Iceland

Country score (EU Average*)

66(72) Political Financing
27(57) Financial Disclosure
23(49) Conflict of Interest
42(59) Freedom of Information
51(63) Public Procurement
73(66) Anti Money Laundering
47(71) Asset Recovery

Country Facts

Income	High
GNI per capita (2011 PPP $)	42253.86
Population, total	334252.00
Urban population (% of total)	94.23
Internet users (per 100 people)	98.24
Life expectancy at birth (years)	82.86
Mean years of schooling (years)	12.2
Global Competitiveness Index	5

Sources: World Bank, UNDP, WEF.

Political Financing

The Act on the Finances of Political Organisations and Candidates (2006, amended 2011) and the Rules on the Financial Accounts of Political Parties 2007 are the main laws regulating the financing of political parties in Iceland.

There are some restrictions on the amount that can be donated to political parties. There are bans on donations from foreign entities, and from corporations with partial government ownership but not from corporations generally. Trade unions are permitted to donate but donations from anonymous donors are banned. There are limits regulating the amount a donor can contribute to political parties and candidates.

Public funding is available for political parties and is allocated based on the share of votes in a previous election, the representation in the elected body and the participation in the election. Funding is available to cover expenses incurred in the general election campaign and for the general activities of political parties. Subsidized media access is available as is tax relief as a form of indirect funding.

The regulations on spending include a ban on vote buying and limits on the amount a candidate can spend in an election. There do not appear to be limits on the amount a political party can spend.

Parties are required to keep accounts which must provide information on finances in relation to election campaigns, the reports must be made public and must in some cases reveal the identity of donors. The accounts are overseen by the National Audit Bureau. There are sanctions for breaches of the provisions in the form of fines, forfeiture and imprisonment.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024
Bans and limits on private income	42	42	42	42	64	69
Public funding	75	75	75	75	75	62
Regulations on spending	100	100	100	100	50	50
Reporting, oversight and sanctions	75	83	83	83	83	83

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Bans and limits on private income
Is there a ban on donations from foreign interests to political parties?	Yes. Contributions may not be accepted from foreign citizens, enterprises or other parties registered in other countries. This prohibition shall not apply, however, to contributions from foreign citizens who have voting rights in Iceland as provided for in the third paragraph of Art. 2 of Act No. 5/1998, on municipal elections. (Art 6, Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Is there a ban on donations from foreign interests to candidates?	Yes. Contributions may not be accepted from foreign citizens, enterprises or other parties registered in other countries. This prohibition shall not apply, however, to contributions from foreign citizens who have voting rights in Iceland as provided for in the third paragraph of Art. 2 of Act No. 5/1998, on municipal elections. (Art 6 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011 )
Is there a ban on corporate donations to political parties?	No. Absent from legal framework
Is there a ban on corporate donations to candidates?	No . Absent from legal framework
Is there a ban on donations from corporations with government contracts to political parties?	Yes. Contributions from enterprises in which a majority is owned, or which is controlled by, the state or municipalities may not be accepted. Contributions may not be accepted from public bodies not included under the provisions of Chapter II (Art 6 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011 )
Is there a ban on donations from corporations of partial government ownership to political parties?	Yes. Contributions from enterprises in which a majority is owned, or which is controlled by, the state or municipalities may not be accepted. (Art 6 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011 )
Is there a ban on donations from corporations with government contracts to candidates?	Yes. Contributions from enterprises in which a majority is owned, or which is controlled by, the state or municipalities may not be accepted. Contributions may not be accepted from public bodies not included under the provisions of Chapter II (Art 6 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011 )
Is there a ban on donations from corporations of partial government ownership to candidates?	Yes. Contributions from enterprises in which a majority is owned, or which is controlled by, the state or municipalities may not be accepted. (Art 6 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011 )
Is there a ban on donations from Trade Unions to political parties?	No. Absent from legal framework
Is there a ban on donations from Trade Unions to candidates?	No. Absent from legal framework
Is there a ban on anonymous donations to political parties?	Yes. Contributions from anonymous donors may not be accepted. [If a political organisation or candidate receive contributions from an unknown donor, the contribution shall be delivered to the Treasury if there was no opportunity to refuse its acceptance. (Art 6 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011 )
Is there a ban on anonymous donations to candidates?	Yes. Contributions from anonymous donors may not be accepted. [If a political organisation or candidate receive contributions from an unknown donor, the contribution shall be delivered to the Treasury if there was no opportunity to refuse its acceptance. (Art 6 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011 )
Is there a ban on state resources being given to or received by political parties or candidates (excluding regulated public funding)?	Yes. Contributions may not be accepted from public bodies not included under the provisions of Chapter II (Art 6 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011 )
Is there a ban on any other form of donation?	No. Absent from legal framework
Is there a limit on the amount a donor can contribute to a political party over a time period (not election specific)?	Yes. Political organisations and candidates may not accept contributions from legal entities exceeding ISK [400,000] per year. (Art 7 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Is there a limit on the amount a donor can contribute to a political party in relation to an election?	Yes. Art 6 Political organisations and candidates may accept contributions for their activities or an election campaign with the restrictions which result from the second to fifth paragraphs of this Article and the provisions of Article 7. Art 7 places an annual restriction of 400,000 so it appears that applies to elections as well. (Art 6 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011 )
Is there a limit on the amount a donor can contribute to a candidate?	Yes. Political organisations and candidates may not accept contributions from legal entities exceeding ISK [400,000] per year. (Art 7 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Public funding
Eligibility criteria for direct public funding to political parties	Yes. See sub-indicators
Eligibility criteria for direct public funding to political parties: Share of votes in previous election	Yes. Each year allocations shall be made from the Treasury for the activities of political organisations who have had at least one person elected to the Althingi or who have received at least 2.5% of votes in the most recent elections to the Althingi, in accordance with a budget decision in each instance. (Art 3 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Eligibility criteria for direct public funding to political parties: Representation in elected body	Yes. Each year allocations shall be made from the Treasury for the activities of political organisations who have had at least one person elected to the Althingi or who have received at least 2.5% of votes in the most recent elections to the Althingi, in accordance with a budget decision in each instance. (Art 3 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Eligibility criteria for direct public funding to political parties: Participation in election	Yes. Political organisations who field candidates in all constituencies in elections to the Althingi may, upon the conclusion of the elections, apply for a special financial grant from the Treasury to cover expenses incurred in their election campaign, of a maximum of ISK 3 million. (Art 3 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Eligibility criteria for direct public funding to political parties: Number of candidates	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of seats in previous election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of votes in next election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Registration as a political party	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Share of seats in next election	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Number of members	No. Absent from legal framework
Eligibility criteria for direct public funding to political parties: Other	No. Absent from legal framework
Allocation calculations for direct public funding to political parties	Yes. See sub-indicators
Allocation calculations for direct public funding to political parties: Proportional to votes received	Yes. The amount shall be allocated in proportion to the number of votes. (Art 3 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Allocation calculations for direct public funding to political parties: Equal	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Proportional to seats received	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Flat rate by votes received	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Share of expenses reimbursed	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Proportional to candidates fielded	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Number of members	No. Absent from legal framework
Allocation calculations for direct public funding to political parties: Other	No. Absent from legal framework
Earmarking provisions for direct public funding to political parties	Yes. See sub-indicators
Earmarking provisions for direct public funding to political parties: Campaign spending	Yes. Political organisations who field candidates in all constituencies in elections to the Althingi may, upon the conclusion of the elections, apply for a special financial grant from the Treasury to cover expenses incurred in their election campaign, of a maximum of ISK 3 million. (Art 3 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Earmarking provisions for direct public funding to political parties: Ongoing party activities	Yes. Each year allocations shall be made from the Treasury for the activities of political organisations (Art 3 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Earmarking provisions for direct public funding to political parties: Intra-party institution	No. Absent from legal framework
Earmarking provisions for direct public funding to political parties: Other	No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties	Yes. See sub-indicators
Allocation criteria for free or subsidized access to media for political parties: Equal	Yes. "Some form of indirect funding of election campaigns is provided through free broadcasting time on the State-‌owned television channel at the time of election campaigns.‌ There are no specific provisions on media space, but, according to the Law No.‌ 53/‌2000 (Art.9) on Broadcasting, all radio and television stations are bound by the basic rules of democracy and freedom of expression.‌ On this basis, parties are treated equally when allocating air time.‌" (GRECO (2008) Evaluation Report on Iceland, Transparency of Party Funding (Theme II))
Allocation criteria for free or subsidized access to media for political parties: Number of candidates	No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Share of seats	No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Share of votes in preceding election	No. Absent from legal framework
Allocation criteria for free or subsidized access to media for political parties: Other	No. Absent from legal framework
Are there provisions for free or subsidized access to media for candidates?	No. Absent from legal framework
Are there provisions for any other form of indirect public funding?	Yes. See sub-indicators
Provisions for any other form of indirect public funding: Premises for campaign meetings	No. Absent from legal framework
Provisions for any other form of indirect public funding: Space for campaign materials	No. Absent from legal framework
Provisions for any other form of indirect public funding: Tax relief	Yes. Individual gifts and donations to churches, acknowledged charities, fields of culture, political parties and scientific research, though not above 0,75% of income in acc. with section B of Article 7 in the year of giving. The Minister of Finance decides via regulation which areas and institutions are governed by this point. (Article 31(2), Law No.‌ 90/‌2003 on Income Tax, amended 2016)
Provisions for any other form of indirect public funding: Free or subsidised transport	No. Absent from legal framework
Provisions for any other form of indirect public funding: Free or subsidised postage cost	No. Absent from legal framework
Provisions for any other form of indirect public funding: Other	No. Absent from legal framework
Is the provision of direct public funding to political parties related to gender equality among candidates?	No. Absent from legal framework
Are there provisions for other financial advantages to encourage gender equality in political parties?	No. Absent from legal framework
Regulations on spending
Is there a ban on vote buying?	Yes. Banned election propaganda and election sabotage" include:] "To offer anyone money or advantages in order to have an effect on whether they cast a vote or for whom they cast a vote, to deprive a person or to threaten a person with the deprivation of his or her job or advantages for the same purpose, to promise money or advantages to a person if an election turns out this way or that way, to make it difficult for others to go to a polling session or to a pre-‌election polling station, as well as to apply coercive measures in connection with elections.‌ Pays, promises to pay or offers to pay someone money or some other gain with a view to having them vote in a particular way, or not vote (...) shall be subjected up to 2 years’ imprisonment, or to a fine if the offence is minor. (Act on Parlimentary Elections to the Althing, No. 24/2000, Art. 117 Penal Code, Art. 103(4), amended 2015)
Are there bans on state resources being used in favour or against a political party or candidate?	No. Absent from legal framework
Are there limits on the amount a political party can spend?	No. Absent from legal framework
Are there limits on the amount a candidate can spend?	Yes. Candidates' total expenses [in an election campaign for national or municipal elections] 1) may not exceed ISK 1 million, plus a premium as follows: In an electoral district with over 50,000 residents 18 years of age and older, ISK 75 per person. In an electoral district with 40,000-49,999 residents 18 years of age and older, ISK 100 per person. In an electoral district with 20,000-39,999 residents 18 years of age and older, ISK 125 per English translation person. In an electoral district with 10,000-19,999 residents 18 years of age and older, ISK 150 per person. In an electoral district with fewer than 10,000 residents 18 years of age and older, ISK 175 per person. (Art 7 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Reporting, oversight and sanctions
Do political parties have to report regularly on their finances?	Yes. Political organisations must keep consolidated accounts for all units they are comprised of, such as subsidiary associations, constituency boards, holding companies and related self-governing institutions. (Art 8 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Do political parties have to report on their finances in relation to election campaigns?	Yes. "Political parties shall report all their income and expenses in their income statements, except as other provided by law or statutory accounting standards." [Candidates must prepare financial results of their election campaigns, listing all contributions and expenses in connection with it in accordance with general accounting rules ( Art. 15 Rules on the Financial Accounts of Political Parties, 2007 Art 10 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Do candidates have to report on their campaign finances?	Yes. [Candidates must prepare financial results of their election campaigns, listing all contributions and expenses in connection with it in accordance with general accounting rules (Art 10 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Is information in reports from political parties and/or candidates to be made public?	Yes. The National Audit Bureau shall, as soon as possible thereafter, publish an excerpt from the statements in a co-ordinated manner. (Art 11 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Must reports from political parties and/or candidates reveal the identity of donors?	Yes. The names of all legal entities providing contributions to the candidate's election campaign and the respective amounts shall be published. In addition, the names of all individuals providing contributions valued at over ISK 200,000 to the candidate's election campaign shall be published. (Art 11 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Institutions receiving financial reports from political parties and/or candidates
Institutions receiving financial reports from political parties and/or candidates: Electoral Management Board	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Auditing agency	Yes. Political organisations must, prior to 1 October each year, send the National Audit Bureau their accounts from the previous year, cf. Art. 8, endorsed by auditors. (Art 9 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Institutions receiving financial reports from political parties and/or candidates: Ministry	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Special institution	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Court	No. Absent from legal framework
Institutions receiving financial reports from political parties and/or candidates: Other	No. Absent from legal framework
Is it specified that a particular institution(s) is responsible for examining financial reports and/or investigating violations?
Institution responsible for examining financial reports and/or investigating violations: Court	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Ministry	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Auditing agency	Yes. The National Audit Bureau may, at any time, request all documentation to verify that the expenses of the election campaign and contributions from individuals and legal entities to the candidate are within the limits set in Chapter III. (Art 10 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Institution responsible for examining financial reports and/or investigating violations: Electoral Management Body	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Institution for this purpose	No. Absent from legal framework
Institution responsible for examining financial reports and/or investigating violations: Other	No. Absent from legal framework
Other institutions with a formal role in political finance oversight
Institutions with a formal role in political finance oversight: Court	No. Absent from legal framework
Institutions with a formal role in political finance oversight: Ministry	No. Absent from legal framework
Institutions with a formal role in political finance oversight: Auditing agency	No. Absent from legal framework
Institutions with a formal role in political finance oversight: EMB	No. Absent from legal framework
Institutions with a formal role in political finance oversight: Institution for this purpose	No. Absent from legal framework
Institutions with a formal role in political finance oversight: Other	No. Absent from legal framework
Sanctions for political finance infractions
Sanctions for political finance infractions: Fines	Yes. Anyone receiving contributions, or their equivalent, which may not be accepted according to Art. 6, or higher contributions than provided for in Art. 7, shall be subject to fines or imprisonment of up to two years. (Art 6 and 7 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Sanctions for political finance infractions: Loss of public funding	No. Absent from legal framework
Sanctions for political finance infractions: Penal/Criminal	Yes. Anyone receiving contributions, or their equivalent, which may not be accepted according to Art. 6, or higher contributions than provided for in Art. 7, shall be subject to fines or imprisonment of up to two years. (Art 6 and 7 Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011)
Sanctions for political finance infractions: Forfeiture	Yes. Unauthorised contributions accepted or contributions accepted in excess of limits provided for in this Act may be confiscated by the Treasury, as stated in Chapter VII A of the Criminal Code. (Penal Code, Chapter VII A, amended 2015)
Sanctions for political finance infractions: Deregistration of party	No. Absent from legal framework
Sanctions for political finance infractions: Loss of elected office	No. Absent from legal framework
Sanctions for political finance infractions: Suspension of political party	No. Absent from legal framework
Sanctions for political finance infractions: Loss of nomination of candidate	No. Absent from legal framework
Sanctions for political finance infractions: Loss of political rights	No. Absent from legal framework
Sanctions for political finance infractions: Other	No. Absent from legal framework

