Norway, Iceland and Liechtenstein

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If you are from Norway, Iceland or Liechtenstein, Switzerland treats you in practice the same as an EU citizen: you get the same B, C, L and G EU/EFTA permits under the same conditions. The legal basis is Annex K of the EFTA Convention rather than the EU agreement, but the result is the same. The one real difference is Liechtenstein: moving from Liechtenstein to Switzerland is free, but a Swiss national who wants to live in Liechtenstein faces a quota.

In short

• Same rights as EU citizens. Norwegian, Icelandic and Liechtenstein nationals get B/C/L/G EU/EFTA permits on the same terms as EU nationals, with no quotas and no priority for local workers.
• C permit after 5 years of uninterrupted lawful residence, if you meet the integration criteria (Art. 58a FNIA).
• Family reunification is broad: spouses, registered partners, children under 21, dependent children and dependent parents, with no language test on first grant.
• Naturalisation has no EFTA shortcut. You follow the ordinary Swiss Citizenship Act (SCA) route like everyone else.
• Liechtenstein is asymmetric. Liechtenstein nationals move to Switzerland freely, but Swiss nationals need a quota-limited residence authorisation to live in Liechtenstein.

Why EFTA works like the EU agreement

The European Free Trade Association (EFTA) has four members: Switzerland, Norway, Iceland and Liechtenstein. Norway, Iceland and Liechtenstein are also in the European Economic Area (EEA), which gives them EU free movement. Switzerland rejected the EEA in 1992 and instead has a bilateral Agreement on the Free Movement of Persons with the EU (AFMP, SR 0.142.112.681).

To give all four EFTA states free movement among themselves, the 1960 EFTA Convention was revised by the Vaduz Convention of 21 June 2001. Since 1 June 2002, Annex K of the Convention (with its Appendix 1 on free movement of persons) has set up rules that are largely identical to the AFMP. That is why you see the label "EU/EFTA permit": same permit types, same conditions. Only the treaty is different.

Norway and Iceland: permits and conditions

In Switzerland, Norwegian and Icelandic nationals fall under Appendix 1 to Annex K. Swiss law applies it through the Federal Act on Foreign Nationals and Integration (FNIA, SR 142.20) and the Ordinance on Admission, Residence and Gainful Employment (OASA, SR 142.201).

The conditions mirror the EU rules:

• Employees and self-employed people: you need an employment contract or proof of self-employment. There are no quotas, no priority for resident workers, and no skills test under Art. 23 FNIA (that test applies only to third-country nationals).
• People not working: you need enough money to live on (cantons usually measure this against the level of supplementary benefits) and full health insurance.
• Students: you need enrolment at a Swiss university or recognised school, plus money and health insurance.

The State Secretariat for Migration (SEM) updates its "Residence EU/EFTA" page and its directives regularly. Always check the current version at https://www.sem.admin.ch/sem/de/home/themen/aufenthalt/eu_efta.html for the latest practice.

Liechtenstein: a special case

Liechtenstein has just under 40,000 inhabitants and three layers of treaties with Switzerland:

1. The settlement treaty of 6 July 1874, which gave both countries mutual freedom of settlement and trade. Later agreements have largely replaced it.
2. The Customs Union Treaty of 29 March 1923 (SR 0.631.112.514, in force since 1924), which makes Liechtenstein part of the Swiss customs territory and creates an economic, monetary and customs union. Separate free-movement agreements between the two states (SR range 0.142.115.x) govern residence today. Check the current consolidated versions on fedlex.admin.ch.
3. Annex K of the EFTA Convention, which applies free movement among all four EFTA members.

On paper Annex K is symmetrical. In practice, Liechtenstein negotiated a special arrangement within the EEA that lets it cap immigration from EEA and EFTA states, Switzerland included, with its own annual quotas. The reason is its very high share of foreign residents (around one third of the population) and the need to keep a small state's population balanced. For exact figures, see the Office of Statistics of the Principality of Liechtenstein.

Moving from Liechtenstein to Switzerland

Liechtenstein nationals are fully covered by Annex K when they come to Switzerland. They receive B, L, G or C EU/EFTA permits on the same criteria as EU citizens. Switzerland has no quota for them.

