Anti-Corruption and Integrity Outlook 2024 – Country Notes: Iceland

Contextual factors

 

State structure	Executive power	Legislative system	Legal system
Unitary	Parliamentary	Unicameral	Civil law

Strategy and institutions on anti-corruption and public integrity

Iceland has no unified anti-corruption strategy. Rather than having one central government body responsible for mitigating integrity risks in the public sector, Iceland has different institutions responsible for mitigating public integrity risks in their corresponding fields.

The Act on Protection Against Conflicts-of-Interest in Iceland’s Cabinet regulates lobbying activities, and the Prime Minister’s Office oversees transparency of lobbying activities in addition to collecting and publishing interest declarations for members of the Government. The National Audit Office has the mandate to oversee the financing of political parties and election campaigns and is an independent body with financial accountability to the parliament (Alþingi). Additionally, the Information Committee is the independent body ruling on requests for access and reuse of public information, while the Ministry of Higher Education, Science and Innovation is responsible for open data policy.

Overview

 

Greatest strengths	Areas to improve
Lobbying - implementation	Anti-corruption strategy
Political finance	Lobbying - regulation
Transparency of public information	Conflict of Interest - regulation

Anti-corruption strategy

On average, OECD countries fulfil 45% of OECD criteria on the quality of the strategic framework and 36% on implementation. However, Iceland has no national anti-corruption strategy. Having a strategic framework based on evidence and outlining objectives and priorities is essential to mitigate corruption risks in the public sector.

Corruption risk management and audit

Data for Iceland were not provided.

Lobbying

As measured against OECD standards on lobbying, Iceland fulfils 25% of criteria on regulations but fulfils 56% on practice, compared to the OECD average of 38% and 35%, respectively.

Iceland’s regulations define lobbying activities but do not define which actors are considered lobbyists. They also establish a six-month cooling-off period for public officials before they can become lobbyists. Iceland has not established sanctions for breaches of lobbying regulations. In practice, however, Iceland has a publicly accessible lobbying register, and a supervisory function in central government (The Prime Minister’s Office) oversees transparency of lobbying activities. Information disclosed by lobbyists in the register includes their name, organisations, domain of intervention, and type of lobbying activities. The code of conduct that regulates interactions between public officials and lobbyists is supported by practical examples of undesirable behaviours and situations.

Conflict of interest

As measured against OECD standards on conflict of interest, Iceland has fulfilled 44% of criteria on regulations, and 44% on practice, compared to the OECD average of 76% and 40%, respectively.

Iceland’s regulations define circumstances and relationships that can lead to conflict-of-interest situations for public officials and require members of Government and parliament to submit interest declarations as a minimum upon entry and any renewal or change in public office. A similar obligation also exists for top-tier civil servants of the executive branch. However, there is no requirement for judges to submit interest declarations at regular intervals, and Iceland’s regulations do not establish a procedure for verifying the content of interest declarations. In practice, all members of the Government and parliament have submitted interest declarations in the past six years, and all top-tier civil servants of the executive branch have submitted interest declarations in the past four years. However, declarations are not verified according to a risk-based approach, and Iceland does not collect data on how many of the declarations were verified by the responsible authority.

Political finance

As measured against OECD standards on political finance, Iceland is a strong performer and fulfils 90% of criteria on regulations and 57% of criteria in practice, compared to the OECD averages of 73% and 58%, respectively.

Regulations in Iceland define sanctions for breaches of political finance and election campaign rules and ban anonymous donations and contributions from foreign enterprises, foreign states, and publicly owned enterprises. Furthermore, all political parties and candidates are obliged to report their finances during election campaigns, and political parties must make their financial reports public. In practice, as an independent body, the National Audit Office, has the mandate to oversee the financing of political parties and election campaigns and has certified auditors on its payroll. However, Iceland does not publish aggregated data on the number of cases related to breaches of political finance regulations, the number of investigations conducted, or the types of sanctions issued. While financial reports from all political parties are publicly available, not all political parties represented in parliament have submitted annual accounts within the timelines defined by national legislation for the past five years, and not all parties have submitted accounts related to elections within the timelines defined by national legislation for the past two election cycles.

Transparency of public information

As measured against OECD standards on public information, which includes access to information and open data, Iceland fulfils 67% of criteria on regulations and 73% on practice, compared to the OECD average of 67% and 62%, respectively.

Iceland’s regulations establish that all public institutions and private persons carrying out public duties are holders of public information and that everyone, including non-citizens and legal persons, has the right to access information in all the forms available. Regulations also establish the right to appeal in the case of refusal or inactivity of an administrative agency, there are statutory deadlines for processing requests for information, and information holders are required to provide information in the requested format. In practice, Iceland proactively discloses the following datasets: consolidated versions of all primary laws, the state budget for the current calendar year, the results of the last national elections, legislative proposals of the government, agendas of Government sessions, ministers’ agendas, public tenders and their results, the company registry, the land registry, and asset and interest declarations of ministers and top civil servants in the executive branch. However, salaries of individual senior civil servants and aggregated data on lobbying and access to information requests are not publicly available online.