Iceland

Country score (European Average*)

66(66) Political Financing
27(53) Financial Disclosure
14(37) Conflict of Interest
42(59) Freedom of Information
53(62) Public Procurement

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
Bans and limits on private income	69	69	69	69	69
Public funding	62	62	62	62	62
Regulations on spending	50	50	50	50	50
Reporting, oversight and sanctions	75	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
Bans on donations from foreign interests
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 )
Bans on corporate donations
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 )
Bans on donations from trade unions
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
Bans on anonymous donations
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 )
Other bans on donations
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
Donation limits
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
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
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
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
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?
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
Reporting standards
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
Political finance oversight
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	Trend
Disclosure items	15	12	12	12	21
Filing frequency	25	25	25	25	38
Sanctions	0	0	0	0	0
Monitoring and Oversight	12	19	19	19	38
Public access to declarations	12	12	12	12	38
Alternative Metric	2012	2015	2016	2017	2020	Trend
Head of State	0	0	0	0	0
Ministers	19	17	17	17	53
Members of Parliament	33	38	38	38	53
Civil servants	0	0	0	0	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. (General)
Income and Assets
Real estate	No. Absent from legal framework. (General)
Movable assets	No. Absent from legal framework. (General)
Cash	No. Absent from legal framework. (General)
Loans and Debts	No. Absent from legal framework. (General)
Income from outside employment/assets	No. Absent from legal framework. (General)
Incompatibilities
Gifts received as a public official	No. Absent from legal framework. (General)
Private firm ownership and/or stock holdings	No. Absent from legal framework. (General)
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework. (General)
Holding government contracts	No. Absent from legal framework. (General)
Board member, advisor, or company officer of private firm	No. Absent from legal framework. (General)
Post-employment	No. Absent from legal framework. (General)
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework. (General)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework. (General)
Concurrent employment of family members in public sector	No. Absent from legal framework. (General)
Filing frequency
Filing required upon taking office	No. Absent from legal framework. (General)
Filing required upon leaving office	No. Absent from legal framework. (General)
Filing required annually	No. Absent from legal framework. (General)
Ad hoc filing required upon change in assets or conflicts of interest	No. Absent from legal framework. (General)
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
Monitoring and Oversight
Depository body explicitly identified	No. Absent from legal framework. (General)
Enforcement body explicitly identified	No. Absent from legal framework. (General)
Some agency assigned responsibility for verifying submission	No. Absent from legal framework. (General)
Some agency assigned responsibility for verifying accuracy	No. Absent from legal framework. (General)
Public access to declarations
Public availability	No. Absent from legal framework. (General)
Timing of information release specified	No. Absent from legal framework. (General)
Location(s) of access specified	No. Absent from legal framework. (General)
Cost of access specified	No. Absent from legal framework. (General)
Ministers
Disclosure items
Spouses and children included in disclosure	No. Absent from legal framework. (General)
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 (2020))
Movable assets	No. Absent from legal framework. (General)
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 (2020))
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 (2020))
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 (2020))
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 (2020))
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 (2020))
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 (2020))
Holding government contracts	No. Absent from legal framework. (General)
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 (2020))
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 (2020))
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework. (General)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework. (General)
Concurrent employment of family members in public sector	No. Absent from legal framework. (General)
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 (2020))
Filing required upon leaving office	No. Absent from legal framework. (General)
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 (2020))
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 (2020))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
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 (2020))
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 (2020))
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 (2020))
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 (2020))
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 (2020))
Cost of access specified	No. Absent from legal framework. (General)
Members of Parliament
Disclosure items
Spouses and children included in disclosure	No. Absent from legal framework. (General)
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 (2020))
Movable assets	No. Absent from legal framework. (General)
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 (2020))
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 (2020))
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 (2020))
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 (2020))