Legislation

Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011 (English)	pdf
Law No.‌ 90/‌2003 on Income Tax, amended 2016 (Icelandic)	pdf
Act on Parlimentary Elections to the Althing, No. 24/2000 (English)	pdf
Penal Code, 1940, amended 2015 (English)	pdf
Rules on the Financial Accounts of Political Parties, 2007 (English)	pdf

*Last update: 2017

Financial Disclosure

Iceland’s financial disclosure legislation does not apply to the Head of State or to Civil Servants. According to the Ministerial Code of Conduct (2011), Ministers must declare gifts and information on any financial or private interests they have which may lead to a conflict of interests. The Disclosure Regulations for Members of Parliament and Senior Positions outside Parliament (2011) makes more specific requirements for MPs to declare real estate that is not for personal use, cash, debt, income from outside employment, and private or public firm ownership. While Ministers make their declaration only upon taking office, Members of Parliament are obliged to an annual declaration. No declarations include family members.

However, no sanctions are specified for the failure to make declarations or for making false statements. The Althing Secretariat and the Parliamentary Office receive declarations made by Ministers and MPs respectively. The Coordinating Committee for Public Administration Ethics functions as an enforcement body only for Ministers. Meanwhile, Members of Parliament do not fall under the control of an enforcement body. However, the declarations made by Members of Parliament are publicly available on the website of parliament.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Disclosure items	79	80	80	81	83	21
Filing frequency	94	94	94	75	75	38
Sanctions	100	100	100	100	100	0
Monitoring and Oversight	50	50	50	56	50	38
Public access to declarations	50	50	50	38	12	38
Alternative Metric	2012	2015	2016	2017	2020	2024	Trend
Head of State	76	76	76	71	61	0
Ministers	76	76	76	71	61	53
Members of Parliament	76	77	77	72	73	53
Civil servants	71	71	71	66	61	0

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Head of State
Disclosure items
Spouses and children included in disclosure	No. Absent from legal framework.
Income and Assets
Real estate	No. Absent from legal framework.
Movable assets	No. Absent from legal framework.
Cash	No. Absent from legal framework.
Loans and Debts	No. Absent from legal framework.
Income from outside employment/assets	No. Absent from legal framework.
Incompatibilities
Gifts received as a public official	No. Absent from legal framework.
Private firm ownership and/or stock holdings	No. Absent from legal framework.
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	No. Absent from legal framework.
Board member, advisor, or company officer of private firm	No. Absent from legal framework.
Post-employment	No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework.
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	No. Absent from legal framework.
Filing required upon leaving office	No. Absent from legal framework.
Filing required annually	No. Absent from legal framework.
Ad hoc filing required upon change in assets or conflicts of interest	No. Absent from legal framework.
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	No. Absent from legal framework.
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	No. Absent from legal framework.
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	No. Absent from legal framework.
Monitoring and Oversight
Depository body explicitly identified	No. Absent from legal framework.
Enforcement body explicitly identified	No. Absent from legal framework.
Some agency assigned responsibility for verifying submission	No. Absent from legal framework.
Some agency assigned responsibility for verifying accuracy	No. Absent from legal framework.
Public access to declarations
Public availability	No. Absent from legal framework.
Timing of information release specified	No. Absent from legal framework.
Location(s) of access specified	No. Absent from legal framework.
Cost of access specified	No. Absent from legal framework.
Ministers
Disclosure items
Spouses and children included in disclosure	No. Absent from legal framework.
Income and Assets
Real estate	Yes. Any property which is one third or more in the ownership of a Member or a company in which the Member holds a quarter share or more. Residential premises or summer homes for the private use of the Member or the Member's family and land rights relating to such properties shall not be disclosed. The name of the land holding and location of the property shall be disclosed. Applicable through MPs’ disclosure obligations under the Rules on disclosure of financial interests of Members of Parliament (2019), as ministers are typically members of the Althingi. No separate legal regime exists for ministers (Article 4.3 (a) of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Movable assets	No. Absent from legal framework.
Cash	Yes. Contribution or other financial support from domestic and foreign legal entities and individuals, including support in the form of a secretariat or similar services, which falls outside the support of the parliament or party MP provider, and value the support of more than 50 thousand. kr. year. Furthermore, registered financial support in the form of a discount on the market and other forms of preferential value of more than 50 thousand. kr. which is expected to be given to member of parliament. Applicable through MPs’ disclosure obligations under the Rules on disclosure of financial interests of Members of Parliament (2019), as ministers are typically members of the Althingi. No separate legal regime exists for ministers (Article 4.2 (a) of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Loans and Debts	Yes. Debts shall be disclosed, together with personal and other guarantees which relate to the administration of real property or the commercial operations of companies, savings banks or private foundations. Debts and guarantees exceeding parliamentary salaries shall be disclosed. The amount of a debt or debts or guarantees undertaken for other purposes, such as the purchase of residential property for private use, a vehicle for private use, loans for educational purpose, or other purposes not relating to commercial operations shall not be disclosed. The type of debt or guarantee shall be disclosed together with the identity of the creditor. Applicable through MPs’ disclosure obligations under the Rules on disclosure of financial interests of Members of Parliament (2019), as ministers are typically members of the Althingi. No separate legal regime exists for ministers (Article 4.4 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Income from outside employment/assets	Yes. Paid work and income-generating activities shall be included in teh delcaration. In particular: a. Paid service on the boards of directors of private or public companies. The position and name of company shall be disclosed; b. Paid work or assignments (other than salaried parliamentary work). The title of the position and identity of the employer shall be disclosed; c. Business that is conducted concurrently with parliamentary work and generates income for the Member or a company that the Member owns or of which the Member is a partial owner. The type of business in question shall be disclosed. Applicable through MPs’ disclosure obligations under the Rules on disclosure of financial interests of Members of Parliament (2019), as ministers are typically members of the Althingi. No separate legal regime exists for ministers (Article 4.1 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Incompatibilities
Gifts received as a public official	Yes. Any gift from Icelandic and foreign legal entities and private persons when the value of the gift is estimated at over 50,000 ISK and the gift is given by reason of membership of the Althingi. The name of the giver, the occasion of the gift, its nature and time of giving shall be disclosed. Applicable through MPs’ disclosure obligations under the Rules on disclosure of financial interests of Members of Parliament (2019), as ministers are typically members of the Althingi. No separate legal regime exists for ministers (Article 4.2 (b) of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Private firm ownership and/or stock holdings	Yes. The name of any company (e.g. private limited company, partnership, limited partnership or co-operative) or savings bank in which the Member holds an interest exceeding any of the following criteria: 1. The market value of the interest exceeds 1,000,000 ISK as at 31 December each year; 2. The interest is 1% or more in a company, savings bank or foundation where assets at year-end amount to 230,000,000 ISK or more, or the operating income is 460,000,000 ISK or more; 3. The interest amounts to 25% or more in the share capital or initial capital of a company, savings bank or foundation. Applicable through MPs’ disclosure obligations under the Rules on disclosure of financial interests of Members of Parliament (2019), as ministers are typically members of the Althingi. No separate legal regime exists for ministers (Article 4.3 (b) of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Ownership of state-owned enterprises (SOEs)	Yes. The name of any company (e.g. private limited company, partnership, limited partnership or co-operative) or savings bank in which the Member holds an interest exceeding any of the following criteria: 1. The market value of the interest exceeds 1,000,000 ISK as at 31 December each year; 2. The interest is 1% or more in a company, savings bank or foundation where assets at year-end amount to 230,000,000 ISK or more, or the operating income is 460,000,000 ISK or more; 3. The interest amounts to 25% or more in the share capital or initial capital of a company, savings bank or foundation. Applicable through MPs’ disclosure obligations under the Rules on disclosure of financial interests of Members of Parliament (2019), as ministers are typically members of the Althingi. No separate legal regime exists for ministers (Article 4.3 (b) of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Holding government contracts	No. Absent from legal framework.
Board member, advisor, or company officer of private firm	Yes. Information on service on boards of directors and other positions of trust on behalf of interest groups, public organisations, municipalities and associations other than political parties shall be disclosed, regardless of whether such work is remunerated or not. The name of the association, interest group organisation or municipality and the nature of the position of trust shall be disclosed. (Article 5 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Post-employment	No. The amounts or value of the agreements with the future employer, regardless if the appointment takes effect after the MP leaves parliament are not to be declared. (Article 4.5 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework.
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	Yes. Within one month from the time that a newly elected parliament convenes, Members of the Althingi shall provide a public account of their financial interests and positions of trust outside the Althingi. (Article 2 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Filing required upon leaving office	No. Absent from legal framework.
Filing required annually	Yes. The name of any company (e.g. private limited company, partnership, limited partnership or co-operative) or savings bank in which the Member holds an interest exceeding any of the following criteria: 1. The market value of the interest exceeds 1,000,000 ISK as at 31 December each year; 2. The interest is 1% or more in a company, savings bank or foundation where assets at year-end amount to 230,000,000 ISK or more, or the operating income is 460,000,000 ISK or more; 3. The interest amounts to 25% or more in the share capital or initial capital of a company, savings bank or foundation. Annual updates required as part of the obligation to keep disclosures current. Members must update information within one month of changes (Article 4.3 (b) + article 2 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Members of the Althingi shall maintain their records up to date by disclosing new information and additional information within one month from the time that such information becomes available. (Article 2 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	No. Absent from legal framework. No explicit administrative or criminal sanctions; however, non-compliance is handled through notification and review by the Speakers’ Committee under the Code of Conduct (Article 16 and 18 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	No. Absent from legal framework. No explicit administrative or criminal sanctions; however, non-compliance is handled through notification and review by the Speakers’ Committee under the Code of Conduct (Article 16 and 18 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	No. Absent from legal framework. No explicit administrative or criminal sanctions; however, non-compliance is handled through notification and review by the Speakers’ Committee under the Code of Conduct (Article 16 and 18 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Monitoring and Oversight
Depository body explicitly identified	Yes. The Althingi Administration (Article 3 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Enforcement body explicitly identified	Yes. Members are alone responsible for the disclosure of their financial interests and positions of trust outside the Althingi. If the Althingi Administration receives notice that a Member has neglected to disclose his or her interests or maintain the disclosure up to date, the Administration shall notify the Member. In the resolution of matters received by the Speakers' Committee regarding the failure of a Member to disclose his or her interests in accordance with these Rules, the Committee shall act in accordance with the instructions in Articles 16–18 of the Code of Conduct for Members of the Althingi. (Article 8 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Some agency assigned responsibility for verifying submission	Yes. The Speakers' Committee shall appoint an advisory committee of three members for a term of five years to address communications sent by the Speakers' Committee concerning alleged violations of this Code. The Committee will express an opinion of whether a Member has, through his or her conduct, violated his or her principles of behaviour pursuant to Article 5 (among which discloure obligations) (Artcile 16 of Code of Conduct for Members of the Althingi (26th March 2016, amended on 5th June 2018))
Some agency assigned responsibility for verifying accuracy	No. The Speakers' Committee shall appoint an advisory committee of three members for a term of five years to address communications sent by the Speakers' Committee concerning alleged violations of this Code. The Committee will express an opinion of whether a Member has, through his or her conduct, violated his or her principles of behaviour pursuant to Article 5 (among which discloure obligations) (Artcile 16 of Code of Conduct for Members of the Althingi (26th March 2016, amended on 5th June 2018))
Public access to declarations
Public availability	Yes. New or changed information shall be accessible on the Althingi website within 10 days from the time that the Member notifies its registration. The information referred to in Item 2 of Article 4 may be deleted when four years have passed from their original registration. The records following an election to the Althingi shall be accessible to the public on the website of the Althingi within 20 working days from the expiry of the deadline for registration. (Article 6 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Timing of information release specified	Yes. New or changed information shall be accessible on the Althingi website within 10 days from the time that the Member notifies its registration. The information referred to in Item 2 of Article 4 may be deleted when four years have passed from their original registration. The records following an election to the Althingi shall be accessible to the public on the website of the Althingi within 20 working days from the expiry of the deadline for registration. (Article 6 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Location(s) of access specified	Yes. Website of Althigi (Article 6 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Cost of access specified	No. Absent from legal framework.
Members of Parliament
Disclosure items
Spouses and children included in disclosure	No. Absent from legal framework.
Income and Assets
Real estate	Yes. Any property which is one third or more in the ownership of a Member or a company in which the Member holds a quarter share or more. Residential premises or summer homes for the private use of the Member or the Member's family and land rights relating to such properties shall not be disclosed. The name of the land holding and location of the property shall be disclosed. (Article 4.3 (a) of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Movable assets	No. Absent from legal framework.
Cash	Yes. Contribution or other financial support from domestic and foreign legal entities and individuals, including support in the form of a secretariat or similar services, which falls outside the support of the parliament or party MP provider, and value the support of more than 50 thousand. kr. year. Furthermore, registered financial support in the form of a discount on the market and other forms of preferential value of more than 50 thousand. kr. which is expected to be given to member of parliament. (Article 4.2 (a) of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Loans and Debts	Yes. Debts shall be disclosed, together with personal and other guarantees which relate to the administration of real property or the commercial operations of companies, savings banks or private foundations. Debts and guarantees exceeding parliamentary salaries shall be disclosed. The amount of a debt or debts or guarantees undertaken for other purposes, such as the purchase of residential property for private use, a vehicle for private use, loans for educational purpose, or other purposes not relating to commercial operations shall not be disclosed. The type of debt or guarantee shall be disclosed together with the identity of the creditor. (Article 4.4 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Income from outside employment/assets	Yes. Paid work and income-generating activities shall be included in teh delcaration. In particular: a. Paid service on the boards of directors of private or public companies. The position and name of company shall be disclosed; b. Paid work or assignments (other than salaried parliamentary work). The title of the position and identity of the employer shall be disclosed; c. Business that is conducted concurrently with parliamentary work and generates income for the Member or a company that the Member owns or of which the Member is a partial owner. The type of business in question shall be disclosed. (Article 4.1 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Incompatibilities
Gifts received as a public official	Yes. Any gift from Icelandic and foreign legal entities and private persons when the value of the gift is estimated at over 50,000 ISK and the gift is given by reason of membership of the Althingi. The name of the giver, the occasion of the gift, its nature and time of giving shall be disclosed. (Article 4.2 (b) of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Private firm ownership and/or stock holdings	Yes. The name of any company (e.g. private limited company, partnership, limited partnership or co-operative) or savings bank in which the Member holds an interest exceeding any of the following criteria: 1. The market value of the interest exceeds 1,000,000 ISK as at 31 December each year; 2. The interest is 1% or more in a company, savings bank or foundation where assets at year-end amount to 230,000,000 ISK or more, or the operating income is 460,000,000 ISK or more; 3. The interest amounts to 25% or more in the share capital or initial capital of a company, savings bank or foundation. (Article 4.3 (b) of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Ownership of state-owned enterprises (SOEs)	Yes. The name of any company (e.g. private limited company, partnership, limited partnership or co-operative) or savings bank in which the Member holds an interest exceeding any of the following criteria: 1. The market value of the interest exceeds 1,000,000 ISK as at 31 December each year; 2. The interest is 1% or more in a company, savings bank or foundation where assets at year-end amount to 230,000,000 ISK or more, or the operating income is 460,000,000 ISK or more; 3. The interest amounts to 25% or more in the share capital or initial capital of a company, savings bank or foundation. (Article 4.3 (b) of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Holding government contracts	No. Absent from legal framework.
Board member, advisor, or company officer of private firm	Yes. Information on service on boards of directors and other positions of trust on behalf of interest groups, public organisations, municipalities and associations other than political parties shall be disclosed, regardless of whether such work is remunerated or not. The name of the association, interest group organisation or municipality and the nature of the position of trust shall be disclosed. (Article 5 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Post-employment	No. The amounts or value of the agreements with the future employer, regardless if the appointment takes effect after the MP leaves parliament are not to be declared. (Article 4.5 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework.
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	Yes. Within one month from the time that a newly elected parliament convenes, Members of the Althingi shall provide a public account of their financial interests and positions of trust outside the Althingi. (Article 2 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Filing required upon leaving office	No. Absent from legal framework.
Filing required annually	Yes. The name of any company (e.g. private limited company, partnership, limited partnership or co-operative) or savings bank in which the Member holds an interest exceeding any of the following criteria: 1. The market value of the interest exceeds 1,000,000 ISK as at 31 December each year; 2. The interest is 1% or more in a company, savings bank or foundation where assets at year-end amount to 230,000,000 ISK or more, or the operating income is 460,000,000 ISK or more; 3. The interest amounts to 25% or more in the share capital or initial capital of a company, savings bank or foundation. (Article 4.3 (b) of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Ad hoc filing required upon change in assets or conflicts of interest	Yes. Members of the Althingi shall maintain their records up to date by disclosing new information and additional information within one month from the time that such information becomes available. (Article 2 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	No. Absent from legal framework.
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	No. Absent from legal framework.
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	No. Absent from legal framework.
Monitoring and Oversight
Depository body explicitly identified	Yes. The Althingi Administration (Article 3 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Enforcement body explicitly identified	Yes. Members are alone responsible for the disclosure of their financial interests and positions of trust outside the Althingi. If the Althingi Administration receives notice that a Member has neglected to disclose his or her interests or maintain the disclosure up to date, the Administration shall notify the Member. In the resolution of matters received by the Speakers' Committee regarding the failure of a Member to disclose his or her interests in accordance with these Rules, the Committee shall act in accordance with the instructions in Articles 16–18 of the Code of Conduct for Members of the Althingi. (Article 8 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Some agency assigned responsibility for verifying submission	Yes. The Speakers' Committee shall appoint an advisory committee of three members for a term of five years to address communications sent by the Speakers' Committee concerning alleged violations of this Code. The Committee will express an opinion of whether a Member has, through his or her conduct, violated his or her principles of behaviour pursuant to Article 5 (among which discloure obligations) (Artcile 16 of Code of Conduct for Members of the Althingi (26th March 2016, amended on 5th June 2018))
Some agency assigned responsibility for verifying accuracy	No. The Speakers' Committee shall appoint an advisory committee of three members for a term of five years to address communications sent by the Speakers' Committee concerning alleged violations of this Code. The Committee will express an opinion of whether a Member has, through his or her conduct, violated his or her principles of behaviour pursuant to Article 5 (among which discloure obligations) (Artcile 16 of Code of Conduct for Members of the Althingi (26th March 2016, amended on 5th June 2018))
Public access to declarations
Public availability	Yes. New or changed information shall be accessible on the Althingi website within 10 days from the time that the Member notifies its registration. The information referred to in Item 2 of Article 4 may be deleted when four years have passed from their original registration. The records following an election to the Althingi shall be accessible to the public on the website of the Althingi within 20 working days from the expiry of the deadline for registration. (Article 6 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Timing of information release specified	Yes. New or changed information shall be accessible on the Althingi website within 10 days from the time that the Member notifies its registration. The information referred to in Item 2 of Article 4 may be deleted when four years have passed from their original registration. The records following an election to the Althingi shall be accessible to the public on the website of the Althingi within 20 working days from the expiry of the deadline for registration. (Article 6 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Location(s) of access specified	Yes. Website of Althigi (Article 6 of Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (2019))
Cost of access specified	No. Absent from legal framework.
Civil servants
Disclosure items
Spouses and children included in disclosure	No. Absent from legal framework.
Income and Assets
Real estate	No. Absent from legal framework.
Movable assets	No. Absent from legal framework.
Cash	No. Absent from legal framework.
Loans and Debts	No. Absent from legal framework.
Income from outside employment/assets	No. Absent from legal framework.
Incompatibilities
Gifts received as a public official	No. Absent from legal framework.
Private firm ownership and/or stock holdings	No. Absent from legal framework.
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	No. Absent from legal framework.
Board member, advisor, or company officer of private firm	No. Absent from legal framework.
Post-employment	No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework.
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Concurrent employment of family members in public sector	No. Absent from legal framework.
Filing frequency
Filing required upon taking office	No. Absent from legal framework.
Filing required upon leaving office	No. Absent from legal framework.
Filing required annually	No. Absent from legal framework.
Ad hoc filing required upon change in assets or conflicts of interest	No. Absent from legal framework.
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	No. Absent from legal framework.
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	No. Absent from legal framework.
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	No. Absent from legal framework.
Monitoring and Oversight
Depository body explicitly identified	No. Absent from legal framework.
Enforcement body explicitly identified	No. Absent from legal framework.
Some agency assigned responsibility for verifying submission	No. Absent from legal framework.
Some agency assigned responsibility for verifying accuracy	No. Absent from legal framework.
Public access to declarations
Public availability	No. Absent from legal framework.
Timing of information release specified	No. Absent from legal framework.
Location(s) of access specified	No. Absent from legal framework.
Cost of access specified	No. Absent from legal framework.