Commuting from Liechtenstein to work in Switzerland

Some Liechtenstein residents work in Switzerland, mostly in the Canton of St. Gallen (Rheintal, Werdenberg, Sarganserland) and nearby parts of Graubünden. They receive a G EU/EFTA cross-border commuter permit (Art. 35 FNIA, Art. 39 OASA). The conditions are the same as for EU commuters:

• you live in Liechtenstein (returning home once a week is enough; you do not need to return daily);
• you work in Switzerland, as an employee or self-employed;
• there are no grounds of public order or security against you.

The numbers are small compared with commuters from Germany, France or Italy. The Federal Statistical Office (FSO) and SEM publish the figures. For the permit itself, see the G cross-border commuter permit.

Swiss nationals working or living in Liechtenstein

Many more people commute the other way: Switzerland is, with Austria, one of the main home countries of Liechtenstein's cross-border workforce.

• Working in Liechtenstein while living in Switzerland: you apply for a Liechtenstein cross-border commuter permit under Liechtenstein law. It is not subject to the residence quota, because you do not live there.
• Moving to Liechtenstein: you need a Liechtenstein residence authorisation, which is subject to a quota. You have no automatic right to live there. The routes are a residence authorisation linked to a job (itself quota-limited), the annual draw (a lottery for part of the authorisations), or a recognised family reason such as being the spouse or child of a Liechtenstein national, which also has limits.

Liechtenstein sets its quotas each year. For quotas, the draw, residence and settlement in Liechtenstein, contact the Ausländer- und Passamt (APA), the Office for Foreign Nationals and Passports in Vaduz, at https://www.llv.li/de/landesverwaltung/auslaender-und-passamt, or a lawyer admitted in Liechtenstein.

The C permit after 5 years

Norway and Iceland. You can get the C EU/EFTA settlement permit after 5 years of uninterrupted lawful residence. This rests on the old bilateral settlement treaties with Norway and Iceland, which SEM lists as "five-year treaty states" (see section 5 of the Switzerland and USA Settlement Treaty 1850 for a similar list), and on SEM practice for earlier grants to integrated EU/EFTA nationals (Art. 60 OASA). You must meet the integration criteria of Art. 58a FNIA: language skills, financial independence, respect for public security and order, and respect for the values of the Federal Constitution. Art. 62 para. 1bis OASA sets the language level for the early C permit, usually at least B1 spoken and A1 written in a national language. Your cantonal migration office decides.

Liechtenstein. Liechtenstein is also a traditional five-year treaty state. In current practice, Liechtenstein nationals get the C EU/EFTA after 5 years of lawful residence on the same terms as EU citizens.

Swiss nationals in Liechtenstein follow Liechtenstein's own system for a settlement authorisation, which usually needs a longer stay and integration. It does not map onto the Swiss B/C system; ask the APA.

Language requirements

For the C permit and later for naturalisation, you need a Swiss national language: German, French, Italian or, to a limited extent, Romansh (Art. 58a para. 1 let. c FNIA; Art. 60 para. 2 or Art. 62 para. 1bis OASA).

• Norway: Norwegian (Bokmål or Nynorsk) does not count. You need B1 spoken and A1 written in a Swiss national language, usually the language of your canton. German is often easier for Norwegian speakers, but the test is in the Swiss language.
• Iceland: Icelandic does not count either. The same rules apply as for Norwegians.
• Liechtenstein: Liechtenstein is German-speaking, so in German-speaking cantons you will usually meet the requirement easily. You still have to provide the formal proof.

Recognised tests include fide, telc, Goethe, DELF and CELI; other equivalent evidence is accepted under Art. 77d para. 1 let. d OASA. See the language certificate A1/A2/B1 fide.

Family reunification

For all three countries, family reunification follows Appendix 1 to Annex K, modelled on Art. 3 Annex I AFMP. It is much broader than the third-country rules in Art. 43-44 FNIA.

The conditions are:

• suitable housing for the whole family;
• compulsory health insurance for everyone;
• no dependence on social assistance (in practice, you keep your status as an employee or self-employed person);
• no grounds for revocation for breach of public order or security.