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 (2020))
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 (2020))
Holding government contracts	No. Absent from legal framework. (General)
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 (2020))
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 (2020))
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework. (General)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework. (General)
Concurrent employment of family members in public sector	No. Absent from legal framework. (General)
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 (2020))
Filing required upon leaving office	No. Absent from legal framework. (General)
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 (2020))
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 (2020))
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
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 (2020))
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 (2020))
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 (2020))
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 (2020))
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 (2020))
Cost of access specified	No. Absent from legal framework. (General)
Civil servants
Disclosure items
Spouses and children included in disclosure	No. Absent from legal framework. (General)
Income and Assets
Real estate	No. Absent from legal framework. (General)
Movable assets	No. Absent from legal framework. (General)
Cash	No. Absent from legal framework. (General)
Loans and Debts	No. Absent from legal framework. (General)
Income from outside employment/assets	No. Absent from legal framework. (General)
Incompatibilities
Gifts received as a public official	No. Absent from legal framework. (General)
Private firm ownership and/or stock holdings	No. Absent from legal framework. (General)
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework. (General)
Holding government contracts	No. Absent from legal framework. (General)
Board member, advisor, or company officer of private firm	No. Absent from legal framework. (General)
Post-employment	No. Absent from legal framework. (General)
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework. (General)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework. (General)
Concurrent employment of family members in public sector	No. Absent from legal framework. (General)
Filing frequency
Filing required upon taking office	No. Absent from legal framework. (General)
Filing required upon leaving office	No. Absent from legal framework. (General)
Filing required annually	No. Absent from legal framework. (General)
Ad hoc filing required upon change in assets or conflicts of interest	No. Absent from legal framework. (General)
Sanctions
Sanctions stipulated for late filing (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
Sanctions stipulated for non-filing (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
Sanctions stipulated for false disclosure (fines, administrative, and/or criminal)	No. Absent from legal framework. (General)
Monitoring and Oversight
Depository body explicitly identified	No. Absent from legal framework. (General)
Enforcement body explicitly identified	No. Absent from legal framework. (General)
Some agency assigned responsibility for verifying submission	No. Absent from legal framework. (General)
Some agency assigned responsibility for verifying accuracy	No. Absent from legal framework. (General)
Public access to declarations
Public availability	No. Absent from legal framework. (General)
Timing of information release specified	No. Absent from legal framework. (General)
Location(s) of access specified	No. Absent from legal framework. (General)
Cost of access specified	No. Absent from legal framework. (General)

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	Trend
Restrictions	18	18	18	18	18
Sanctions	0	0	0	0	0
Monitoring and Oversight	25	25	25	25	25
Alternative Metric	2012	2015	2016	2017	2020	Trend
Head of State	10	10	10	10	10
Ministers	47	43	43	43	47
Members of Parliament	0	0	0	0	0
Civil servants	0	3	3	3	0

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. (General)
Accepting gifts	No. Absent from legal framework. (General)
Private firm ownership and/or stock holdings	No. Absent from legal framework. (General)
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework. (General)
Holding government contracts	No. Absent from legal framework. (General)
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. (Article 9 Constitution of the Republic of Iceland (1944, last amended 1999) )
Post-employment	No. Absent from legal framework. (General)
Simultaneously holding policy-making position and policy-executing position	Yes. The President of the Republic may not be a Member of Althingi. (Article 9 Constitution of the Republic of Iceland (1944, last amended 1999) )
Participating in official decision-making processes that affect private interests	Yes. The President of the Republic may not be a Member of Althingi or accept paid employment in the interest of any public institution or private enterprise. (Article 9 Constitution of the Republic of Iceland (1944, last amended 1999) )
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework. (General)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework. (General)
Enforcement body specified (sanctions, hearings)	No. Absent from legal framework. (General)
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. (Article 2 Ministerial Code of Conduct (regulation no. 360/2011))
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. (Article 3(d) Ministerial Code of Conduct (regulation no. 360/2011))
Private firm ownership and/or stock holdings	No. Absent from legal framework. (General)
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework. (General)
Holding government contracts	No. Absent from legal framework. (General)
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. (Article 3(a) Ministerial Code of Conduct (regulation no. 360/2011))
Post-employment	No. Absent from legal framework. (General)
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. (Article 51 Constitution of the Republic of Iceland (1944, last amended 1999) )