Legislation

Rules on the disclosure of financial interests of Members of Parliament of 2019_ICE (Icelandic)	pdf
Code of Conduct for Members of the Althingi of 2016_ICE (Icelandic)	pdf

*Last update: 2017

Conflict of Interest

As financial disclosure legislation on MPs is more extensive, no laws apply to them in the area of conflicts of interests. However, some restrictions are in place for other public officials. The Constitution (1944, last amended 2013) prevents the President from pursuing any paid employment in the interest of a public institution or private enterprise. The Ministerial Code of Conduct (2011) includes a general guideline for Ministers to avoid that conflicts of interests affect their work. Ministers may not pursue additional employment, including advisory positions, during their tenure. Civil Servants face no general restrictions on conflicts of interests. According to the Code of Conduct for Staff in the Government Offices (2012) they may not accept valuable gifts and must ensure that no family or friendly relation affects their work. The Government Office staff is also charged with preventing family relations from making an impact.

However, no sanctions are specified for behavior that would violate conflicts of interests. Only the Ministerial Code of Conduct makes a reference to monitoring and enforcement. While the Althing Secretariat and Prime Minister decide which data must be submitted by Ministers and provide guidance, the Coordinating Committee for Public Administration Ethic is responsible for reacting to infringements of the Ministerial Code of Conduct. No such bodies are specified for any other public officials.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Restrictions	35	35	35	35	42	45
Sanctions	25	25	25	25	33	0
Monitoring and Oversight	25	25	25	25	38	25
Alternative Metric	2012	2015	2016	2017	2020	2024	Trend
Head of State	31	31	31	31	28	7
Ministers	0	0	0	0	11	20
Members of Parliament	34	34	34	34	58	57
Civil servants	48	48	48	48	54	10