This is far more generous than for nationals of the USA, the UK (after Brexit), Canada or Australia. The A1 language requirement on first grant (Art. 73a OASA) applies only to third-country family reunification. EFTA family reunification has no language requirement on first grant.

Naturalisation

The EFTA Convention and the bilateral agreements do not cover Swiss citizenship. Norwegian, Icelandic and Liechtenstein nationals go through ordinary naturalisation under the Swiss Citizenship Act (SCA, SR 141.0), the Swiss Citizenship Ordinance (SCO, SR 141.01) and cantonal and communal law.

The standard conditions (Art. 9, 11 and 12 SCA):

• Residence: 10 years of lawful residence, including 3 of the last 5 years before you apply. Years between your 8th and 18th birthdays count double, but you need at least 6 actual years (Art. 9 SCA).
• C permit: you must hold one when you apply.
• Integration (Art. 11 let. a and Art. 12 SCA): respect for public security and order and constitutional values, taking part in working life or education, and supporting your family's integration. The language level, usually B1 spoken and A2 written in a national language, comes from Art. 6 SCO.
• Familiarity with Swiss life (Art. 11 let. b SCA); some cantons test this.
• No social assistance in the years before you apply, under the applicable rules.
• Cantonal and communal residence periods and interviews, which vary by place.

Facilitated naturalisation for the spouse of a Swiss citizen (Art. 21 SCA) is possible after 5 years of residence in Switzerland and 3 years of marriage, or, if you live abroad, after 6 years of marriage and close ties to Switzerland. This applies to every nationality.

So the only EFTA advantage is reaching the C permit in year 5 instead of year 10. For more, see the Citizenship Act 2018 glossary and the paths to naturalisation.

Liechtenstein citizenship is a separate matter with its own strict rules, which traditionally need the approval of the Landtag (parliament) or in some cases a vote in the municipality. For that, ask Liechtenstein legal services.

EFTA and the EU agreement compared

For a Norwegian, Icelandic or Liechtenstein national living in Switzerland, the legal position is essentially the same as for a German, Italian or French national. See also the AFMP glossary and the FNIA and OASA glossary.

Dual citizenship

Switzerland has allowed multiple nationality without restriction since 1992. You do not lose Swiss citizenship by taking Norwegian, Icelandic or Liechtenstein nationality, or the other way round.

The other countries' rules differ. Check with their authorities before you act:

• Norway has generally allowed dual citizenship since 1 January 2020. Older cases fall under Norwegian transitional law.
• Iceland has allowed it in principle since a reform in the 2000s.
• Liechtenstein allows Swiss and Liechtenstein dual citizenship with restrictions. When you naturalise in Liechtenstein, you traditionally have to give up your previous nationality, with exceptions such as acquisition by birth or, under some conditions, by marriage. Ask the APA.

Tax and social security

Annex K covers free movement, not tax. Taxes between Switzerland and Norway, Iceland and Liechtenstein are governed by separate double taxation agreements, each with amending protocols. The State Secretariat for International Financial Matters (SIF) keeps the list, and the texts are on fedlex.admin.ch. Liechtenstein also forms a single VAT territory with Switzerland through the 1923 customs treaty. Withholding tax on wages depends on cantonal tax law and the relevant agreement. For tax, pension or social security questions, ask a specialist.

Related pages

• The B residence permit
• The C settlement permit
• The L short-term permit
• UK Citizens' Rights Agreement: the UK was never an EFTA member.
• Settlement agreements with Germany and Austria

Sources

• EFTA Convention (1960, revised by the Vaduz Convention of 21 June 2001), SR 0.632.31, Annex K Appendix 1, in force since 1 June 2002.
• AFMP, SR 0.142.112.681.
• FNIA, SR 142.20; OASA, SR 142.201.
• SCA, SR 141.0; SCO, SR 141.01.
• Customs Treaty between Switzerland and Liechtenstein of 29 March 1923, SR 0.631.112.514; Settlement Treaty of 6 July 1874 and later free-movement agreements (SR 0.142.115.x).
• SEM, Residence EU/EFTA: https://www.sem.admin.ch/sem/de/home/themen/aufenthalt/eu_efta.html
• Liechtenstein APA: https://www.llv.li/de/landesverwaltung/auslaender-und-passamt