Country report, gender equality : how are EU rules transposed into national law? : Iceland 2025.
Date: 2025-09-29
Institutions: Directorate-General for Justice and Consumers
Subjects: Iceland, age discrimination, anti-discriminatory measure, application of EU law, equal pay, equal treatment, gender equality, maternity leave, national law, parental leave, paternity leave, pension scheme, report, sexual discrimination, sexual harassment, social security

Iceland 
2025 

 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Justice and Consumers 
Directorate D — Equality and Non-Discrimination 
Unit D.3 Gender Equality 

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Country report  

Gender equality 

How are EU rules transposed into 
national law? 

Iceland 

Herdís Thorgeirsdóttir 

Reporting period 1 January 2024 – 1 January 2025 

2025  Directorate-General for Justice and Consumers 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Europe Direct is a service to help you find answers  
to your questions about the European Union. 

Freephone number (*): 

00 800 6 7 8 9 10 11 

(*)  The  information  given  is  free,  as  are  most  calls  (though  some  operators,  phone 

boxes or hotels may charge you). 

LEGAL NOTICE 

This document has been prepared for the European Commission however it reflects the views only of the 
authors, and the Commission cannot be held responsible for any use which may be made of the information 
contained therein. 

More information on the European Union is available on the Internet (http://www.europa.eu). 

Luxembourg: Publications Office of the European Union, 2025 

© European Union, 2025 

PDF  

ISBN 978-92-68-24197-4 

ISSN 2600-0164  

doi: 10.2838/6130222    DS-01-25-026-EN-N 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

CONTENTS 
1

Introduction ............................................................................................... 5
Basic structure of the national legal system ............................................ 5
List of main legislation transposing and implementing the directives .......... 7
Sources of law .................................................................................... 9
Main surveys, reports on gender equality and other issues ..................... 10
General legal framework .......................................................................... 12
Constitution ...................................................................................... 12
Equal treatment legislation ................................................................. 12
Implementation of central concepts ......................................................... 16
Sex/gender/transgender .................................................................... 16
Direct sex discrimination .................................................................... 18
Indirect sex discrimination .................................................................. 19
Multiple discrimination and intersectional discrimination ......................... 20
Positive action ................................................................................... 22
Harassment and sexual harassment ..................................................... 25
Instruction to discriminate .................................................................. 27
Other forms of discrimination .............................................................. 27
Evaluation of implementation .............................................................. 28
Remaining issues ............................................................................... 28
Equal  pay  and  equal  treatment  at  work  (Article 157  of  the  Treaty  on  the 
Functioning of the European  Union (TFEU) and Recast  Directive 2006/54)
 ................................................................................................................. 29
General (legal) context....................................................................... 29
Equal pay ......................................................................................... 31
Access to work, working conditions and dismissal .................................. 36
Evaluation of implementation .............................................................. 39
Remaining issues ............................................................................... 39
Work-life  balance  issues:  pregnancy,  maternity,  family-related  leave  and 
flexible  working  arrangements  (Directive 92/85,  relevant  provisions  of 
Directives 2006/54, and Directive 2019/1158) ....................................... 40
General (legal) context....................................................................... 40
Pregnancy and maternity protection .................................................... 41
Maternity leave ................................................................................. 45
Paternity leave .................................................................................. 49
Adoption leave .................................................................................. 51
Parental leave ................................................................................... 51
Child-related leave in relation to surrogacy ........................................... 53
Carers’ leave ..................................................................................... 54
Time off for force majeure .................................................................. 56
Flexible working time arrangements (FWAs) ......................................... 57
Evaluation of implementation .............................................................. 58
Remaining issues ............................................................................... 59
Occupational social security schemes (Chapter 2 of Directive 2006/54) .. 60
General (legal) context....................................................................... 60
Direct and indirect discrimination ........................................................ 62
Personal scope .................................................................................. 62
Material scope ................................................................................... 63
Exclusions ........................................................................................ 63
Laws and case law falling under the examples of sex discrimination mentioned 
in Article 9 of Directive 2006/54 .......................................................... 63
Actuarial factors ................................................................................ 64
Difficulties ........................................................................................ 64
Evaluation of implementation .............................................................. 65
Remaining issues ............................................................................... 65
Statutory schemes of social security (Directive 79/7) ............................. 66
General (legal) context....................................................................... 67

