Terms: 2027 Draft Retires Test Keys

Norges Bank published a consultation letter on 2 November 2026 proposing revised Norges Bank account management terms, formally the Terms and Conditions for Account Management at Norges Bank, in a draft dated 1 February 2027. The letter is addressed to undertakings with an account at Norges Bank and to Finance Norway, and asks for comments by 1 December 2026. Two proposals remove arrangements that may still sit in contingency procedures: the contingency account and test keys.

An account holder commits to the Terms by completing, signing and submitting the Form for Account Management at Norges Bank (Section 1.1). Norges Bank lays them down under Section 3-1, second paragraph, of the Central Bank Act and the Regulation on access to lending and deposit facilities at Norges Bank, and last amended them with effect from 15 April 2024. The 2027 draft also adds duties: a broader notification obligation, a lending-access condition for direct clearing participants and a wider allocation of withholding risk to the account holder.

Related reading: NBO Prices and Fees 2027: Norges Bank Lifts Charges About 3%

The dates in the letter:

• 2 November 2026: letter published with the draft Terms and Annexes 1 and 2.
• 1 December 2026: comments due to the Interbank Settlement Unit at nbo@norges-bank.no.
• 4 January 2027: revised Terms scheduled to be announced by circular.
• 1 February 2027: scheduled entry into force. Until then the Terms in force from 15 April 2024 (Circular 2/2024) remain the current text.

Norges Bank account management terms: a third notice clock in Section 2.1

The 2024 Terms already require notice of changes to company structure, mergers or demergers no later than one month before they take effect. The draft adds a broader duty: the account holder shall, without undue delay, notify Norges Bank of any other operational or organisational changes that may be material to account management, including changes to the nature of its activities or its role in the payment system, in writing to the Interbank Settlement Unit. The English letter summarises the duty as covering changes that “may be relevant” and the English draft says “may be material”. The Norwegian letter and the Norwegian draft both use the same phrase, “kan ha betydning for kontoholdet”, and under Section 1.7 the Norwegian text applies in case of discrepancy.

Two existing rules keep their own triggers. Section 3.4 requires a change in NICS participation that affects settlement in NBO to be notified on the Form at least one week ahead, except where the account holder must switch settlement bank rapidly. Section 1.13 covers information Norges Bank asks for. The new Section 2.1 duty is the only one of the three that the account holder must trigger itself with no fixed lead time.

Lending access for direct clearing participants

Under Section 3.3 of the 2024 Terms, an account holder that participates directly in the settlement of clearings in Norges Bank must be a SWIFT participant in NBO. The draft adds a second condition, established access to Norges Bank’s lending facilities, and Norges Bank may in special cases grant an exemption from one or both requirements on application. Section 5.1 of the draft requires an account holder that wants access to Norges Bank’s lending facilities to sign and submit the Form for account management with Section D (Borrowing from Norges Bank) and Section E (Declaration of collateral) completed. Submitting the Form is a condition of access; the Regulation on access to lending and deposit facilities governs who is given access (Section 3), and loans must be adequately collateralised (Section 6).

What that access amounts to depends on Annex 2. A bank classified by Norges Bank as a monetary policy counterparty has access to all deposit and lending facilities, and the same status decides whether its reserves earn the policy rate within a quota, as covered in our note on Norges Bank Circular 3/2026 and bank reserve quotas. The draft Annex 2 widens the intraday-only group: besides banks from another EEA state offering cross-border banking services in Norway, it names other banks not classified as monetary policy counterparties. Their overnight deposits earn the policy rate minus 10 percentage points, overnight loans cost the overnight lending rate plus 10 percentage points, and repeated overnight use is regarded as a material breach that may lead to suspension or termination.

Section 3.6: a funded order can pass a held one

Where no settlement time is specified, both versions settle payment orders in the order received. The draft adds that a payment order may be settled even if an earlier payment order of the same priority is on hold due to insufficient funds. The ranking for an underfunded NBO LOM account stays as it is: interest on F-loans and foreign exchange trades with Norges Bank, then NICS Net clearings, then gross payment orders. A gross order still cannot be given priority over a clearing in a queue.

