On 22 September 2026, the US, Denmark and Greenland signed an agreement covering, among other things, foreign investments in Greenland. The agreement has not yet entered into force, but may have implications for future transactions and Greenland’s future screening rules.
Restrictions on investors from countries other than EU and NATO Member States or NATO partners
Article X of the agreement is aimed at states and investors from countries other than EU and NATO Member States or NATO partners. As a general rule, they may not acquire control, significant influence or access to non-public information within "particularly sensitive sectors or activities" in Greenland, if this could pose a threat to national security or public order. Critical infrastructure and resource extraction are among the areas mentioned, but the precise scope has not yet been determined. However, a specific investment may proceed if Greenland, Denmark and the US jointly assess that it does not pose any such threat.
The agreement does thus not introduce a general ban on foreign investments in Greenland. The restriction applies to investors from states other than EU and NATO Member States or NATO partners and to investments in particularly sensitive sectors or activities. Whether a specific investment may proceed also depends on the security assessment made.
The restriction is not linked to a specific ownership share in Greenlandic undertakings or Greenlandic activities. Investments not involving the acquisition of ownership shares may also be comprised if they give the investor control, significant influence or access to non-public information.
Interaction with future Greenlandic FDI regulation
The agreement does not in itself introduce a detailed screening procedure. Instead, it provides for the restrictions to be managed through Greenland’s future investment screening legislation in close cooperation with the Danish authorities. The Danish authorities must also consult the relevant US authorities and other partners. The future legislation will determine whether and when a specific investment must be notified.
Greenland does not yet have an investment screening act. A proposal for an Inatsisartut Act on the screening of certain foreign investments was considered in 2025 but was withdrawn from the 2026 spring session. The proposal, for example, provided for requirements of prior authorisation of investments in particularly sensitive sectors, voluntary notification of other investments and the possibility of investigating certain investments that had not been notified.
The agreement is expected to have an impact on the drafting of the future Greenlandic FDI regulations. However, the scope of future legislation may be broader than the restrictions set out in Article X. For investors, it will be particularly important to monitor which sectors and activities are covered, which investments are subject to screening, and how "control" and "significant influence" are to be assessed.
The first reading of the new draft Inatsisartut Act on the screening of certain foreign investments is scheduled to take place on 10 November 2026.
Are you planning foreign investments?
If you are planning foreign investments in Greenlandic undertakings or activities, you should assess as follows at an early stage of the process:
-
the investor’s country of origin and the ultimate ownership structure,
-
whether the undertaking operates within a particularly sensitive sector or activity, and
-
what control, influence or access to non-public information the transaction affords the investor.
Particularly in the case of complex ownership structures and investments from states other than EU and NATO Member States or NATO partners, this assessment may have implications for the transaction structure, the timetable and any conditions for completion.
Article X does not impose the same specific restrictions on investors from EU and NATO Member States or NATO partners. However, this does not mean that their investments will necessarily be exempt from a future Greenlandic screening scheme. This will depend on the wording of the future legislation.
The agreement has not yet entered into force and is subject to the required parliamentary procedures in Denmark and Greenland.
We are monitoring the legislative process closely. If you are considering investments in Greenland, we will be happy to assist you in assessing the investment environment, activities and potential implications for the structure and timetable of the transaction.
Update
On 13 October, Naalakkersuisut reintroduced the proposed Greenlandic Act on the screening of certain foreign investments. Read more here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
[View Source]