2

3

4

5

6

7

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

9

8

Implementation  of  the  principle  of  equal  treatment  for  men  and  women  in 
matters of social security .................................................................... 68
Personal scope .................................................................................. 68
Material scope ................................................................................... 68
Exclusions ........................................................................................ 68
Actuarial factors ................................................................................ 68
Difficulties ........................................................................................ 69
Evaluation of implementation .............................................................. 69
Remaining issues ............................................................................... 69
Self-employed  workers  (Directive 2010/41/EU  and  some 
relevant 
provisions of the Recast Directive) ........................................................... 70
Implementation of Directive 2010/41/EU .............................................. 70
Personal scope .................................................................................. 71
Material scope ................................................................................... 72
Positive action ................................................................................... 72
Social protection ............................................................................... 72
Maternity benefits.............................................................................. 73
Occupational social security ................................................................ 74
Prohibition of discrimination ................................................................ 74
Evaluation of implementation .............................................................. 75
Remaining issues ............................................................................... 75
Goods and services (Directive 2004/113) ................................................ 76
General (legal) context....................................................................... 76
Prohibition of direct and indirect discrimination ..................................... 77
Material scope ................................................................................... 77
Exceptions ........................................................................................ 78
Justification of differences in treatment ................................................ 78
Actuarial factors ................................................................................ 78
Interpretation of exception contained in Article 5(2) of Directive 2004/113 78
Positive action measures (Article 6 of Directive 2004/113) ...................... 78
Specific problems related to pregnancy, maternity or parenthood ............ 78
Evaluation of implementation .............................................................. 78
Remaining issues ............................................................................... 78
Violence  against  women  and domestic violence  in  relation to  the Istanbul 
Convention  and  the  Violence  Against  Women  Directive  (Directive  (EU) 
2024/1385) ............................................................................................. 79
General (legal) context with regard to the obligation set out by the Istanbul 
Convention ....................................................................................... 79
General context with regard to the obligation set out by the Violence Against 
Women Directive ............................................................................... 84
Ratification of the Istanbul Convention ................................................. 85
Compliance  and  enforcement  aspects  (horizontal  provisions  of  all 
directives) ................................................................................................ 86
General (legal) context....................................................................... 86
Victimisation ..................................................................................... 88
Access to courts ................................................................................ 88
Horizontal effect of the applicable law .................................................. 90
Burden of proof ................................................................................. 91
Remedies and sanctions ..................................................................... 92
Equality body .................................................................................... 93
Social partners .................................................................................. 94
Other relevant bodies......................................................................... 94
Evaluation of implementation .............................................................. 94
Remaining issues ............................................................................... 94
Overall assessment .................................................................................. 95
12
Bibliography ..................................................................................................... 98

10

11

4 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

1 

Introduction 

  Basic structure of the national legal system 

Icelandic  law  is  primarily  comprised  of  statutes  adopted  by  Althingi,  the  Icelandic 
Parliament, but also includes orders issued by the executive branch of the state, mainly in 
the form of regulations. All laws and orders of the executive authority are published in the 
Official Gazette of Iceland (Stjórnartíðindi). The police and prosecutors are responsible for 
law  enforcement.  The  courts,  and  to  some  extent  public  administrative  bodies,  resolve 
legal disputes. 

It is the responsibility of the Ministry of Justice to make public the rules of law which apply 
in Iceland. Agencies of law enforcement, that is offices of the police, the Icelandic Coast 
Guard,  public  prosecutors,  the  courts,  the  Prisons  and  Probation  Administration,  the 
prisons  and  the  District  Commissioners,  also  fall  within  the  mandate  of  the  Ministry  of 
Justice 

The  judicial  system  in  Iceland  is  based  on  the  Constitution  and  the  Judiciary  Act 
No. 50/2016. There is no distinction in Iceland between criminal and civil courts. A single 
court system handles both criminal and civil matters. The judiciary has three levels: the 
district courts, the Court of Appeal and the Supreme Court. 