A liquidity view that treats a held order as blocking every later order of the same priority would not match NBO once the draft applies.

The contingency account arrangement ends for its one user

Norges Bank proposes that ordinary accounts serve as backup settlement accounts in place of the contingency account arrangement. The letter says the arrangement has been very little used, is considered unsuitable for contingencies because of the significant manual effort it requires, and is used by one bank. That bank would get a transition period to open an ordinary account or enter into an agreement with an alternative settlement bank. The letter does not say how long the period would be.

Under Section 4.1 of the 2024 Terms, a contingency account stays inactive until Norges Bank activates it, and within 14 calendar days of activation the holder must say whether it will deactivate it, open an ordinary account or close its account. The draft has no equivalent section. Circular 4/2026, published on 30 October 2026, still prices a contingency account at 15,000 per year for 2027, against 37,000 per month for a Group B bank with an ordinary account in NBO (amounts as printed; the price table carries no currency label).

The Norwegian Banks’ Guarantee Fund has a separate agreement under which an account can be activated in a contingency, and the letter says the discontinuation will not affect it. The letter also calls an ordinary account the more suitable contingency solution for banks that settle indirectly through a private settlement bank, since the holder manages payments and liquidity itself through NBO Online and has access to lending facilities. The draft Terms contain no provision that requires an indirectly settling bank to open one.

Test keys give way to an approved authentication solution

Section 4.3 of the 2024 Terms lets an account holder, with Norges Bank’s consent, submit payment orders, cash withdrawal orders or collateral release requests in a contingency by secure e-mail or telefax with a test key, or by signed letter. Orders with a correct test key bind both parties and are executed without further controls. The letter says test keys are rarely used and can be difficult to manage, maintain and practise using.

Draft Section 4.2 keeps the three order types and the consent condition, and requires “a secure communication and authentication solution approved at any given time by Norges Bank”, to which Norges Bank may add further requirements. The draft names no solution, and the signed-letter route is absent from its text. Norges Bank invites views on the functional and security requirements the solution should meet and on whether a transition period is needed before test keys are discontinued. Account holders that are not SWIFT participants in NBO depend on this route: under Section 4.1 they must submit payment orders through the contingency solution when the enhanced contingency mechanism is active, while SWIFT participants keep using SWIFT.

Section 4 is also renumbered. The enhanced contingency mechanism moves from 4.2 to 4.1, the contingency solution from 4.3 to 4.2, and contingency exercises from 4.4 to 4.3. Draft Section 4.1 still points non-SWIFT participants to “a contingency solution in accordance with Section 4.3”, which in the new numbering is the exercises section.

Section 5.10: withholding risk on pledged securities

The 2024 Section 5.10 makes the account holder responsible for correctly completing and timely reporting documents related to tax liability and tax reporting, and for submitting them to Norges Bank for signature and forwarding where required. The draft adds that the account holder bears the risk where that documentation is not provided or is incomplete, invalid or expired. Norges Bank would not be liable for withholding tax or other financial consequences, including withholding by the securities depository on interest or coupons on pledged securities.

The account holder also becomes responsible for ensuring securities are not pledged in a way that results in such withholding, and for requesting release within the applicable deadlines where release is necessary to avoid it. For collateral held by Euroclear Bank SA/NV or Clearstream Banking SA, release must be requested no later than the settlement day before maturity (Section 5.4), and registration and release requests follow the deadline in the operating schedule for NBO (Section 5.5).

Frequently Asked Questions

Is the T+1 operating schedule part of this consultation?

The operating schedule is a supplementary provision under Section 1.3, alongside prices and fees and the collateral guidelines, and has its own consultation: input by 27 November 2026 to post@norges-bank.no, covered in our article on the NBO operating schedule under T+1. The account terms consultation runs to 1 December 2026 at nbo@norges-bank.no.

Will consultation responses be published?

The account terms letter says comments may be published on the Norges Bank website; the operating schedule letter says responses will be.

If the English and Norwegian versions differ, which wording counts?

Section 1.7, in both the 2024 Terms and the 2027 draft, gives the Norwegian text precedence in case of discrepancy. In Section 2.2 the Norwegian “vesentlig mislighold” is rendered “material breach”, while Norwegian Section 2.1 uses “kan ha betydning for kontoholdet”, so a response on how far the notification duty reaches should address the Norwegian wording.