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Head of State
Restrictions
General restriction on conflict of interest	No. Absent from legal framework.
Accepting gifts	No. Absent from legal framework.
Private firm ownership and/or stock holdings	No. Absent from legal framework.
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	No. Absent from legal framework.
Board member, advisor, or company officer of private firm	Yes. The President of the Republic may not accept paid employment in the interest of any public institution or private enterprise. (Constitution of the Republic of Iceland of 1944 (as of 2020), Art. 9)
Post-employment	No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position	Yes. The President of the Republic may not be a Member of the Althingi (Parliament). (Constitution of the Republic of Iceland of 1944 (as of 2020), Art. 9)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework.
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. The President of the Republic may not be held accountable for executive acts. The same applies to those who exercise presidential authority. The President may not be prosecuted on a criminal charge except with the consent of Althingi. (Constitution of the Republic of Iceland of 1944 (as of 2020), Art. 11)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework.
Enforcement body specified (sanctions, hearings)	No. Absent from legal framework.
Ministers
Restrictions
General restriction on conflict of interest	Yes. Ministers shall avoid any conflict of interests and not allow personal connections to affect their work and they must provide information on any shared financial interests or similar connections which might lead to a conflict of interests. (Act on the Government Offices of Iceland of 2011, as amended in 2020, Art. 24 Minister's Code of Conduct No. 190 of 2017 (as of 2020), Art. 2)
Accepting gifts	Yes. The gifts which ministers accept by virtue of their office shall be recorded and shall accrue to the ministry concerned. However, this does not apply to personal gifts of a minor nature. (Act on the Government Offices of Iceland of 2011, as amended in 2020, Art. 24 Minister's Code of Conduct No. 190 of 2017 (as of 2020), Art. 3 (2))
Private firm ownership and/or stock holdings	No. Absent from legal framework.
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	No. Absent from legal framework.
Board member, advisor, or company officer of private firm	Yes. A minister's work (generally in addition to being a member of the Althing) is considered a full-time position. Ministers are not to be engaged in any other work during this period. If the Minister performs other incidental tasks, he may not receive payments for them unless they are within reasonable limits and with the approval of the Prime Minister's Office. (Act on the Government Offices of Iceland of 2011, as amended in 2020, Art. 24 Minister's Code of Conduct No. 190 of 2017 (as of 2020), Art. 3 (1))
Post-employment	Yes. Former ministers and other top executive officials may not act as lobbyists for six months after leaving office, unless an exemption is granted. (Act No. 64/2020 on Conflicts of Interest in the Government Offices of Iceland, Art. 5; entered into force 1 January 2021.)
Simultaneously holding policy-making position and policy-executing position	Yes. Ministers are entitled to a seat in Althingi (Parliament) and, by virtue of their office, have the right to participate in its debates as often as they may desire, but they must observe the rules of procedure. They have the right to vote only if they are at the same time Members of Althingi. (Constitution of the Republic of Iceland of 1944 (as of 2020), Art. 51)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework.
Assisting family or friends in obtaining employment in public sector	Yes. The Minister does not use his/her position, or information to which he gives him/her special access, for personal gain for himself or a party close to him/her, and sh/e strives to ensure that the appointment of officials and other employees is handled professionally. (Act on the Government Offices of Iceland of 2011, as amended in 2020, Art. 24 Minister's Code of Conduct No. 190 of 2017 (as of 2020), Arts. 1 (3) and 5 (1) )
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. The Prime Minister’s Office keeps the registers and the Prime Minister exercises general advice and oversight on interests, gifts, outside jobs, lobbyists, and post-employment restrictions. (Act No. 64/2020 on Conflicts of Interest in the Government Offices of Iceland, Arts. 6–7)
Enforcement body specified (sanctions, hearings)	No. The Minister shall show a willingness to co-operate if his/her work is examined by the Althingi or its regulatory bodies, as well as when members of Althingi request information on the basis of the Act on Althingi Procedure. No specific enforcement body is mentioned. (Act on the Government Offices of Iceland of 2011, as amended in 2020, Art. 24 Minister's Code of Conduct No. 190 of 2017 (as of 2020), Art. 7 (1))
Members of Parliament
Restrictions
General restriction on conflict of interest	Yes. Members shall avoid any conflict of interests in their work. In the discharge of their duties Members shall avoid conflicts between the public interest and their own financial or other personal interests, or those of their families, If a Member is unable to prevent such conflict of interests, the conflict shall be disclosed by the Member. Members shall, when applicable, draw attention to their own personal interests that may be relevant to the process of parliamentary business. (Code of Conduct for Members of the Althingi of 2016 (as of 2020), Arts. 9, 10 and 11)
Accepting gifts	Yes. Members shall not accept any inappropriate payment or gift. Members shall register with the Secretariat of the Althingi any gifts or other similar benefits that they may enjoy, such as travel expenses, subsistence, or hospitality expenses, which they may receive in the course of their work as Members of the Althingi and which do not fall within the scope of the rules on Members' allowance, as provided in the rules on the registration of Members' financial interests and commissions of trusts outside the Althingi. (Code of Conduct for Members of the Althingi of 2016 (as of 2020), Arts. 11 and 14)
Private firm ownership and/or stock holdings	Yes. A Member of the Althingi must disclose the name of any company (e.g. private limited company, partnership, limited partnership or co-operative) or savings bank in which s/he holds an interest exceeding any of the following criteria: 1. The market value of the interest exceeds 1,000,000 ISK as at 31 December each year; 2. The interest is 1% or more in a company, savings bank or foundation where assets at year-end amount to 230,000,000 ISK or more, or the operating income is 460,000,000 ISK or more; 3. The interest amounts to 25% or more in the share capital or initial capital of a company, savings bank or foundation. Additionally, any property which is one third or more in the ownership of a Member, or a company in which the Member holds a quarter share or more shall be disclosed. (Rules on the disclosure of financial interests of Members of Parliament of 2018 (as of 2020), Art. 4 (3) )
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	Yes. The following interests shall be disclosed: a) paid service on the boards of directors of private or public companies - the position and name of company shall be disclosed; b) paid work or assignments (other than salaried parliamentary work) - the title of the position and identity of the employer shall be disclosed; c) business that is conducted concurrently with parliamentary work and generates income for the Member or a company that the Member owns or of which the Member is a partial owner - the type of business in question shall be disclosed. (Rules on the disclosure of financial interests of Members of Parliament of 2018 (as of 2020), Art. 4 (1))
Board member, advisor, or company officer of private firm	Yes. Paid services on the boards of directors of private or public companies, the position the Member holds and the name of the company must be disclosed. Moreover, information on service on boards of directors and other positions of trust on behalf of interest groups, public organisations, municipalities and associations other than political parties shall be disclosed, regardless of whether such work is remunerated or not. The name of the association, interest group organisation or municipality and the nature of the position of trust shall be disclosed. (Rules on the disclosure of financial interests of Members of Parliament of 2018 (as of 2020), Arts. 4 (1) and 5)
Post-employment	Yes. Any agreement with a prospective employer on employment, regardless of whether the employment takes effect only after the Member leaves parliament, must be disclosed. The nature of the agreement and identity of the employer shall be disclosed. (Rules on the disclosure of financial interests of Members of Parliament of 2018 (as of 2020), Arts. 4 (5) (b))
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework.
Participating in official decision-making processes that affect private interests	No. There are no restrictions to participation in official decision-making processes that affect private interests. However, there is a general requirement that Members of the Althingi shall take decisions in the public interest, without requesting or accepting any consideration, fee or reward intended to affect their actions as Members, particularly in their decisions to support or oppose any parliamentary business in the course of deliberations in the Althingi or its committees. (Code of Conduct for Members of the Althingi of 2016 (as of 2020), Arts. 5 (b) and 11)
Assisting family or friends in obtaining employment in public sector	Yes. Members of the Althingi, as elected representatives of the people, shall not use their public office for their, or anyone else's, private gain. In the discharge of their duties Members shall avoid conflicts between the public interest and their own financial or other personal interests, or those of their families. (Code of Conduct for Members of the Althingi of 2016 (as of 2020), Arts. 5 (f) and 9)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. There are no administrative sanctions per se. If the Speakers' Committee has accepted a case for further consideration and valid explanations have emerged, or the matter has been rectified and the violation is regarded as minor, the Committee shall conclude the matter by a notice to the Member. (Code of Conduct for Members of the Althingi of 2016 (as of 2020), Art. 18)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	Yes. The Speakers' Committee shall appoint an advisory committee of three members for a term of five years to address communications sent by the Speakers' Committee concerning alleged violations of the Code of Conduct. The Committee will express an opinion of whether a Member has, through his or her conduct, violated his or her principles of behaviour pursuant to Article 5. The Committee will also advise the Speakers' Committee on all matters falling within the scope of the Code and any circumstances that may arise in the course of its enforcement. (Code of Conduct for Members of the Althingi of 2016 (as of 2020), Art. 16)
Enforcement body specified (sanctions, hearings)	Yes. Speakers' Committee. (Code of Conduct for Members of the Althingi of 2016 (as of 2020), Arts. 16, 17 and 18)
Civil servants
Restrictions
General restriction on conflict of interest	No. Absent from legal framework.
Accepting gifts	No. There is a provision specifically applicable to staff in the Government Offices, i.e. Cabinet/Ministries' staff. It stipulates that staff shall never personally accept any valuable gifts on account of their work. There is no general restriction applicable to civil servants at large. (Act on the Government Offices of Iceland of 2011, as amended in 2020, Art. 24 Code of Conduct for Staff in the Government Offices of Iceland of 2012 (as of 2020), Art. 2 (4))
Private firm ownership and/or stock holdings	No. Absent from legal framework.
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework.
Holding government contracts	Yes. Before an employee intends, alongside his/her job, to take up a paid job in the service of another party, join the management of an enterprise or establish an enterprise, he must inform of his intention to the authority that provided him with his job. He shall be informed within two weeks whether the aforesaid job is incompatible with his job and whether he is forbidden to undertake it. Such a prohibition may be referred to the minister in question. An employee should be prohibited to engage in activity as described above if it subsequently transpires that it is incompatible with his job with the government. (Government Employees Act No. 70 of 1996, as amended in 2020, Art. 20)
Board member, advisor, or company officer of private firm	Yes. Before an employee intends, alongside his/her job, to take up a paid job in the service of another party, join the management of an enterprise or establish an enterprise, he must inform of his intention to the authority that provided him with his job. He shall be informed within two weeks whether the aforesaid job is incompatible with his job and whether he is forbidden to undertake it. Such a prohibition may be referred to the minister in question. An employee should be prohibited to engage in activity as described above if it subsequently transpires that it is incompatible with his job with the government. (Government Employees Act No. 70 of 1996, as amended in 2020, Art. 20)
Post-employment	No. Absent from legal framework.
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework.
Participating in official decision-making processes that affect private interests	Yes. An employee who has a personal, family, or other significant private interest in a case is disqualified and must alert the institution. (Administrative Procedures Act No. 37/1993, Arts. 3–5.)
Assisting family or friends in obtaining employment in public sector	No. There is a provision specifically applicable to staff in the Government Offices, i.e. Cabinet/Ministries' staff. Government Office staff shall take care that no involvement with family relations, friends or interests affects their work. Should there be a risk of any such involvement resulting in a conflict of interests, the staff member shall inform her/his immediate superior, with both of them ensuring that the provision of this information is entered in the Document Registry. (Act on the Government Offices of Iceland of 2011, as amended in 2020, Art. 24 Code of Conduct for Staff in the Government Offices of Iceland of 2012 (as of 2020), Art. 3 (1) (2))
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework.
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework.
Enforcement body specified (sanctions, hearings)	No. Absent from legal framework.

Legislation

Constitution of the Republic of Iceland of 1944 (Icelandic)	pdf
Act on the Government Offices of Iceland of 2011 (Icelandic)	pdf
Minister's Code of Conduct No. 190 of 2017 (Icelandic)	pdf
Code of Conduct for Members of the Althingi (Parliamentary Resolution No. 23/145 and No. 18/148) (Icelandic)	pdf
Rules on the disclosure of financial interests of Members of Parliament and their positions of trust outside the Althingi (Icelandic)	pdf
The Government Employees Act No. 70 of 1996 (Icelandic)	pdf
Code of Conduct for Staff in the Government Offices of Iceland No. 410 of 2012 (Icelandic)	pdf

*Last update: 2017

Freedom of Information

Iceland’s freedom of information regime is established by Information Act No 140 (2012, amended 2016), which establishes the right to information and lays out implementing measures. The law applies to all government activities, thus excluding parliamentary and judicial activities from its scope. Any legal entity in which 51% or more shares are owned by the state is covered by the law, along with private enterprises that perform statutory roles or provide statutory services.

Specific exemptions to disclosure are outlined in the aforementioned FOI law, the Act on the Protection of Privacy as regards the Processing of Personal Data, No. 77/2000, and Administrative Procedures Act No. 37/1993. No public interest test exists whereby exemptions to disclosure may be overridden in cases where disclosure of information benefits the public interest.

The Information Committee hears appeals against rejected information requests and issues legally binding rulings enforcing disclosure. Appeals are not accepted at public agencies or in the courts.

There are no sanctions specified in the law for violations of FOI provisions except in the cases of substantial resulting damage, nor are there any enforcement or oversight bodies tasked with managing implementation.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024
Scope and Coverage	93	93	93	93	93	100
Information access and release	88	88	88	88	88	42
Exceptions and Overrides	83	83	83	83	83	50
Sanctions for non-compliance	0	0	67	67	67	0
Monitoring and Oversight	33	33	33	33	50	17

