Begrunnelse (Duty to Give Reasons) for Administrative Decisions

In Norwegian administrative law, reasons are not optional. A decision that affects your rights or obligations (an enkeltvedtak) must normally be accompanied by a written explanation. This is one of the most important safeguards against arbitrary decision-making.

On Do Better Norge, we call this the “show-your-work rule”: the authorities must show what facts they accepted, what legal rules they applied, and how they weighed key considerations—especially in family- and child-related matters.

Legal framework

The main rules are in Forvaltningsloven:

• § 24: when an individual decision must be justified (main rule: it must).
• § 25: what the justification must contain (rules applied, factual basis, and key considerations in discretionary assessments).

What a proper begrunnelse should include

• Legal basis: the relevant statutory provisions (and, where applicable, regulations and binding guidance).
• Facts: what the authority believes happened, based on which documents/observations.
• Assessment: the “bridge” between facts and conclusion—why those facts meet (or do not meet) the legal threshold.
• Key considerations: especially where discretion is used (what mattered most, and why).

Do Better Norge red flags

• Copy-paste text with no case-specific facts.
• “Best interests” mentioned, but not actually analyzed (no balancing, no alternatives considered).
• References to documents you have never seen (often a partsinnsyn issue).
• Conclusory statements (“we find…”) without reasoning.

What you can do if the reasons are missing or weak

1. Request a complete begrunnelse in writing (and ask them to log the request in the case file).
2. Request partsinnsyn if the reasoning relies on unseen documents.
3. Use the weakness in your appeal: inadequate reasoning can be a procedural error and may support reversal or remittal.

Template: Request for full begrunnelse

Subject: Request for full written reasoning – Forvaltningsloven §§ 24–25

To [Agency],
I request a complete written begrunnelse for decision [reference/date]. Please specify (1) the legal provisions applied, (2) the factual basis relied upon (with document references), and (3) the key considerations in the assessment/discretion.
If any documents are referenced that I have not received, please treat this as a partsinnsyn request as well.
Sincerely,
[Name]

Sources and further reading

• Lovdata – Forvaltningsloven § 24 (when reasons are required)
• Lovdata – Forvaltningsloven § 25 (content of the reasoning)
• Sivilombudet – Begrunnelser (practical guidance)
• Statsforvalteren – training material on reasoning requirements (PDF)