Security law differs
A floating charge exists in all four countries but covers different assets and ranks differently in bankruptcy. Share pledges are treated differently, and pledges over movables are in practice only relevant in some jurisdictions.
A cross-border facility therefore normally has to be paired with local security documents in each jurisdiction — and a clear intercreditor agreement.
Currency and natural hedge
Companies with revenue in NOK, DKK or EUR are wise to match at least part of their debt to the same currency. This provides a natural hedge that is cheaper than continually buying FX protection.
The role of the Nordic majors
Nordea, SEB, Danske Bank, DNB and OP-Pohjola all have a pan-Nordic presence but different risk appetites in different segments. A structured process that allows offers to be compared across borders normally delivers better terms than relying on a single relationship.
- Security documentation needs to be local — even under a common facility agreement.
- Currency matching creates a natural hedge.
- An intercreditor agreement must be in place before drawdown.
- Benchmark Nordic banks in parallel for the best terms.
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