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Scope and Coverage
Scope of disclosure
Existence of legal right to access	Yes. The right of access to material shall apply to: 1. all of the material related to a matter, including copies of correspondence sent by a government authority or other entity according to Chapter I, if this correspondence may be expected to have reached the recipient, (Article 5 Information Act No 140/2012, amended 2019)
"Information" or "Documents" is defined	Yes. The right of access to material shall apply to: 1. all of the material related to a matter, including copies of correspondence sent by a government authority or other entity according to Chapter I, if this correspondence may be expected to have reached the recipient, (Article 5 Information Act No 140/2012, amended 2019)
Proactive disclosure is specified	Yes. Government authorities (ie legal entities in which a share of 51% or more is in public ownership) must regularly provide the public with information on government activities, for instance by publishing reports electronically, summarising important programmes or publishing other types of material. This information should increasingly be available electronically. (Article 13 Information Act No 140/2012, amended 2019)
Coverage of public and private sectors
Executive branch	Yes. The law applies to all government activities. (Article 2 Information Act No 140/2012, amended 2019 Article 7 Act on the Government of Iceland no. 115 2011 as amended 2020)
Legislative branch	Yes. This Act applies to the administration of Althingi, as further defined in the Act on Althingi Procedure and the Rules of the Presidium, which are set on the basis thereof. The provisions of the Act do not apply to the Parliamentary Ombudsman, the National Audit Office or investigative committees according to the Act on Investigative Committees, no. 68/2011 . Access to information at these institutions is subject to what is stated in the law on them or rules set on the basis thereof. Provisions V. – VII. chapters do not apply to Althingi or its institutions. ( Article 2 Information Act No 140/2012, amended 2019)
Judicial branch	Yes. This Act applies to courts and the Judicial Service, with the exception of the provisions of Articles V – VII. chapter. However, the law does not apply to documents in their custody on the handling of individual court cases and transcripts from court records, minutes and parliamentary records. ( Article 2 Information Act No 140/2012, amended 2020)
Other public bodies	Yes. Any legal entity in which 51% or more shares are owned by the state is covered by the law. (Article 2 Information Act No 140/2012, amended 2019 Article 7 Act on the Government of Iceland no. 115 2011 as amended 2020)
Private sector	Yes. Private enterprises that perform statutory roles or provide statutory services are covered (except those which have applied for or received an official listing of shares according to the Act on Stock Exchanges, or their subsidiaries). (Article 2 and Article 3 Information Act No 140/2012, amended 2019)
Access to specific documents (subject to reactive and/or proactive disclosure)
Draft legal instruments	Yes. As government ministries are covered by the FOIA, so draft legislation would be covered. In practice draft legislation is often actively published on Ministry websites. (Article 2 Information Act No 140/2012, amended 2019 Article 7 Act on the Government of Iceland no. 115 2011 as amended 2015)
Enacted legal instruments	Yes. All laws must be published under the Constitution. In addition, as government ministries are covered by the FOIA, so enacted laws would be covered. (Article 27 Constitution No. 33/1944, amended 2013 Article 2 Information Act No 140/2012, amended 2019)
Annual budgets	Yes. The budgets of a wide range of (but not all) public bodies are presented to the parliament by the Minister of Finance each year in a bill on public finances. This is accompanied by a projection of government finances for the next 3 years. In addition, all government authorities covered by the FOIA would be required to reveal their budgets and accounts under that law. (Article 21 and Article 28 Government Financial Reporting Act No. 88/1997, amended 2011 Article 2 Information Act No 140/2012, amended 2019 )
Annual chart of accounts (actual expenditures)	Yes. A specified group of bodies – including the Office of the President, the parliament, the Cabinet and the Supreme Court, the ministries and government agencies, and non-government entities that are funded by or legally responsible to the Treasury – must report their accounts to the Financial Management Authority (FJS), National Audit Bureau and the relevant Ministry. As these 3 latter bodies are covered by the FOIA, the accounts would be available. In addition, all government authorities covered by the FOIA would be required to reveal their budgets and accounts under that law. (Article 62 Public Finanace Act No. 123/2015 Article 2 Information Act No 140/2012, amended 2019)
Annual reports of public entities and programs	Yes. Government authorities must regularly provide the public with information on government activities, for instance by publishing reports electronically, summarising important programmes or publishing other types of material. This information should increasingly be available electronically. (Article 13 Information Act No 140/2012, amended 2019)
Information access and release
Procedural access
Universal access (agencies, citizens and non-citizens)	Yes. The law refers to "the public" and doesn't specify who that covers. It doesn't preclude any particular groups so it can be assumed that there is universal access. (Article 5 Information Act No 140/2012, amended 2019)
Type of request is specified (written, electronic, oral)	No. The law doesn't specify how the request must be made, just that the application must clear enough to understand what is needed, without significant effort. The applicant might be required to use a form but it does not specify how that should be submitted (ie written, electronic). (Article 15 Information Act No 140/2012, amended 2019)
Assistance to requesters must be provided by law (includes barriers due to language differences, illiteracy, complexity of requests, etc.)	No. Absent from legal framework.
Cost of access is specified (free, request fees, photocopying costs, other administrative costs)	Yes. Fees for copying and expenses for equipment and staff work must be covered according to a schedule set out by the “Minister”. Prepayment may be demanded if the cost of copying or photocopying can be foreseen to exceed ISK 10,000 (c.€70). It has not been possible to locate this cost schedule. (Article 18 Information Act No 140/2012, amended 2019)
Deadlines for release of information
20-day response deadline	No. Requests should be dealt with "as soon as possible". If the information requested is not provided within 7 days, applicants must be told why and given an expected delivery date. There is no fixed maximum timeframe. For research materials, the request must be responded to within 20 days. (Article 17 Information Act No 140/2012, amended 2019)
Agency granted right to extend response time	No. There is no set maximum timeframe or, therefore, provision to extend.
Maximum total response time of no more than 40 days	Yes. If a request for access to data has not been processed within 30 working days of its receipt, the applicant may refer the case to the Appellate Committee on Information, which rules on his right of access. (Article 17 Information Act No 140/2012, amended 2019)
Exceptions and Overrides
Exemptions to disclosure
Existence of secrecy/states secrets law	No. Absent from legal framework.
Existence of personal privacy/data law	Yes. There is a data protection law and the Constitution provides for a right to privacy. (Act on the Protection of Privacy as regards the Processing of Personal Data, No. 77/2000, amended 2018 Article 71 Constitution No. 33/1944, amended 2013)
Specific exemptions to disclosure	Yes. Material exempted from the right to information includes minutes and preparatory documents for State Council and Cabinet meetings (except agendas), memoranda at ministerial meetings, preparatory financial material of local authorities, correspondence with experts for use in or about legal proceedings, material related to personnel matters, working documents, personal private or financial information, financial or commercial interests of businesses or other legal entities. It also includes documents containing information on state security or defence issues, relations with other States or international organisations, economically significant State interests, the business of State-owned or municipally owned institutions or companies insofar as they are competing with other bodies, environmental matters. In some cases access to information on an administrative case can be restricted. (Articles 6-10 Information Act 140/2012 , amended 2016 Article 21 Act on the Protection of Privacy as regards the Processing of Personal Data No. 77/2000, amended 2018 Article 17 Administrative Procedures Act No. 37/1993, amended 2021)
Public Interest test: Specified exemptions to disclosure may be overridden in cases where disclosure of information benefits the public interest.
Appeals
Appeals allowed within public entities	No. Absent from legal framework.
Independent, non-judicial appeals mechanism, e.g., information commissioner. Does not include Ombudsman unless appeals decisions are binding.	Yes. A refusal of a request for access to documents pursuant to this Act may be submitted to the Appellate Committee on Information Matters, which shall rule on the dispute. The same goes for refusal on request to submit data in the form requested. The committee is independent in its work and its rulings under this Act will not be appealed to other authorities. (Article 20 Information Act No 140/2012, amended 2019)
Judicial appeals mechanism	No. Absent from legal framework.
Sanctions for non-compliance
Administrative sanctions are specified for violations of disclosure requirements	No. The Information Committee can force a public body to disclose information through legally binding rulings. (Article 23 Information Act No 140/2012, amended 2019)
Fines are specified for violations of disclosure requirements	No. Absent from legal framework.
Criminal sanctions are specified for violations of disclosure requirements	No. Absent from legal framework.
Monitoring and Oversight
Information officers must be appointed in public agencies	No. Absent from legal framework.
Public body that is responsible for applying sanctions	Yes. The Information Committee hears appeals against rejected information requests and issues legally binding rulings enforcing disclosure. (Article 22 and Article 23 Information Act No 140/2012, amended 2019)
Public body that is responsible for public outreach (raising public awareness)	No. Absent from legal framework.
Nodal agency for RTI (implementation support/compliance within public sector). Does not include Ombudsman.	No. Absent from legal framework.
Ombudsman involvement in implementation is specified by law	No. Absent from legal framework.
Reporting of data and/or implementation is required	No. Absent from legal framework.

Legislation

Constitution of the Republic of Iceland of 1944_ICE (Icelandic)	pdf
Act on the Government Offices of Iceland of 2011_ICE (Icelandic)	pdf
Information Act No. 140 of 2012_ICE (Icelandic)	pdf
Act No. 123 on Public Finances of 2015_ICE (Icelandic)	pdf
Act on Personal Data Protection and Processing of Personal Data of 2018_ICE (Icelandic)	pdf
Administrative Law of 1993_ICE (Icelandic)	pdf

*Last update: 2017

Public Procurement

The Icelandic public procurement system is regulated by the Act No. 84/2007 on Public Procurement (last amended in 2013), and additional regulations are laid down in Government Decrees. The public procurement body (central purchasing unit) is the State Trading Centre (Ríkiskaup) which is an organization under the Ministry of Finance.

The lowest minimum thresholds for conducting a public procurement tender are:

▪         ISK 11,500,000 (ca. EUR 91000) for goods

▪         ISK 49,000,000(ca. EUR 400,000) for works

▪         ISK 11,500,000 (ca. EUR 91000) for services

The minimum number of bidders is 5 for restricted procedures and 3 for negotiated procedures and competitive dialogue. The minimum submission period is 15 days for open procedures, 15 days for restricted procedures and 15 for negotiated procedures from the call for tender publication date. The final beneficial owners do not have to be disclosed when placing a bid.

There is a possibility for preferential treatment, as green/sustainability aspects can be considered during the awarding procedure, though no specific provisions for SMEs. There are also several options for bid exclusion: participation in a criminal organization, corruption, fraud, money laundering, bankruptcy, professional misconduct, outstanding tax or social security liabilities, false information. Bids can be also excluded because of abnormally low bid prices.

In the bid evaluation phase, there is no separate conflict of interest regulation on the composition of the evaluation committee and, for most cases, there is no specific provision on the independence of the evaluation committee at the contracting authority.

There is a payable fee in case of an arbitration procedure that is a standard ISK 150,000 (ca. EUR 1100) and the decisions are published as the rulings of the Public Procurement Complaints Commission.

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2015	2016	2017	2020	2024
Scope	79	77	72	80	63
Information availability	99	99	99	49	31
Evaluation	56	56	56	75	69
Open competition	75	75	75	75	56
Institutional arrangements	100	100	100	100	36

