Letter to the Norwegian Ministry of Trade, Industry and Fisheries regarding the Field Safety Regulations and Guide Certification
Posted: 12 November. 2025
This inquiry concerns the implementation of the Field Safety Regulations, focusing on training requirements and the approval scheme for Svalbard guides, published in June 2025. AECO is concerned about the lack of clarification on key topics, including §11 (guide approval, courses, and learning requirements) and §27 (transitional provisions).
The regulations introduce major changes with significant practical and financial consequences for operators and guides. The requirements for courses and certification are extensive, and the exemption scheme in §27 may affect future competence and capacity.
§11 outlines minimum safety training requirements, with the Governor of Svalbard responsible for defining course and learning standards. These will guide providers in developing commercial or internal training programs. This work is not yet completed, which may cause problems for providers and guides needing to complete training before July 1, 2027. AECO assumes the requirements will reflect input from industry organizations and expert communities and expects the process will not monopolize course offerings or create unfair market advantages. Information is also needed on how to become an approved course provider.
If course and learning requirements are not published and documentation demands are impractical, there is a risk of a guide shortage, which could undermine safety, quality, and tourism capacity in Svalbard. AECO is concerned about the short timeline and asks the Ministry to consider postponing the implementation of all or parts of the regulation.
The transitional period is short. Individuals must document 1,500 guiding hours between January 1, 2024, and January 1, 2027. This documentation process should already be underway, though the industry lacks clarity on how to document it. The basis for the 1,500-hour requirement is unclear and was not part of the consultation process. AECO believes confirmation from employers should suffice and urges that this understanding be confirmed quickly.
AECO’s Recommendations:
- Consider postponing the implementation
- Publish course and learning requirements
- Confirm that working hours count toward the 1,500-hour requirement
- Clarify documentation requirements
- Ensure documentation requirements are simple and practical
AECO requests that the Ministry clarify these matters promptly. AECO is in dialogue with the Governor of Svalbard but is also addressing the Ministry due to the intrusive and unclear nature of the provisions.
AECO is willing to participate in meetings to elaborate and discuss solutions. AECO also seeks clarification on other aspects of the regulation that appear unclear in terms of practical implementation and looks forward to continued constructive dialogue.
This is a translated summary of the letter sent to the Ministry of Trade, Industry and Fisheries.