Participating in official decision-making processes that affect private interests	No. Absent from legal framework. (General)
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework. (General)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	Yes. Althing Secretariat, the Prime Minister: In consultation with the Cabinet, the Prime Minister may decide to call systematically for more information on ministers' shared interests which would be revealed to the general public (for information tracking) and the Coordinating Committee for Public Administration Ethics to provide guidance. (Article 2(c) Ministerial Code of Conduct (regulation no. 360/2011) Article 8(a) Ministerial Code of Conduct (regulation no. 360/2011))
Enforcement body specified (sanctions, hearings)	Yes. Coordinating Committee for Public Administration Ethic shall promote coordinated responses to any information on infringements of conduct codes or on risks of corruption within the national government. (Article 8(a) Ministerial Code of Conduct (regulation no. 360/2011))
Members of Parliament
Restrictions
General restriction on conflict of interest	No. Absent from legal framework. (General)
Accepting gifts	No. Absent from legal framework. (General)
Private firm ownership and/or stock holdings	No. Absent from legal framework. (General)
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework. (General)
Holding government contracts	No. Absent from legal framework. (General)
Board member, advisor, or company officer of private firm	No. Absent from legal framework. (General)
Post-employment	No. Absent from legal framework. (General)
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework. (General)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework. (General)
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework. (General)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework. (General)
Enforcement body specified (sanctions, hearings)	No. Absent from legal framework. (General)
Civil servants
Restrictions
General restriction on conflict of interest	No. Absent from legal framework. (General)
Accepting gifts	No. Absent from legal framework. (General)
Private firm ownership and/or stock holdings	No. Absent from legal framework. (General)
Ownership of state-owned enterprises (SOEs)	No. Absent from legal framework. (General)
Holding government contracts	No. Absent from legal framework. (General)
Board member, advisor, or company officer of private firm	No. Absent from legal framework. (General)
Post-employment	No. Absent from legal framework. (General)
Simultaneously holding policy-making position and policy-executing position	No. Absent from legal framework. (General)
Participating in official decision-making processes that affect private interests	No. Absent from legal framework. (General)
Assisting family or friends in obtaining employment in public sector	No. Absent from legal framework. (General)
Sanctions
Fines are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Administrative sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Penal sanctions are stipulated for violations of COI regulations restricting behavior	No. Absent from legal framework. (General)
Monitoring and Oversight
Monitoring body specified (guidance, training, data tracking)	No. Absent from legal framework. (General)
Enforcement body specified (sanctions, hearings)	No. Absent from legal framework. (General)

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
Scope and Coverage	69	87	87	87	100
Information access and release	42	25	25	25	42
Exceptions and Overrides	50	50	50	50	50
Sanctions for non-compliance	33	0	0	0	0
Monitoring and Oversight	17	17	17	17	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 2019)
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. (Act 123 on Public Finances, 2015 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. (General)
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. (General)
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. (General)
Existence of personal privacy/data law	Yes. There is a data protection law and the Constitution provides for a right to privacy. (Act on Personal Data Protection and Processing of Personal Data of 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. Other instances are: national security; land defense; public safety; to prevent, investigate, prosecute or prosecute criminal offenses or to enforce criminal sanctions, including protecting against and preventing threats to public safety; other important public interest objectives, in particular economic or financial, including foreign exchange, budgetary and fiscal matters, public health and social security; the protection of the data subject, the overriding public interest or the fundamental rights of others; the fulfillment of private law requirements; legal provisions on confidentiality. 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 2019 Article 17 Act on Personal Data Protection and Processing of Personal Data of 2018 Article 17 Administrative Procedures Act No. 37/1993, amended 2020)
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. (General)
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. (General)
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. (General)
Criminal sanctions are specified for violations of disclosure requirements	No. Absent from legal framework. (General)
Monitoring and Oversight
Information officers must be appointed in public agencies	No. Absent from legal framework. (General)
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. (General)
Nodal agency for RTI (implementation support/compliance within public sector). Does not include Ombudsman.	No. Absent from legal framework. (General)
Ombudsman involvement in implementation is specified by law	No. Absent from legal framework. (General)
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
Scope	73	70	72	76
Information availability	18	18	18	31
Evaluation	75	75	75	69
Open competition	22	22	56	56