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Scope
Threshold - lowest PP
What is the minimum contract value above which the public procurement law is applied? (Product type GOODS)	ISK 20,866,000. Supply contracts must be tendered under the Act when the estimated value of goods reaches at least ISK 20,866,000; below this, simplified procedures may apply. (Act No. 120/2016, Art. 23(1))
What is the minimum contract value above which the public procurement law is applied? (Product type WORKS)	ISK 58,543,000. Works contracts must be tendered in accordance with Chapter IV when the contract value is at least ISK 58,543,000. (Act No. 120/2016, Art. 23(1))
What is the minimum contract value above which the public procurement law is applied? (Product type SERVICES)	ISK 20,866,000. Service contracts, other than special social and specific services, are subject to the Act’s procedures when their value reaches ISK 20,866,000. (Act No. 120/2016, Art. 23(1), (4))
Threshold - by PP type
What are the minimum application thresholds for the procurement type? (Entity: PUBLIC SECTOR)	ISK 20,866,000. Public authorities covered by the general Act must follow formal procedures when purchasing goods or services from ISK 20,866,000 and works from ISK 58,543,000. (Act No. 120/2016, Arts. 3, 23)
What are the minimum application thresholds for the procurement type? (Entity: UTILITIES)	ISK 64,634,000. Utilities in water, energy, transport and postal services must follow the utilities regime when contracts reach the threshold amounts specified in the utilities regulation, which sets separate values for supplies/services and for works. (Regulation No. 340/2017, Art. 15)
What are the minimum application thresholds for the procurement type? (Entity: DEFENCE)	ISK 64,634,000. Defence and security procurement is governed by specific rules; Chapters XI–XII of the Act apply when defence/security contracts exceed the threshold amounts set by ministerial regulation for that sector. (Act No. 120/2016, Arts. 7, 9, 23; Regulation No. 845/2014, Art. 2)
Threshold - by product type
What are the minimum application thresholds for the procurement type? (Product type GOODS)	ISK 20,866,000. For contracts mainly concerning goods, formal procedures apply from ISK 20,866,000. (Act No. 120/2016, Art. 23(1))
What are the minimum application thresholds for the procurement type? (Product type WORKS)	ISK 58,543,000. For works contracts, formal procedures apply once the estimated value reaches ISK 58,543,000. (Act No. 120/2016, Art. 23(1))
What are the minimum application thresholds for the procurement type? (Product type SERVICES)	ISK 20,866,000. For contracts mainly for services, formal procedures apply from ISK 20,866,000, except where special rules for certain social or specific services apply. (Act No. 120/2016, Art. 23(1), (4))
Information availability
Publishing and record keeping
Is there a requirement that tender documents must published in full?	Yes. Authorities must give unrestricted, full and direct electronic access, free of charge, to procurement documents from the date of the notice or invitation and indicate where they are available. (Act No. 120/2016, Arts. 2(27), 47, 48, 60)
Are any of these documents published online at a central place?	Yes. Procurements above national thresholds must be advertised electronically on a common national site designated by the minister, and above EEA thresholds notices must also be sent electronically to the Publications Office of the EU. (Act No. 120/2016, Arts. 55, 56, 60)
Is it mandatory to keep all of these records? -Public notices of bidding opportunities, -Bidding documents and addenda, -Bid opening records, -Bid evaluation reports, -Formal appeals by bidders and outcomes, -Final signed contract documents and addenda and amendments, -Claims and dispute resolutions, -Final payments, -Disbursement data (as required by the country’s financial management system	Yes. Contracting authorities must keep sufficient documentation on all stages of procurement procedures, including communications and decisions, for at least three years from the award decision. (Act No. 120/2016, Art. 96)
Are contracts awarded within a framework agreement published (ie mini contracts)?	No. The law requires documentation of procurement procedures but does not specifically oblige publication of individual contracts awarded under framework agreements (mini‑contracts). (Act No. 120/2016, Art. 96)
Sub-contracting
Is it mandatory to publish information on subcontractors (ie names) in some cases?	No. Tenderers must indicate which parts of the contract they intend to subcontract and notify the contracting authority of intended subcontractors, who must approve them, but there is no obligation to publish subcontractors’ names. (Act No. 120/2016, Art. 88)
If yes, what is the threshold for publication (i.e. the % of total contract value subcontracted)? For example, if the threshold is 75%, and you have subcontracted out only 40% of your contract, no disclosure is required. Consultant will insert 75% in the short answer column.	There is no percentage or value threshold above which subcontractors must be publicly disclosed, since publication of their identity is not mandated at all. (Act No. 120/2016, Art. 88)
Evaluation
Preferential treatment
Is there a ban on mentioning specific companies or brands in tender specification/call for tender?	Yes. Technical specifications must not refer to a specific make, source, trademark, patent, type or origin with the effect of favouring or eliminating certain undertakings, except in justified cases and then only with the words “or equivalent” or similar. (Act No. 120/2016, Art. 49(4))
Is there a preferential treatment for small-to-medium enterprises (SMEs)?	No. The Act does not provide explicit preferential treatment (e.g. reserved procedures or scoring advantages) for SMEs; general rules on equal treatment and competition apply. (Act No. 120/2016, Arts. 15, 33–39)
Is there a preferential treatment for local/national companies? (companies from other EU MS are considered foreign companies)	No. Contracting authorities must ensure equal treatment, proportionality and transparency and may not discriminate on grounds of nationality or unreasonably restrict competition. (Act No. 120/2016, Art. 15)
Is there a specific set of rules for green/sustainable procurement?	Yes. Environmental considerations may be included in technical specifications, selection and award criteria; non‑compliance with environmental legislation may justify exclusion, and authorities may require recognised environmental management certificates. (Act No. 120/2016, Arts. 49(2)–(4), 50, 66, 68(1)(a), 75, 79, 80, 87)
Bid evaluation
Are there restrictions on allowable grounds for tenderer exclusion?	Yes. The Act lists mandatory exclusion grounds (e.g. criminal offences such as corruption, fraud, money laundering, trafficking) and a closed list of optional grounds (e.g. bankruptcy, grave professional misconduct, distortion of competition, conflict of interest, serious past performance issues). (Act No. 120/2016, Art. 68)
Are some bids automatically excluded? e.g., lowest/highest price; unusually low price, etc.	Yes. Contracting authorities may reject all tenders on objective grounds and must be able to reject abnormally low tenders if, after seeking explanations, the justification is not satisfactory; expired or withdrawn offers are also rejected. (Act No. 120/2016, Arts. 81–83)
Is scoring criteria published?	Yes. Contracting authorities must indicate in the procurement documents the award criteria and their relative weighting (or priority order if precise weighting is not possible), unless the sole award criterion is price. (Act No. 120/2016, Arts. 47(1)(m), 79)
Are decisions always made by a committee?	No. For design contests, a jury independent from participants decides; for other types of procurement, the Act does not require that decisions be taken by a multi‑member evaluation committee. (Act No. 120/2016, Art. 44)
Are there regulations on evaluation committee composition to prevent conflict of interest?	Yes. The Act requires that procurement be conducted with non‑discrimination, proportionality and transparency and that appropriate measures be taken to prevent conflicts of interest, including where staff or advisors might have personal interests compromising impartiality. (Act No. 120/2016, Arts. 15, 68(1)(f), 96(1)(i))
Is some part of evaluation committee mandatorily independent of contracting authority?	No. The law provides for an independent jury in design contests but does not require that members of evaluation committees in ordinary procurement be independent of the contracting authority. (Act No. 120/2016, Art. 44)
Are scoring results publicly available?	No. The Act does not oblige contracting authorities to publish detailed scoring results for each tenderer; unsuccessful bidders receive information through notification, but scores are not systematically made public. (Act No. 120/2016, Art. 85)
Does the law specify under which conditions the tender can be cancelled?	No. The Act allows rejection of all tenders on objective grounds, but it does not set out an exhaustive list of conditions under which a procedure may be cancelled. (Act No. 120/2016, Arts. 81–82)
Open competition
CFT publication
Does the law specify the location for publicizing open calls for tenders?	Yes. All procurement of supplies, services and works above national thresholds must be advertised electronically on the national tender portal designated by the minister and, where EEA thresholds are exceeded, notices must also be sent to the EU Publications Office (TED). (Act No. 120/2016, Arts. 55–56)
Does the law specify the location for publicizing restricted calls for tenders?	Yes. Restricted procedures above thresholds must be advertised on the same national electronic portal and, where applicable, also submitted electronically to the EU Publications Office. (Act No. 120/2016, Arts. 55–56)
Does the law specify the location for publicizing negotiated calls for tenders?	Yes. Negotiated procedures and competitive procedures with negotiation above thresholds must be advertised on the national electronic portal and, when EEA thresholds are exceeded, also notified to the EU Publications Office. (Act No. 120/2016, Arts. 39, 55–56)
Minimum # of bidders
What is the minimum number of bidders for restricted procedures?	5. For restricted procedures, the contracting authority must invite at least five qualified candidates to submit tenders, as far as there are enough suitable candidates. (Act No. 120/2016, Art. 78(1))
What is the minimum number of bidders for negotiated procedures?	3. For competitive procedures with negotiation or negotiated procedures with prior publication, at least three candidates must be invited, where available. (Act No. 120/2016, Art. 78(2))
What is the minimum number of bidders for competitive dialogue procedures?	3. For competitive dialogue, the contracting authority must invite at least three candidates, subject to availability of suitable candidates. (Act No. 120/2016, Art. 78(3))
Bidding period length
What are the minimum number of days for open procedures?	15. For open procedures, the minimum time limit for submission of tenders is 15 calendar days for contracts at national level and 35 days when EEA thresholds apply, with the possibility of shortening in urgent cases but never below 7 or 15 days respectively. (Act No. 120/2016, Art. 58(1)–(2))
What are the minimum number of days for restricted procedures?	10. For restricted procedures, the minimum time limit for submitting tenders is 10 calendar days in the shortened regime when certain conditions are met; general rules allow longer periods which may be reduced under specific circumstances. (Act No. 120/2016, Art. 59(1)–(3))
What are the minimum number of days for competitive negotiated procedures?	10. For competitive procedures with negotiation, the minimum time limit for submission of tenders in the shortened regime is also 10 calendar days, with similar possibilities to reduce longer standard periods under defined conditions. (Act No. 120/2016, Art. 59(1)–(3))
Institutional arrangements
Institutions and regulations
Does the law specify the main EXCEPTIONS preventing the application of the public procurement law for tenders/organisations?	Yes. The Act lists the main categories of contracts excluded from its scope, including certain mixed and secret contracts in defence/security, contracts under international agreements, specific utilities contracts, electronic communications, real estate, broadcasting, arbitration and legal services, financial services, employment contracts, certain transport services, political activities, and specific R&D services. (Act No. 120/2016, Arts. 5–13)
Does the law specify the main types of institutions that must apply the public procurement law?	Yes. The law specifies that it applies to the State, municipalities, their institutions and other public entities, as well as certain legal persons governed by public law established to meet needs in the general interest and mainly financed or controlled by public authorities. (Act No. 120/2016, Art. 3)
Does the law specify the main procedure types or procurement methods permitted?	Yes. The Act explicitly provides for open procedure, restricted procedure, negotiated procedure, competitive procedure with negotiation, competitive dialogue, innovative partnership and design contests. (Act No. 120/2016, Arts. 2(8), 2(19)–(21), 33–39)
Is there a procurement arbitration court dedicated to public procurement cases?	Yes. Public procurement complaints are decided by the Public Procurement Complaints Committee, a specialised administrative review body established by the Act. (Act No. 120/2016, Arts. 103–105)
Is there a procurement regulatory body dedicated to public procurement?	Yes. Ríkiskaup acts as the central purchasing authority for the State and performs regulatory and coordination functions for public procurement policy and practice. (Act No. 120/2016, Arts. 99, 122)
Does the law specify procurement advisors' profession (i.e. degree to be obtained, official list of members of the professional association) and its role in the tendering process (e.g. right to draft tender documentations, conduct market research identifying bidders)?	No. The Act sets qualification requirements for members of the Complaints Committee and juries for design contests but does not define a regulated profession of procurement advisers or their formal role in tender processes. (Act No. 120/2016, Arts. 44, 103)
Is disclosure of final, beneficial owners required for placing a bid?	No. The public procurement legislation does not contain an explicit requirement that bidders disclose their ultimate beneficial owners as a condition for participation. (Act No. 120/2016, Arts. 68–73)
Complaints
Is there a fee for arbitration procedure?	Yes. A fixed complaints fee must be paid for each complaint lodged with the Public Procurement Complaints Committee. (Act No. 120/2016, Art. 106(3))
Is there a ban on contract signature until arbitration court decision (first instance court)?	Yes. If a complaint against an award decision is filed within the statutory standstill period, the contracting authority is prohibited from concluding the contract until the Complaints Committee has issued its final decision or lifted the suspension. (Act No. 120/2016, Arts. 86, 107)
What is the maximum number of days until arbitration court decision from filing a complaint in the case of awarded contracts?	30. The Complaints Committee must issue its ruling on a complaint as soon as possible and no later than one month after receiving the necessary comments and information from the parties. (Act No. 120/2016, Art. 108(2))
Is there a requirement to publicly release arbitration court decisions ?	Yes. Decisions of the Public Procurement Complaints Committee must be made public, and are published so that parties and the public can access the outcomes of procurement disputes. (Act No. 120/2016, Art. 113)

Legislation

Public Procurement Act No. 120/2016 (Icelandic)	pdf
Regulation No. 340/2017 on advertisements, thresholds and procurement procedures under the Public Procurement Act (Icelandic)	pdf
Regulation No. 845/2014 on procurement in the fields of defence and security (Icelandic)	pdf

*Last update: 2017

Anti Money Laundering

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Risk-based approach						100
Sanctions for natural persons						100
Sanctions for legal persons						75
Pecuniary sanctions for obliged entities						100
Beneficial ownership of legal persons and legal arrangements						48
Supervision of obliged entities						100
Financial Intelligence Units (FIUs)						83
Mutual legal assistance (MLA) and International Cooperation						100

