Dato: 11.11.2025 Svartype: Med merknad This høringssvar is provided by the local staff at the Royal Norwegian Embassy in Berlin who are insured under the German social security system, not under the Norwegian system. In a letter dated 30 May 2022, the AID ( Arbeids- og inkluderingsdepartementet , Ministry of Labour and Inclusion) defined all local staff at Norwegian diplomatic missions abroad as employees of the Norwegian state and therefore subject to compulsory insurance under the Norwegian social security system . This would also have affected those of us insured under the German system. Alternatively, the possibility of applying for an exemption from the above-mentioned compulsory insurance in Norway was mentioned. In Germany, the DVKA (Deutsche Verbindungsstelle Krankenversicherung Ausland) is responsible for this. During a telephone call, it emerged that this exemption can be applied for a maximum of 5 years, has to be reviewed on a case-by-case basis, and might (!!) be extended after the 5 years have expired. We received all this information at very short notice. We were asked to decide quickly whether we wanted to switch to the Norwegian system or (with an exemption) remain in the system of the country of employment (Germany), without being informed of the consequences of a change. In addition, a change would have affected not only health insurance, but all types of social insurance (i.e. pension insurance, long term care insurance and unemployment insurance as well). When we asked for clarification, we were simply referred to the relevant hotline at NAV Norway and told that everyone would have to clarify the consequences for himself/herself. In addition, a change would have meant that social security contributions would have to be paid retrospectively in Norway and reclaimed from the social security institutions in the country of employment. It is understandable that this approach caused unrest and dissatisfaction not only among us, but in all Norwegian diplomatic missions, together with a significant loss of trust and a feeling of being left alone. The reaction from all sides was accordingly. After much back and forth, the whole matter was put on hold. Following our enquiries, we were informed several times, both verbally and in writing, that the aim of a new regulation was to give the individual employee the right to choose which social security system (in Norway or in the country of employment) they wanted to be insured under. Why are we writing about this in such detail? More than three years later, a U-turn is now being made, so to speak, by means of a proposal for a change in the law. Those insured under the Norwegian system are to switch to the German system (again, no information was provided about the consequences) or, alternatively, apply for an exemption to remain in the Norwegian system. Based on our own experiences in 2022, we can very well understand the situation our colleagues are now facing and would therefore like to support them by submitting our own høringssvar . Among other things, we have the following comments/questions: We do not understand why this change in the law is absolutely necessary. What is not ‘working’ with the current practice? What is the basis for the statement that the majority of local staff would like to remain in the social security system of their country of employment? We are not aware of any relevant surveys in the individual Norwegian diplomatic missions. The group of local staff at Norwegian diplomatic missions is very heterogeneous. This is due, on the one hand, to the different social security systems in the countries of employment (there are also differences within the EEA) and, on the other hand, to personal insurance histories. For example, it makes no sense at all for an older employee to suddenly switch from one system to another after many years/decades, regardless of the direction of the change. In addition, some countries of employment have very inadequate social security systems of their own. In such cases, it is downright irresponsible to force an employee to switch to that system. For the reasons mentioned above alone, the argument of ‘equal treatment of all local staff’ is not justifiable. In our opinion, there are procedural/formal errors in the drafting of the høringsnotat . Those affected by the change in the law and their representatives were neither involved at an early stage, nor was there an utredning as a basis for the høringsnotat . To our knowledge, AID and UD spent at least two years, possibly even longer, preparing the høringsnotat . There would therefore have been enough time to involve those affected. Before the høringsnotat was published, one of our colleagues repeatedly requested access to certain topics, which was denied for reasons we cannot understand. We request that the consultation paper be withdrawn in its current form or, if this is not possible, that it be fundamentally revised and resubmitted in consultation with those affected and their representatives that the promised freedom of choice for individual employees between social security in Norway and in the country of employment is included in the new draft that all current compulsory members of the Norwegian social security system can remain compulsory members as long as their employment relationship exists Trygdesaken places a particular burden on our colleagues insured under the Norwegian system and, of course, on all of us. A lot of trust and energy has been (and continues to be!) lost, the atmosphere is tense, and uncertainty, frustration and fears about the future are spreading. We local staff in Berlin support each other, both professionally and personally. We are committed to serving the Norwegian state and ensuring that everything runs smoothly. We want openness, co-determination, long-term security, trust and reliability – the values that Norway represents externally. All local staff at the Royal Norwegian Embassy in Berlin who are insured under the German social security system Arbeids- og inkluderingsdepartementet Til høringen Til toppen <div class="page-survey" data-page-survey="133" data-page-survey-api="/api/survey/SubmitPageSurveyAnswer" data-text-hidden-title="Tilbakemeldingsskjema" data-text-question="Fant du det du lette etter?"