Institutional arrangements	36	36	36	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 15500000. Any public procurement of supplies and services exceeding ISK 15,500,000 and procurement of works exceeding ISK 49,000,000 shall be put up for tender and made in accordance with the procurement procedures stipulated in Chapter IV. Threshold amounts for procurement of public service contracts relating to social services and other specialised services according to Chapter VIII shall comply with paragraph 4. Amounts according to paragraph 1 may be revised every other year in accordance with changes to the consumer price index, the first revision taking effect on 1 January 2018. Additionally, EEA/EU thresholds also apply. (Law No. 120 of 2016, as amended in 2019, Art. 23 Regulation No. 260 of 2020 (as of 2020), Arts. 2 and 3 )
What is the minimum contract value above which the public procurement law is applied? (Product type WORKS)	ISK 49000000. Any public procurement of supplies and services exceeding ISK 15,500,000 and procurement of works exceeding ISK 49,000,000 shall be put up for tender and made in accordance with the procurement procedures stipulated in Chapter IV. Threshold amounts for procurement of public service contracts relating to social services and other specialised services according to Chapter VIII shall comply with paragraph 4. Amounts according to paragraph 1 may be revised every other year in accordance with changes to the consumer price index, the first revision taking effect on 1 January 2018. Additionally, EEA/EU thresholds also apply. (Law No. 120 of 2016, as amended in 2019, Art. 23 Regulation No. 260 of 2020 (as of 2020), Arts. 2 and 3 )
What is the minimum contract value above which the public procurement law is applied? (Product type SERVICES)	ISK 15500000. Any public procurement of supplies and services exceeding ISK 15,500,000 and procurement of works exceeding ISK 49,000,000 shall be put up for tender and made in accordance with the procurement procedures stipulated in Chapter IV. Threshold amounts for procurement of public service contracts relating to social services and other specialised services according to Chapter VIII shall comply with paragraph 4. Amounts according to paragraph 1 may be revised every other year in accordance with changes to the consumer price index, the first revision taking effect on 1 January 2018. Additionally, EEA/EU thresholds also apply. (Law No. 120 of 2016, as amended in 2019, Art. 23 Regulation No. 260 of 2020 (as of 2020), Arts. 2 and 3 )
Threshold - by PP type
What are the minimum application thresholds for the procurement type? (Entity: PUBLIC SECTOR)	ISK 15500000. Any public procurement of supplies and services exceeding ISK 15,500,000 and procurement of works exceeding ISK 49,000,000 shall be put up for tender and made in accordance with the procurement procedures stipulated in Chapter IV. Additionally, EEA/EU thresholds also apply. (Law No. 120 of 2016, as amended in 2019, Art. 23 Regulation No. 260 of 2020 (as of 2020), Arts. 2 and 3 )
What are the minimum application thresholds for the procurement type? (Entity: UTILITIES)	ISK 15500000. Any public procurement of supplies and services exceeding ISK 15,500,000 and procurement of works exceeding ISK 49,000,000 shall be put up for tender and made in accordance with the procurement procedures stipulated in Chapter IV. The provisions of Chapters XI and XII apply to the procurement of entities in charge of water, energy, transport and postal services that exceed the threshold amounts of the regulation issued by the Minister for procurements in this field. Otherwise the Public Procurement Law does not cover such procurements if contracts are awarded on account of water suppliers, energy suppliers, transport and postal services. Additionally, EEA/EU thresholds also apply. (Law No. 120 of 2016, as amended in 2019, Arts. 9 and 23 Regulation No. 261 of 2020 (as of 2020), Art. 1 )
What are the minimum application thresholds for the procurement type? (Entity: DEFENCE)	ISK 15500000. The Public Procurement Law does not apply to public contracts when they are declared to be secret, or when their performance must be accompanied by special security measures according to current legislation or administrative provisions, or when the protection of the essential interests of the State so requires. However, the provisions of Chapters XI and XII apply to procurement in the field of defence and security that exceed the threshold amounts of a regulation issued by the Minister regarding procurement in the field of defence and security. Hence, any public procurement of supplies and services exceeding ISK 15,500,000 and procurement of works exceeding ISK 49,000,000 shall be put up for tender and made in accordance with the procurement procedures stipulated in Chapter IV. Additionally, EEA/EU thresholds also apply. (Law No. 120 of 2016, as amended in 2019, Arts. 7 and 23 Regulation No. 260 of 2020 (as of 2020), Arts. 2 and 3 )
Threshold - by product type
What are the minimum application thresholds for the procurement type? (Product type GOODS)	ISK 15500000. Any public procurement of supplies and services exceeding ISK 15,500,000 shall be put up for tender and made in accordance with the procurement procedures stipulated in Chapter IV. (Law No. 120 of 2016, as amended in 2019, Art. 23 Regulation No. 260 of 2020 (as of 2020), Arts. 2 and 3 )
What are the minimum application thresholds for the procurement type? (Product type WORKS)	ISK 49000000. Any public procurement of works exceeding ISK 49,000,000 shall be put up for tender and made in accordance with the procurement procedures stipulated in Chapter IV. (Law No. 120 of 2016, as amended in 2019, Art. 23 Regulation No. 260 of 2020 (as of 2020), Arts. 2 and 3 )
What are the minimum application thresholds for the procurement type? (Product type SERVICES)	ISK 15500000. Any public procurement of supplies and services exceeding ISK 15,500,000 shall be put up for tender and made in accordance with the procurement procedures stipulated in Chapter IV. (Law No. 120 of 2016, as amended in 2019, Art. 23 Regulation No. 260 of 2020 (as of 2020), Arts. 2 and 3 )
Information availability
Publishing and record keeping