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Country score
Risk-based approach
Each Member State shall be legally required to prepare a national risk assessment that outlines appropriate steps to identify, assess, understand and mitigate the risks of money laundering and terrorist financing affecting it.	Yes. Act No. 140/2018 requires the National Police Commissioner to prepare a government AML/TF risk assessment and issue a report identifying risk and mitigation measures. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 4 (1))
Member states shall be legally required to keep the national risk assessment up to date and review it at least every 4 years.	Yes. The national risk assessment report must be issued every four years or more often if needed, and the National Police Commissioner must consider updates at least every two years. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 4 (1))
Member states should legally designate an authority or mechanism to co-ordinate actions to assess risks.	Yes. The National Police Commissioner shall carry out the government's risk assessment of money laundering and terrorist financing. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 4 (1))
Sanctions for natural persons
The following conduct, when committed intentionally, is punishable as a criminal offence: the conversion or transfer of property, knowing that such property is derived from criminal activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action;	Yes. Anyone who receives, uses or obtains for himself or another the benefit of a violation of the Penal Code or of a punishable violation of other laws, or among other things transforms such benefit, transports it, sends it, stores it, assists in its delivery, conceals it or information about its origin, nature, location or disposal of the benefit shall be subject to imprisonment for up to 6 years. (General Penal Code No. 19/1940, Art. 264)
The following conduct, when committed intentionally, is punishable as a criminal offence: the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity;	Yes. Anyone who receives, uses or obtains for himself or another the benefit of a violation of the Penal Code or of a punishable violation of other laws, or among other things transforms such benefit, transports it, sends it, stores it, assists in its delivery, conceals it or information about its origin, nature, location or disposal of the benefit shall be subject to imprisonment for up to 6 years. (General Penal Code No. 19/1940, Art. 264)
The following conduct, when committed intentionally, is punishable as a criminal offence: the acquisition, possession or use of property, knowing at the time of receipt, that such property was derived from criminal activity.	Yes. Anyone who receives, uses or obtains for himself or another the benefit of a violation of the Penal Code or of a punishable violation of other laws, or among other things transforms such benefit, transports it, sends it, stores it, assists in its delivery, conceals it or information about its origin, nature, location or disposal of the benefit shall be subject to imprisonment for up to 6 years. (General Penal Code No. 19/1940, Art. 264)
Aiding and abetting, inciting and attempting a money laundering offence is punishable as a criminal offence.	Yes. Attempt and participation, including assistance and incitement, are punishable under the general Penal Code rules that apply to offences in the Code, including money laundering. (General Penal Code No. 19/1940, Art. 20, 22)
Money laundering offences are punishable by a maximum term of imprisonment of at least four years.	Yes. Intentional money laundering is punishable by imprisonment of up to six years. (General Penal Code No. 19/1940, Art. 264)
A prior or simultaneous conviction for the criminal activity from which the property was derived is not a prerequisite for a conviction for money laundering offences	Yes. The Penal Code does not expressly state that a prior or simultaneous conviction for the predicate offence is necessary or unnecessary, but money laundery derives from a crime "punishable" by common criminal law or other law. Also, punishment shall be made in accordance with the Icelandic Penal Code: For offences against Article 264 committed within the Icelandic state, even if the predicate offence from which the proceeds arise was committed abroad and regardless of who was responsible for it. (General Penal Code No. 19/1940, Art. 4 (3), 264)
A conviction for money laundering offences is possible where it is established that the property was derived from a criminal activity, without it being necessary to establish all the factual elements or all circumstances relating to that criminal activity, including the identity of the perpetrator;	Yes. Punishment shall be made in accordance with the Icelandic Penal Code: For offences against Article 264 committed within the Icelandic state, even if the predicate offence from which the proceeds arise was committed abroad and regardless of who was responsible for it. (General Penal Code No. 19/1940, Art. 4(3), 264)
Sanctions for legal persons
Legal persons can be held liable for the breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113 committed on their behalf or for their benefit by any person, acting individually or as part of a body of that legal person and having a leading position within that legal person, based on any of the following: a power to represent the legal person; an authority to take decisions on behalf of the legal person; an authority to exercise control within the legal person.	Yes. National law provides legal-person liability and sanctions for breaches of the Icelandic AML Act and certain breaches of Regulation (EU) 2023/1113 (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 46, 50, 51; General Penal Code No. 19/1940, Art. 19)
Legal persons can be held liable where the lack of supervision or control has made possible the commission of any money laundering offences for the benefit of that legal person by a person under its authority.	No. The legal-person liability rule does not expressly cover liability based on lack of supervision or control that made the offence possible for a subordinate acting for the entity’s benefit. (General Penal Code No. 19/1940, Art. 19c)
Legal persons held liable are punishable by criminal or non-criminal fines.	Yes. Legal persons may be sanctioned by criminal fines under the Penal Code and by administrative fines under the AML Act. (General Penal Code No. 19/1940, Art. 19, 31; Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 46)
Legal persons held liable are punishable by other sanctions, such as: exclusion from entitlement to public benefits or aid; temporary or permanent exclusion from access to public funding, including tender procedures, grants and concessions; temporary or permanent disqualification from the practice of commercial activities; placing under judicial supervision; a judicial winding-up order; temporary or permanent closure of establishments which have been used for committing the offence.	Yes. The AML Act allows removal of the board or managing director and withdrawal of licence or registration for serious, repeated or systematic breaches. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 50, 51)
Pecuniary sanctions for obliged entities
In the event of a breach of Regulations (EU) 2024/1624 and (EU) 2023/1113, where obligations apply to legal persons, pecuniary sanctions can be imposed and administrative measures can be applied not only to the legal person, but also to the senior management and to other natural persons who under national law are responsible for the breach.	Yes. National law allows sanctions on employees and management for AML Act breaches and certain breaches of Regulation (EU) 2023/1113 (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art.46, 50)
Pecuniary sanctions shall be imposed on obliged entities for serious, repeated or systematic breaches, whether committed intentionally or negligently, of the requirements laid down in the following provisions of Regulation (EU) 2024/1624: Chapter II (Internal policies, procedures and controls of obliged entities); Chapter III (Customer due diligence); Chapter V (Reporting obligations); Article 77 (Record retention).	Yes. Administrative fines shall be imposed regardless of whether the offense is committed intentionally or negligently. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art.46)
Supervisors are able to apply administrative measures to an obliged entity, where they identify: breaches of Regulation (EU) 2024/1624 or Regulation (EU) 2023/1113, either in combination with pecuniary sanctions for serious, repeated and systematic breaches, or on their own; weaknesses in the internal policies, procedures and controls of the obliged entity that are likely to result in breaches of the requirements; that the obliged entity has internal policies, procedures and controls that are not commensurate with the risks of money laundering, its predicate offences or terrorist financing to which the entity is exposed.	Yes. Icelandic supervisors can require an obliged entity to remedy deficiencies within a reasonable time where the entity does not comply with the AML Act or binding rules issued under it, and they can also impose daily fines if the remediation order is not followed. In addition, they can impose administrative fines for breaches of the AML obligations on risk assessments and documented policies, controls and procedures, including where those controls are not aligned with the entity’s risk profile. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 44, 45, 46)
Where obliged entities fail to comply with administrative measures applied by the supervisor within the applicable deadlines, supervisors are able to impose periodic penalty payments in order to compel compliance with those administrative measures.	Yes. Supervisors may impose daily penalty payments where an obliged entity fails to comply with remediation requirements within the deadline. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 44, 45)
Supervisors are required to publish on their website, in an accessible format, decisions imposing pecuniary sanctions, applying administrative measures or imposing periodic penalty payments.	Yes. Supervisory authorities shall publish on their websites all administrative sanctions imposed in accordance with Articles 46–47 and 50–51. Decisions shall be published as soon as possible after the offending party has been notified of the decision. The notification shall, at a minimum, include information on the type and nature of the offence and who is responsible for the offence. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 53)
Beneficial ownership of legal persons and legal arrangements
Beneficial ownership information must be held in a central register in the Member State where the legal entity is created or where the trustee of an express trust or person holding an equivalent position in a similar legal arrangement is established or resides, or from where the legal arrangement is administered.	Yes. The central register covers legal persons registered or doing business in Iceland and foreign trust funds or comparable entities doing business in Iceland (Act No 82/2019 on the registration of beneficial owners, Art. 2)
Member States shall ensure that the entities in charge of the central registers are empowered to request from legal entities, trustees of any express trust and persons holding an equivalent position in a similar legal arrangement, and their legal and beneficial owners, any information necessary to identify and verify their beneficial owners, including resolutions of the board of directors and minutes of their meetings, partnership agreements, trust deeds, power of attorney or other contractual agreements and documentation.	Yes. In connection with the registration and maintenance of records pursuant to this Act natural persons and legal persons are required to provide promptly to the Directorate of Internal Revenue all information and documents needed to ensure correct registration pursuant to this Article and Article 5. (Act No 82/2019 on the registration of beneficial owners, Art. 4, 5)
Where no person is identified as the beneficial owner, the central register shall include: (a) a statement that there is no beneficial owner or that the beneficial owners could not be determined, accompanied by a corresponding justification (b) the details of all natural persons who hold the position of senior managing officials in the legal entity equivalent to the following information: all names and surnames, place and full date of birth, residential address, country of residence and nationality or nationalities of the beneficial owner, number of identity document, such as passport or national identity document, and, where it exists, unique personal identification number assigned to the person by his or her country of usual residence, and general description of the source of such number	No. If no beneficial owner can be identified, the person or persons managing the legal entity are treated as beneficial owners, but the law does not require a no-beneficial-owner statement with justification (Act No 82/2019 on the registration of beneficial owners, Art. 4)
Entities in charge of the central registers are required to verify, within a reasonable time upon submission of the beneficial ownership information, and on a regular basis thereafter, that such information is adequate, accurate and up to date.	No. There is no explicit duty to verify beneficial ownership information on a regular ongoing basis after submission.
Competent authorities, if appropriate and to the extent that such requirement does not interfere unnecessarily with their functions, are required to report to the entities in charge of the central registers any discrepancies they find between information available in the central registers and the information available to them.	Yes. Reporting entities and regulatory bodies provided for in the Act on measures against money laundering and terrorist financing shall within two weeks notify the Directorate of Internal Revenue if they become aware in the course of their work of any disparity between information on beneficial owners in the Register of Enterprises and information in their possession. (Act No 82/2019 on the registration of beneficial owners, Art. 6)
The information contained in the central registers must include any change to the beneficial ownership of legal entities and legal arrangements and to nominee arrangements, following their first recording in the central register.	Yes. Obliged entities are required to notify the Directorate of Internal Revenue within two weeks of any changes relating to a registration (Act No 82/2019 on the registration of beneficial owners, Art. 6)
The entity in charge of the central register is empowered, whether directly or by application to another authority, including judicial authorities, to carry out checks, including on-site inspections at the business premises or registered office of legal entities, in order to establish the current beneficial ownership of the entity and to verify that the information submitted to the central register is accurate, adequate and up-to-date.	Yes. In carrying out its functions, the Directorate of Internal Revenue may perform on-site checks or request information in the manner and as often as considered necessary. (Act No 82/2019 on the registration of beneficial owners, Art. 4)
Where verification leads an entity in charge of a central register to conclude that there are inconsistencies or errors in the beneficial ownership information, the entity in charge of a central register is able to withhold or refuse to issue a valid certificate of proof of registration, or to suspend the validity of an existing certification of proof of registration.	Yes. The legal framework provides corrective orders, daily fines, administrative fines, deregistration and dissolution (Act No 82/2019 on the registration of beneficial owners, Art. 13, 14, 15 17)
The entity in charge of the central register is empowered to, whether directly or by application to another authority, including judicial authorities, apply effective, proportionate and dissuasive measures or impose such pecuniary sanctions for failures, including of a repeated nature, to provide the central register with accurate, adequate and up-to-date information about their beneficial ownership.	Yes. The Directorate of Internal Revenue may impose corrective orders, periodic daily penalties, administrative fines and deregistration or dissolution measures for failures to provide accurate and updated beneficial ownership information. (Act No 82/2019 on the registration of beneficial owners, Art. 13, 14, 15, 16, 17)
Competent authorities have immediate, unfiltered, direct and free access to the information held in the interconnected central registers without alerting the legal entity or legal arrangement concerned. These competent authorities include: self-regulatory bodies in the performance of supervisory functions of AML rules; tax authorities; national authorities with designated responsibilities for the implementation of Union restrictive measures; AMLA for the purposes of joint analyses; EPPO; OLAF; Europol and Eurojust when providing operational support to the competent authorities of Member States.	Yes. Direct unalerted access exists for the FIU, AML supervisors/law-enforcement authorities and tax authorities. Information on beneficial owners pursuant to Article 4 shall be accessible as follows through the system of interconnection of registers established by Article 22(1) of Directive (EU) 2017/1132 in accordance with the provisions of Article 30(10) of Directive (EU) 2015/849 (Act No 82/2019 on the registration of beneficial owners, Art. 7, 8)
Beneficial ownership information held in central registers may be made available to obliged entities upon payment of a fee, which shall be limited to what is strictly necessary to cover the costs of ensuring the quality of the information held in the central registers and of making the information available. Those fees shall be established in such a way as not to undermine effective access to the information held in the central registers.	Yes. Obliged entities have timely access to necessary beneficial ownership information for customer due diligence, and any fee for access may not exceed the actual cost of making the information available. (Act No 82/2019 on the registration of beneficial owners, Art. 7, 8, 10)
Any natural or legal person that can demonstrate a legitimate interest in the prevention and combating of money laundering, its predicate offences and terrorist financing has access to the following information on beneficial owners of legal entities and legal arrangements held in the interconnected central registers, without alerting the legal entity or legal arrangement concerned: the name of the beneficial owner; the month and year of birth of the beneficial owner; the country of residence and nationality or nationalities of the beneficial owner; for beneficial owners of legal entities, the nature and extent of the beneficial interest held; for beneficial owners of express trusts or similar legal arrangements, the nature of the beneficial interest.	Yes. For legal entities, access is granted to the public without a legitimate-interest test; for trust funds and comparable entities, access rules are narrower, referring to any natural person or legal person that can demonstrate legally protected interests.. (Act No 82/2019 on the registration of beneficial owners, Art. 7, 8)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	No. The law does not deem journalists or media actors to have legitimate interest; it only grants public access for legal entities and separate access rules for trust funds and comparable entities. (Act No 82/2019 on the registration of beneficial owners, Art. 7, 8)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: civil society organisations, including non-governmental organisations and academia, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	No. The law does not deem civil-society organisations or academia to have legitimate interest; it only grants public access for legal entities and separate access rules for trust funds and comparable entities. (Act No 82/2019 on the registration of beneficial owners, Art. 7, 8)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: natural or legal persons likely to enter into a transaction with a legal entity or legal arrangement and who wish to prevent any link between such a transaction and money laundering, its predicate offences or terrorist financing;	No. The law allows certain written requests relating to trust funds or comparable entities with controlling interests, but it does not create a deemed legitimate-interest category for prospective transaction counterparties. (Act No 82/2019 on the registration of beneficial owners, Art. 8)
The following natural or legal persons shall be deemed to have a legitimate interest to access the information listed above: Member States’ public authorities in the context of public procurement procedures, in respect of the tenderers and operators being awarded the contract under the public procurement procedure;	No. Absent from legal framework
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: persons acting for the purpose of journalism, reporting or any other form of expression in the media, that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing;	No. Absent from legal framework
Member States shall ensure that the information provided by central registers does not lead to the identification of any person consulting the register where such persons are: civil society organisations that are connected with the prevention or combating of money laundering, its predicate offences or terrorist financing.	No. Absent from legal framework
Where entities in charge of central registers decide to grant access to beneficial ownership information, they shall issue a certificate granting access for 3 years. Entities in charge of central registers shall respond to any subsequent request to access beneficial ownership information by the same person within 7 working days.	No. Absent from legal framework
Member States shall ensure that entities in charge of central registers shall only refuse a request to access beneficial ownership information on one of the following grounds: the applicant has not provided the necessary information or documents pursuant to paragraph 1; a legitimate interest to access beneficial ownership information has not been demonstrated; where on the basis of information in its possession, the entity in charge of the central register has a reasonable concern that the information will not be used for the purposes for which it was requested or that the information will be used for purposes that are not connected to the prevention of money laundering, its predicate offences or terrorist financing; one or more of the situations referred to in Article 15 applies; the legitimate interest to access beneficial ownership information granted by the central register of another Member State does not extend to the purposes for which the information is sought; where the applicant is in a third country and responding to the request to access information would not comply with the provisions of Chapter V of Regulation (EU) 2016/679.	No. Absent from legal framework
In exceptional circumstances to be laid down in national law, where the access to beneficial ownership information would expose the beneficial owner to disproportionate risk of fraud, kidnapping, blackmail, extortion, harassment, violence or intimidation, or where the beneficial owner is a minor or otherwise legally incapable, Member States shall provide for an exemption from such access to all or part of the personal information on the beneficial owner. Member States shall ensure that such exemptions are granted on a case-by-case basis upon a detailed evaluation of the exceptional nature of the circumstances and confirmation that those disproportionate risks exist. The right to an administrative review of the decision granting an exemption and the right to an effective judicial remedy shall be guaranteed.	No. Access may be restricted for children and other legally incapable persons, but the law does not provide the broader disproportionate-risk exemption and review regime described in the indicator. (Act No 82/2019 on the registration of beneficial owners, Art. 9)
Supervision of obliged entities
Each Member State shall ensure that all obliged entities established in its territory are subject to adequate and effective supervision. To that end, each Member State shall appoint one or more supervisors to monitor effectively, and to take the measures necessary to ensure compliance by the obliged entities with Regulations (EU) 2024/1624 and (EU) 2023/1113.	Yes. The Financial Supervisory Authority monitors that the parties specified in par. 1 (a-k) of Art. 2 of Act no. 140/2018 conduct themselves in accordance with the act's provisions. This involves, for example, financial institutions, payment institutions electronic money companies and pension funds. The Directorate of Internal Revenue operates the Register of Companies and monitors that the parties specified in par. (l-s) of Art. 2 of Act no. 140/2018 adhere to provisions of the act. This involves, for example, the gaming sector, accounting firms, law firms, and realtors. It also supervises public benefit associations pursuant to the Act on the Registration Obligation of Public Benefit Associations with Cross-Border Activities, No. 119/2019 , with regard to money laundering and terrorist financing. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 38)
Financial Intelligence Units (FIUs)
Each Member State shall establish an FIU in order to prevent, detect and effectively combat money laundering and terrorist financing.	Yes. Iceland’s Financial Intelligence unit is an independent unit within the District Prosecutors Office (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism)
The FIU as the central national unit shall be responsible for receiving and analysing suspicious transaction reports and other information relevant to money laundering, associated predicate offences or terrorist financing.	Yes. The Police Financial Intelligence Unit receives reports of transactions where there is suspicion of money laundering or terrorist financing. The Police Financial Intelligence Unit is responsible for analyzing the reports received, obtaining necessary additional information and communicating the analysis to the competent authorities. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 20)
The FIU shall be responsible for disseminating the results of its analyses and any additional relevant information to the competent authorities where there are grounds to suspect money laundering, associated predicate offences or terrorist financing.	Yes. The Police Financial Intelligence Unit is responsible for analyzing the reports received, obtaining necessary additional information and communicating the analysis to the competent authorities. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 20)
The FIU shall be operationally independent and autonomous, which means that the FIU shall have the authority and capacity to carry out its functions freely, including the ability to take autonomous decisions to analyse, request and disseminate specific information. It shall be free from any undue political, government or industry influence or interference.	No. The government describes the FIU as being an independent administrative unit within the District Prosecutor's Office, but there is no clear binding statutory provision expressly stating that status.
The FIU, regardless of their organisational status, is authorised to have access to the information that they require to fulfil their tasks, including financial, administrative and law enforcement information.	Yes. In connection with the analysis and examination of cases pursuant to this Act and the regulations and rules issued on their basis, individuals, legal entities, public entities, trust funds and similar entities are obliged to provide the Police Financial Intelligence Unit without delay with all information and data it deems necessary. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 20)
FIUs are empowered to take urgent action, directly or indirectly, where there is a suspicion that a transaction is related to money laundering or terrorist financing, to suspend or withhold consent to that transaction.	Yes. The Police Financial Intelligence Unit may instruct parties subject to the reporting obligation not to carry out or to suspend transactions where there is suspicion of money laundering or terrorist financing while the analysis is being carried out and the information is being communicated to the relevant authorities pursuant to [Article 40]. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 20)
Mutual legal assistance (MLA) and International Cooperation
Member States shall ensure that the FIU to whom the request is made is legally required to use the whole range of its available powers which it would normally use domestically for receiving and analysing information when it replies to a request for information from another FIU.	Yes. The Police Financial Intelligence Unit shall use all the authorities it has under the law to assist with a request made pursuant to paragraph 1, including by obtaining information from parties subject to reporting obligations if applicable. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 42)
Member States shall ensure that FIUs are legally required to exchange, spontaneously or upon request, any information that may be relevant for the processing or analysis of information by the FIU related to money laundering, its predicate offences, or terrorist financing, and the natural or legal person involved, regardless of the type of predicate offences that may be involved, and even if the type of predicate offences that may be involved is not identified at the time of the exchange.	Yes. Notwithstanding the obligation of confidentiality, the Police Financial Intelligence Unit shall, on its own initiative or at the request of a sister institution in a Member State, work with and share as soon as possible relevant information on the handling or analysis of cases related to money laundering or terrorist financing, as well as information on individuals or legal entities related to them. Information shall be shared regardless of the type of predicate offence and whether information about it is available. Such information may only be provided on the condition that it is subject to confidentiality in the relevant state or institution. (Act No. 140/2018 on Anti Money Laundering and Countering Financing of Terrorism, Art. 42)