Does the new Section 3.6 sentence hold during a severe NBO disruption?

Section 3.6 lets Norges Bank deviate from its first and second paragraphs, where the new sentence sits, in the event of severe operational disruptions with reduced availability or capacity in NBO. Clearings, payments to CLS Bank and other gross payment orders important for completing payment settlements are then given priority.

Does the enhanced contingency mechanism itself change?

Draft Section 4.1 carries over Section 4.2 of the 2024 Terms, and the paragraphs match on a side-by-side comparison. Annex 1 defines the mechanism as the Market Infrastructure Resiliency Service (MIRS) operated by SWIFT, which can replace NBO’s main functions in an operational crisis. While it is active, all settlements except cleared NICS Real positions run in one account per account holder.

Related Articles

• NBO Prices and Fees 2027: Norges Bank Lifts Charges About 3%: the 2027 NBO price list and breach fees.
• NBO Operating Schedule Under T+1: Norges Bank’s 16:45 Incident Cut-Off: the parallel consultation on the schedule and incident management.
• Norges Bank Circular 3/2026: New Reserve Quotas From 1 October: reserve quotas for monetary policy counterparties.
• Norges Bank Financial Infrastructure Report 2026: What Nordic PSPs Must Track: Norges Bank’s 2026 infrastructure report.

Key Takeaways

• By 1 December 2026: decide whether to ask for a test-key transition period and which requirements to propose for the replacement solution.
• Ahead of the proposed 1 February 2027 commencement: confirm that each direct clearing participant has established access to Norges Bank’s lending facilities, rather than checking only that Form Sections D and E are on file. Review the applicable collateral arrangements, and rely on the special-case exemption only where the final Section 3.3 confirms it covers the lending-access condition.
• Once the circular scheduled for 4 January 2027 confirms the numbering: re-point runbooks that cite Sections 4.2, 4.3 and 4.4 to 4.1, 4.2 and 4.3.
• Under draft Section 2.1, add Norges Bank notice, without undue delay, to change-management sign-off for any other operational or organisational change within the trigger as worded in the prevailing Norwegian text, including changes to activities or payment-system role, separate from the merger and NICS notice periods.
• Before interest or coupon payment dates on pledged securities: assess potential withholding and any release required under the final Section 5.10. For securities held by Euroclear Bank SA/NV or Clearstream Banking SA, apply the operating-schedule deadline in Section 5.5 to registration and release requests. Apply the previous-settlement-day release requirement in Section 5.4 where those securities are approaching maturity or redemption.

Sources and References

• Norges Bank, consultation on the account management terms (2 November 2026): consultation letter
• Norges Bank, draft Terms, 1 February 2027: PDF
• Norges Bank, Norwegian versions: consultation letter; draft Terms, 1 February 2027 (PDF)
• Norges Bank, draft Annex 1, Definitions: PDF
• Norges Bank, draft Annex 2, Access to deposit and lending facilities: PDF
• Norges Bank, Circular 2/2024, Terms from 15 April 2024: circular; Terms (PDF); Annex 2 (PDF)
• Norges Bank, Circular 4/2026, NBO prices and fees for 2027 (30 October 2026): circular
• Norges Bank, Circular 3/2026, reserve quotas (1 September 2026): circular
• Norges Bank, consultation on the NBO operating schedule under T+1 (16 October 2026): consultation letter (PDF)
• Norges Bank, Regulation on access to lending and deposit facilities at Norges Bank (18 December 2019): English translation
• Norges Bank, NBO regulations and forms: norges-bank.no

What to Send Norges Bank Before 1 December

Comments go to the Interbank Settlement Unit by 1 December 2026, and a response can raise drafting points alongside the test-key questions, such as the Section 4.1 reference to Section 4.3. If Norges Bank adopts the revised Terms on its proposed timetable, account holders should use the period between the planned 4 January 2027 circular and 1 February 2027 commencement to validate lending access and prepare contingency procedures against the final requirements, taking account of any transition period specified for the replacement authentication solution.

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