Is there a requirement that tender documents must published in full?	Yes. The contract notice shall include sufficient information so that economic operators can decide if they wish to take part in the procurement procedures. Furhermore, the contracting authorities shall by electronic means offer unrestricted and full direct access free of charge to the procurement documents from the date of publication of a notice in accordance with Article 51 or the date on which an invitation to confirm interest was sent. In a notice or in an invitation to a participant the confirm interest it must be indicated where it is possible to obtain the procurement documents by electronic means. Tender documents must contain all the information necessary for the tenderer to be able to submit a tender. The following items shall be stated in the tender documents, as applicable: a. description of the tender which stipulates quantities and other relevant matters; b. name of the contracting authority, ID number and all information about communication with the auctioneer; c. presentation of bids; d. list of tender documents; e. bid period and where and when bids will be opened; f. delivery or construction time; g. validity of bids; h. payments, indexation and insurance if applicable; i. evidence to prove the financial and technical capacity that the tenderer must submit or may be required to do, cf. Articles 71 and 72; j. handling inquiries from potential bidders; k. delivery terms; l. in which language or languages bids must be submitted; m. criteria for selection of tenders; n. whether the agreement is divided into parts, cf. Article 53, and how many shares each company may bid for; o. whether alternative offers are permitted and the conditions for making them, including the minimum requirements that such offers must meet; p. Deadline for the buyer to accept an offer. A tender form shall be included with the procurement documents, and it shall be presented in such a manner that all bids are submitted in the same fashion, and may thus be readily compared. The technical specifications shall be set out in the procurement documents. (Law No. 120 of 2016, as amended in 2019, Arts. 2 (27), 47, 48, and 60)
Are any of these documents published online at a central place?	Yes. All procurements by public authorities of supplies, services and works that exceed threshold amounts according to paragraphs 1 and 4 of Article 23, shall be advertised electronically at a common site that the minister shall stipulate through regulations. The national procurement portal, Ríkiskaup, can be found at: https://www.rikiskaup.is/is . In addition any kind of procurements may be advertised in a conspicuous manner so that all interested economic operators will be able to participate in the procurement procedures, cf. however Article 39 and paragraph 2 Article 54. Advertisements and notices regarding procurements that exceed threshold amounts in the European Economic Area, cf. paragraph 4 of Article 23 shall be filled out in a standardised form that is published in regulations issued by the Minister. Announcements and notices must be sent by electronic means to the Publications Office of the European Union and the contracting authority shall be able to demonstrate what day the notice was sent to the Publications Office. (Law No. 120 of 2016, as amended in 2019, Arts. 55, 56 and 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. Above EEA/EU thresholds: the contracting authority shall record the progression of all procurement procedures whether these are electronic or not. For that purpose the contracting authority shall make sure that sufficient documents are kept in order to substantiate any decisions that are taken during all stages of the procurement procedures, such as documents regarding relations with economic operators and internal discussions, the preparation of the procurement documents, dialogue or negotiations, if any, the awarding and making of the contract. The documents shall be stored for at least three years from the date of a decision on awarding the contract. Below EEA/EU thresholds: the Law is silent. (Law No. 120 of 2016, as amended in 2019, Art. 96)
Are contracts awarded within a framework agreement published (ie mini contracts)?	No. (Law No. 120 of 2016, as amended in 2019, Art. 96)
Sub-contracting
Is it mandatory to publish information on subcontractors (ie names) in some cases?	No. The procurement documents must include a compulsory demand that the tenderer provides information on which parts of the contract they plan to make a third party implement as a subcontractor, and such information shall be put forward before the signing of the contract. The tenderer shall inform the contracting authority which subcontractors he plans to employ and seek the approval of the contracting authority before the subcontractor starts working. The contracting authority may at the same time demand that the tenderer provide a declaration of competence according to Article 73 for sub-contractors. If reasons for exclusion according to Article 68 apply to subcontractors the contracting authority shall, as the case may be, demand that a new subcontractor substitute the former. Aside from these requirements, there is no obligation to publish information on subcontractors. (Law No. 120 of 2016, as amended in 2019, 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.	General. ( )
Evaluation
Preferential treatment
Is there a ban on mentioning specific companies or brands in tender specification/call for tender?	Yes. The technical specifications shall be set out in the procurement documents. Unless justified by the subject-matter of the contract, technical specifications shall not refer to a specific make or source, or a particular process, or to trade marks, patents, types or a specific origin or production with the effect of favouring or eliminating certain undertakings or certain products. Such reference shall be permitted on an exceptional basis, where a sufficiently precise and intelligible description of the subject-matter of the contract pursuant to paragraph 4 is not possible; such reference shall be accompanied by the words "or equivalent" or similar wording. (Law No. 120 of 2016, as amended in 2019, Art. 49)
Is there a preferential treatment for small-to-medium enterprises (SMEs)?	No.