Legislation

Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011	missing file:
Law No.‌ 90/‌2003 on Income Tax, amended 2016	missing file:
Act on Parlimentary Elections to the Althing, No. 24/2000	missing file:
Penal Code, 1940, amended 2015	missing file:
Rules on the Financial Accounts of Political Parties, 2007	missing file:

*Last update: 2017

Asset Recovery

Quantitative Data
Qualitative Data
Laws

Quantitative Data

Primary Metric	2012	2015	2016	2017	2020	2024	Trend
Asset Offices						0
Confiscation						56
International cooperation						50

Values lie in range between 0 and 100, higher values implying higher legislation comprehensiveness

Qualitative Data

Country score
Asset Offices
Each Member State shall legally designate at least one asset recovery office to facilitate cross-border cooperation in relation to asset-tracing investigations and to conduct asset recovery functions in both criminal matters and civil or administrative matters.	No. Iceland has competent police and prosecutorial authorities handling tracing and confiscation of criminal assets, but no specific “Asset Recovery Office” is designated in law in the EU ARO (Code of Criminal Procedure No. 88/2008, general provisions on investigation and prosecution (no explicit ARO provision).)
Each Member State shall legally designate at least one competent authority to function as an asset management office for the purpose of the management of frozen and confiscated property until the disposal of that property further to a final confiscation order.	No. Confiscated assets are transferred to the State, and their management follows general rules on state property; (General Penal Code No. 19/1940, Articles 69 and 69 b (confiscated property); general State Finance/Property Acts (no specific asset management office).)
Confiscation
Member States shall take the necessary measures to enable the freezing of property necessary to ensure a possible confiscation of that property. The freezing measures shall consist of freezing orders and immediate action. (Freezing measures)	Yes. The Code of Criminal Procedure allows seizure of property, including documents and other items, where there is reason to believe that such property may be confiscated or is important for the case, (Code of Criminal Procedure No. 88/2008, Articles 68–72 (seizure of property and related measures).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of instrumentalities and proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Conviction based confiscation)	Yes. The General Penal Code provides that gains derived from an offence, as well as items used to commit an offence or intended for such use, (General Penal Code No. 19/1940, Article 69 (confiscation of gains) and Article 69 a (confiscation of instruments and products of an offence).)
Member States shall take the necessary measures to enable the confiscation of property the value of which corresponds to instrumentalities or proceeds stemming from a criminal offence subject to a final conviction, which may also result from proceedings in absentia. (Confiscation of equivalent value)	Yes. Where gains from an offence cannot be confiscated in their original form, (General Penal Code, Article 69 (gains or a sum partly or fully equivalent to them may be confiscated).)
Member States shall take the necessary measures to enable the confiscation of proceeds, or other property the value of which corresponds to proceeds, which, directly or indirectly, were transferred by a suspected or accused person to third parties, or which were acquired by third parties from a suspected or accused person. (Third-party confiscation)	Yes. Confiscation may apply to items purchased with gains from an offence and to gains that have been intermingled with other assets, (General Penal Code, Article 69 (confiscation of items purchased with gains and gains intermingled with other assets up to the value of the profits).)
Member States shall take the necessary measures to enable the confiscation, either wholly or in part, of property belonging to a person convicted of a criminal offence where the offence committed is liable to give rise, directly or indirectly, to economic benefit, and where a national court is satisfied that the property is derived from criminal conduct. (Extended confiscation)	Yes. Confiscation covers gains derived from an offence and items purchased with such gains, (General Penal Code, Article 69 (confiscation of gains, including when the original offence was committed abroad and irrespective of the perpetrator).)
Member States shall take the necessary measures to enable the confiscation of instrumentalities, proceeds or property, or proceeds or property transferred to third parties, where criminal proceedings have been initiated but could not be continued because of illness, absconding, or death of the accused or the limitation period of the offence is below 15 years and has expired. (Non-conviction based confiscation)	No. Confiscation is regulated as a criminal measure in connection with criminal proceedings; there is no general statutory regime for non‑conviction (General Penal Code, Articles 69–69 b; Code of Criminal Procedure No. 88/2008 (no general non‑conviction based confiscation regime).)
Confiscation without a prior conviction shall be limited to cases where, in the absence of the circumstances above, it would have been possible for the relevant criminal proceedings to lead to a criminal conviction for, at least, offences liable to give rise, directly or indirectly, to substantial economic benefit, and where the national court is satisfied that the instrumentalities, proceeds or property to be confiscated are derived from, or directly or indirectly linked to, the criminal offence in question. (Non-conviction based confiscation)	No. Icelandic law does not provide a separate non‑conviction based confiscation regime; (General Penal Code, Articles 69–69 b; Code of Criminal Procedure No. 88/2008 (no NCB confiscation).)
Member States shall take the necessary measures to enable the confiscation of property identified in the context of an investigation in relation to a criminal offence, provided that a national court is satisfied that the identified property is (i) derived from criminal conduct committed within the framework of a criminal organisation and (ii) that conduct is liable to give rise, directly or indirectly, to substantial economic benefit. A ‘criminal offence’ in this case is punishable by deprivation of liberty of a maximum of at least four years. (Confiscation of unexplained wealth)	No. There is no specific unexplained‑wealth confiscation regime; (General Penal Code, Article 69; no separate unexplained‑wealth)
Member States are legally required to adopt a national strategy on asset recovery and update it at regular intervals of no longer than five years. (Deadline of 24 May 2027)	No. Iceland had not enacted, by 31.12.2024, a dedicated national asset recovery strategy with a mandatory five‑year (No explicit national asset recovery strategy provision identified in the General Penal Code, Code of Criminal Procedure)
International cooperation
To facilitate cross-border cooperation, Member States shall legally require measures to enable the swift tracing and identification of instrumentalities and proceeds, or of property which is, or might become, the object of a freezing or confiscation order in the course of proceedings in criminal matters.	Yes. Iceland’s mutual legal assistance procedures allow search, seizure and confiscation of proceeds of crime at the request of foreign states, based on the Council of Europe Convention. (National procedures for mutual legal assistance implementing the European Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime (ETS No. 141), including search,)
Member States shall legally require the necessary measures to ensure that their asset recovery offices provide, upon request from an asset recovery office in another Member State, any information that those asset recovery offices have access to, and that is necessary for the performance of the tasks of the asset recovery office requesting that information	No. Although Iceland cooperates on mutual legal assistance and confiscation, there is no formally designated asset recovery office with a statutory information‑exchange mandate equivalent to the EU ARO (National mutual legal assistance framework (no explicit ARO designation).)
Member States may legally allow for cost-sharing agreements with other Member States on the execution of freezing and confiscation orders.	No. Icelandic legislation on mutual legal assistance does not provide a specific rule on cost‑sharing (National mutual legal assistance provisions implementing ETS No. 141 (no explicit cost‑sharing clause).)
Countries should be able to share confiscated property with other countries, in particular when confiscation is directly or indirectly a result of co-ordinated law enforcement actions	Yes. Iceland may share confiscated property with foreign states in accordance with Council of Europe (National implementation of the European Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime (ETS No. 141),)

Legislation

Act on the Finances of Political Organisations and Candidates and their Information Disclosure 2006, amended 2011	missing file:
Law No.‌ 90/‌2003 on Income Tax, amended 2016	missing file:
Act on Parlimentary Elections to the Althing, No. 24/2000	missing file:
Penal Code, 1940, amended 2015	missing file:
Rules on the Financial Accounts of Political Parties, 2007	missing file:

*Last update: 2017

Iceland

Country Facts

Political Financing

Quantitative Data

Primary Metric

Qualitative Data

Bans and limits on private income

Public funding

Regulations on spending

Reporting, oversight and sanctions

Institutions receiving financial reports from political parties and/​or candidates

Is it specified that a particular institution(s) is responsible for examining financial reports and/​or investigating violations?

Other institutions with a formal role in political finance oversight

Sanctions for political finance infractions

Legislation

Financial Disclosure

Quantitative Data

Primary Metric

Alternative Metric

Qualitative Data

Head of State

Disclosure items

Income and Assets

Incompatibilities

Filing frequency

Sanctions

Monitoring and Oversight

Public access to declarations

Ministers

Disclosure items

Income and Assets

Incompatibilities

Filing frequency

Sanctions

Monitoring and Oversight

Public access to declarations

Members of Parliament

Disclosure items

Income and Assets

Incompatibilities

Filing frequency

Sanctions

Monitoring and Oversight

Public access to declarations

Civil servants

Disclosure items

Income and Assets

Incompatibilities

Filing frequency

Sanctions

Monitoring and Oversight

Public access to declarations

Legislation

Conflict of Interest

Quantitative Data

Primary Metric

Alternative Metric

Qualitative Data

Head of State

Restrictions

Sanctions

Monitoring and Oversight

Ministers

Restrictions

Sanctions

Monitoring and Oversight

Members of Parliament

Restrictions

Sanctions

Monitoring and Oversight

Civil servants

Restrictions

Sanctions

Monitoring and Oversight

Legislation

Freedom of Information

Quantitative Data

Primary Metric

Qualitative Data

Scope and Coverage

Institutions receiving financial reports from political parties and/or candidates

Is it specified that a particular institution(s) is responsible for examining financial reports and/or investigating violations?