Is there a preferential treatment for local/national companies? (companies from other EU MS are considered foreign companies)	No. Equal treatment, proportionality and transparency must be maintained in public procurement. Economic operators may not be discriminated against on grounds of nationality and neither is any unreasonable restricting of competition allowed. Appropriate measures shall be taken to avoid conflicts of interest in the procurement process to ensure non-discrimination. (Law No. 120 of 2016, as amended in 2019, Art. 15)
Is there a specific set of rules for green/sustainable procurement?	Yes. Generally, environmental considerations are among selection criteria, and non-compliance with environmental legislation constitutes grounds for tenderer exclusion. In terms of performance or functional requirements, the latter may include environmental characteristics. Where a contracting authority requires the production of certificates drawn up by independent bodies attesting that the economic operator complies with certain environmental management systems or standards, it shall refer to the Eco-Management and Audit Scheme (EMAS) of the European Union or to other environmental management systems as recognised in accordance with the pertinent regulation or other environmental management standards based on the relevant European or international standards by accredited bodies. (Law No. 120 of 2016, as amended in 2019, Art. 49 (b), 50, 66, 68, 75, 79, 80 and 87)
Bid evaluation
Are there restrictions on allowable grounds for tenderer exclusion?	Yes. Any candidate or tenderer who has been the subject of a conviction by final judgment for the following offences shall be excluded from participation in procurement procedures: a. participation in a criminal organisation; b. corruption; c. fraud; d. terrorist offences or offences linked to terrorist activities; e. money laundering or terrorist financing; f. child labour and other forms of trafficking in human beings. Furthermore, contracting authorities may exclude from participation in a procurement procedure any economic operator in any of the following situations: 1. non-compliance with environmental, social and labour law and collective agreements; 2. bankrupcy; 3. grave professional misconduct on the part of the bidder, proven by any means which the contracting authorities can demonstrate; 4. attempts to distort competition; 5. conflict of interest; 6. significant or persistent deficiencies in the performance of a substantive requirement under a prior public contract, which led to early termination of that prior contract; 7. misrepresentation or withholding of information; and 8. unduly influence on the decision-making process by the bidder. (Law No. 120 of 2016, as amended in 2019, Art. 68)
Are some bids automatically excluded? e.g., lowest/highest price; unusually low price, etc.	Yes. The contracting authority is considered to have rejected an offer if, during negotiations with the bidder, the validity of the offer has expired without a request for an extension, or if all offers have been formally rejected. Moreover, the contracting authority may reject all bids if there are objective reasons for doing so or if the general criteria for the tender have been breached. The decision to reject all offers must be duly justified. Concerning unusually low tenders, the contracting authority can reject an offer if, after requesting clarifications from the bidder, they are not satisfied with reasoning presented. (Law No. 120 of 2016, as amended in 2019, Arts. 81, 82 and 83)
Is scoring criteria published?	Yes. The contracting authority must choose the most economically viable offer on the basis of: 1. lowest price; 2. lowest cost; or 3. best ratio between price and quality. The contracting authority shall specify in the procurement documents the relative weightings of each criterion that forms the basis of the choice of the most economically advantageous tender, except when the choice of a tender is solely based on price. Those weightings can be expressed by providing for a range with a reasonable maximum tolerance. If it is impossible to specify a certain weighting for award criteria due to objective reasons the criteria must be prioritised depending on their importance. (Law No. 120 of 2016, as amended in 2019, Arts. 47 (m) and 79)
Are decisions always made by a committee?	No. In case of a design contest, a jury, which is composed exclusively of natural persons who are independent of participants in the contest, decides. Where a particular professional qualification is required from participants in a contest, at least a third of the members of the jury shall have that qualification or an equivalent qualification. The jury shall be autonomous in its decisions or opinions. In case of other procurement methods, there is no express provision about this matter in Law No. 120 of 2016 on Public Procurement. (Law No. 120 of 2016, as amended in 2019, Art. 44)
Are there regulations on evaluation committee composition to prevent conflict of interest?	Yes. Non-discrimination, proportionality and transparency shall be observed in public procurement. Companies may not be discriminated against on the basis of nationality or have competition restricted in an unreasonable manner. Appropriate measures shall be taken to avoid conflicts of interest in the procurement process to ensure non-discrimination. (Law No. 120 of 2016, as amended in 2019, Arts. 15, 68 (f) and 96 (i))
Is some part of evaluation committee mandatorily independent of contracting authority?	No. For design contests, the jury shall be autonomous in its decisions or opinions. It shall examine the plans and projects submitted by the candidates solely on the basis of the criteria indicated in the contest notices. It shall record its ranking of projects in a report, signed by all of its members, made according to the merits of each project, together with its remarks and any points which may need clarification. However, for other procurement there is no specificaton on who should evaluate the tender. (Law No. 120 of 2016, as amended in 2019, Art. 44)
Are scoring results publicly available?	No. Such information is not made publicly available. (Law No. 120 of 2016, as amended in 2019, Art. 85)
Does the law specify under which conditions the tender can be cancelled?	No. Law No. 120 of 2016 does not specify under which conditions the tender can be cancelled.
Open competition
CFT publication
Does the law specify the location for publicizing open calls for tenders?	Yes. All procurements by public authorities of supplies, services and works that exceed threshold amounts according to paragraphs 1 and 4 of Article 23, shall be advertised electronically at: http://utbodsvefur.is/. In addition, announcements and notices must be sent by electronic means to the Publications Office of the European Union (OJEU/TED). (Law No. 120 of 2016, as amended in 2019, Arts. 55 and 56 Regulation No. 260 of 2020, Art. 1)
Does the law specify the location for publicizing restricted calls for tenders?	Yes. All procurements by public authorities of supplies, services and works that exceed threshold amounts according to paragraphs 1 and 4 of Article 23, shall be advertised electronically at: http://utbodsvefur.is/. In addition, announcements and notices must be sent by electronic means to the Publications Office of the European Union (OJEU/TED). (Law No. 120 of 2016, as amended in 2019, Arts. 55 and 56 Regulation No. 260 of 2020, Art. 1)
Does the law specify the location for publicizing negotiated calls for tenders?	Yes. All procurements by public authorities of supplies, services and works that exceed threshold amounts according to paragraphs 1 and 4 of Article 23, shall be advertised electronically at: http://utbodsvefur.is/. In addition, announcements and notices must be sent by electronic means to the Publications Office of the European Union (OJEU/TED). (Law No. 120 of 2016, as amended in 2019, Arts. 55 and 56 Regulation No. 260 of 2020, Art. 1)
Minimum # of bidders
What is the minimum number of bidders for restricted procedures?	General. (Law No. 120 of 2016, as amended in 2019, Art. 78)
What is the minimum number of bidders for negotiated procedures?	General. (Law No. 120 of 2016, as amended in 2019, Art. 78)
What is the minimum number of bidders for competitive dialogue procedures?	General. (Law No. 120 of 2016, as amended in 2019, Art. 78)
Bidding period length
What are the minimum number of days for open procedures?	General. National threshold: 15 calendar days; Above EEA/EU thresholds: 35 calendar days. If there is an urgent need to accelerate the tender procedure the contracting authority may derogate from the time limits that are stated in this provision. However, the time limit for submitting tenders may never be shorter than 7 calendar days in the first case and 15 calendar days (from the publication of the notice) in the second case. (Law No. 120 of 2016, as amended in 2019, Art. 58)
What are the minimum number of days for restricted procedures?	General. National threshold: 10 calendar days; Above EEA/EU thresholds: 30 calendar days. However, the offer deadline may be shortened by five days if an electronic offer may be submitted in accordance with Article 22. It is also permitted to shorten the offer deadline to 10 calendar days when the preliminary advertisement according to Art. Article 54 has been published at least 35 days before and at most 12 months before the publication of the general advertisement. (Law No. 120 of 2016, as amended in 2019, Art. 59)
What are the minimum number of days for competitive negotiated procedures?	General. National threshold: 10 calendar days; Above EEA/EU thresholds: 30 calendar days. However, the offer deadline may be shortened by five days if an electronic offer may be submitted in accordance with Article 22. It is also permitted to shorten the offer deadline to 10 calendar days when the preliminary advertisement according to Art. Article 54 has been published at least 35 days before and at most 12 months before the publication of the general advertisement. (Law No. 120 of 2016, as amended in 2019, Art. 59)
Institutional arrangements
Institutions and regulations
Does the law specify the main EXCEPTIONS preventing the application of the public procurement law for tenders/organisations?	Yes. Main exceptions include, inter alia: 1. certain mixed contracts; 2. mixed and secret contracts in the defence and security sector; 3. contracts concluded on the basis of international agreements; 4. specific contracts in the utilities sector; 5. contracts in the field of electronic communications; 6. contracts connected to real estate; radio and tv broadcasting; 7. arbitration contracts; 8. legal services and litigation; 9. financial services; 10. employment contracts; 11. passenger transport contracts; 12. contracts connected to political parties and campaigns; 13. research and development. (Law No. 120 of 2016, as amended in 2019, Arts. 5-13)
Does the law specify the main types of institutions that must apply the public procurement law?	Yes. Public authorities: the State, local authorities, their institutions and other public entities, associations formed by one or more of such authorities. An entity is considered public if it is governed by public law and if it has been established for the specific purpose of meeting needs in the general interest, provided it does not conduct operations that may be compared with the operation of private entities, such as in the field of business or industry. (Law No. 120 of 2016, as amended in 2019, Art. 3)
Does the law specify the main procedure types or procurement methods permitted?	Yes. Open procedure, restricted procedure, negotiated procedure, competitive dialogue, innovative partnership and design contest (Law No. 120 of 2016, as amended in 2019, Arts. 2 and 33-39)
Is there a procurement arbitration court dedicated to public procurement cases?	Yes. Public Procurement Complaints Committee (Law No. 120 of 2016, as amended in 2019, Art. 103)
Is there a procurement regulatory body dedicated to public procurement?	Yes. Ríkiskaup (Central Public Procurement), which is a central purchasing authority in Ministry of Finance. Found at: https://www.rikiskaup.is/is (Law No. 120 of 2016, as amended in 2019. Arts. 99 and 122 Regulation No. 755 of 2019 (as of 2020), Art. 2)
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. Concerning design contests, where a particular professional qualification is required from participants in a contest, at least a third of the members of the jury shall have that qualification or an equivalent qualification. Additionally, the Public Procurement Complaints Committee consists of three members and an equal number of alternates appointed by the Minister following the nomination of the Supreme Court for four years at a time. Two members of the committee and their deputies shall meet the legal requirements for the office of district judge, and one of them shall be the chairman of the committee. The third member of the committee and his alternate shall have comprehensive experience and knowledge of business. Committee members shall be independent of the interests of the state and other public bodies. However, the Law does not specify procurement advisors' professions and their role in the tendering process. (Law No. 120 of 2016, as amended in 2019, Arts. 44 and 103)
Is disclosure of final, beneficial owners required for placing a bid?	No. (No mention in the law)
Complaints
Is there a fee for arbitration procedure?	Yes. For each complaint there is a complaints fee of ISK 150,000. (Law No. 120 of 2016, as amended in 2019, Art. 106)
Is there a ban on contract signature until arbitration court decision (first instance court)?	Yes. If a complaint regarding a decision to award a contract is lodged within the statutory standstill period, according to Article 86, then the awarding of the contract is not permitted until the Complaints Commission has finally resolved the complaint. The automatic halt of the awarding of the contract because of a complaint becomes activated when the contracting authority should know about the complaint, whether it is because of the notice from the complainant according to paragraph 2 of Article 106, or because of the notice from the Complaints Commission according to paragraph 1 of Article 108. (Law No. 120 of 2016, as amended in 2019, Art. 107)
What is the maximum number of days until arbitration court decision from filing a complaint in the case of awarded contracts?	General. The Complaints Committee must deliver its ruling on a complaint as rapidly as possible, but no later than one month after it receives the comments of the complainant, if applicable. (Law No. 120 of 2016, as amended in 2019, Art. 108)
Is there a requirement to publicly release arbitration court decisions ?	Yes. Decisions can be found at: https://www.stjornarradid.is/raduneyti/nefndir/nanar-um-nefnd/?itemid=e219adb9-4214-11e7-941a-005056bc530c (Law No. 120 of 2016, as amended in 2019, Art. 113)

Legislation

Law No. 120 of 2016 on Public Procurement (Icelandic)	pdf
Regulation No. 260 of 2020 on public procurement websites, reference amounts and procurement under the WTO Agreement on Government Procurement (Icelandic)	pdf
Regulation No. 340 of 2017 on procurement of parties in charge of water supply, energy supply, transport and postal services (Icelandic)	pdf
Regulation No. 755 of 2019 on state procurement arrangements (Icelandic)	pdf
Regulation No. 845 of 2014 on procurement of institutions in the field of defense and security (Icelandic)	pdf

*Last update: 2017

Iceland

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