All court actions in Iceland commence in the district courts (Héraðsdómstólar), of which 
there  are  eight  located  around  the  country.  The  conclusion  of  a  district  court  can  be 
appealed to the Court of Appeal, which was established by the Judiciary Act No. 50/2016 
(Landsréttur)  and  began  operating  on  1  January  2018,  when  a  three-tier  judiciary  was 
introduced in Iceland. Previously, there were only district courts and the Supreme Court, 
which was the system that had been in operation since the 1919 abolition of the National 
High  Court.  In  special  cases,  and  after  receiving  the  permission  of  the  Supreme  Court 
(Hæstiréttur), it is possible to refer the conclusion of the Court of Appeal to the Supreme 
Court, which is the country’s court of highest instance. In most instances, the judgment 
of  the  Court  of  Appeal  will  be  the  final  resolution  in  the  case.  The  role  of  the  Supreme 
Court of Iceland is now mainly setting precedents in jurisprudence. There is a total of 64 
judges in Iceland, 42 of whom preside over the 8 district courts. The Court of Appeal has 
15  judges  and  the  Supreme  Court  has  7.  The  courts  are  composed  of  lawyers  with 
jurisdiction to deal with all legal questions. 1 

The Icelandic judiciary is independent. It is up to the individual judge to decide whether 
to keep a suspect in custody during a criminal investigation or to grant release pending 
trial. There is no bail system. Lawsuits may seek damages for or the cessation of a human 
rights  violation.  Administrative  remedies  as  well  as  judicial  remedies  are  available  for 
alleged wrongdoing. 

The Constitution guarantees a fair trial. Although trials are usually open to the public, they 
may  be  held  behind  closed  doors  at  the  request  of  the  defendant  or  in  cases  involving 
minors. There are no juries, but rather judges or multi-judge panels. Defendants have the 
right to attend their trial, to confront witnesses and to present evidence. In some cases, 
prosecutors  may  introduce  evidence  that  has  been  obtained  illegally.  Defendants  may 
appeal verdicts to the Court of Appeal. 

As a civil law country, court practice in Iceland does not have the same authoritative role 
as  in  common  law  countries. Traditional  practice  refers  to  considerations  of  fairness, 

1   There is only one special court, the Labour Court, which has jurisdiction with respect to disputes in 

industrial relations. In addition, there is the Court of Impeachment which only addresses cases pertaining 
to alleged offences by Government ministers in the opinion of the Icelandic Parliament, Althingi. See, for 
example, European Court of Human Rights, Haarde v. Iceland, No. 66847/12, 23 November 2017. 

5 

 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

justice and feasibility  regarding the needs  of the society and  resembles to  some  extent 
the legal term equity. The Supreme Court has no duty to follow its earlier decisions and 
the district courts are not obligated to adhere to earlier decisions of the Supreme Court. 
However,  in  matters  of  legal  uncertainty,  the  decisions  of  the  Supreme  Court  have 
considerable authority for the disposition of future cases. In certain areas of law that did 
or do not have extensive statutory legislation, such as tort, the decisions of the Supreme 
Court are a source of law of central importance. 

The  Judicial  Administration  (Dómstólasýsla)  is  a  public  agency  that  takes  care  of  the 
administrative  work  of  all  the  courts  and  represents  their  interests  in  dealing  with  the 
Government, the media and other parties. 

The administration of justice is covered by the Code of Civil Procedure No. 91/1991 with 
later  amendments2  and  the  Code  of  Criminal  Procedure  No. 88/2008.3  Other  acts  have 
various procedural provisions.  

The Equality Complaints Committee operates on the basis of Chapter III of the act on the 
administration of matters concerning equality, No. 151/2020, and the Regulation on the 
Work  of  the  Equality  Complaints  Committee,  No.  1320/2024.  The  Equality  Complaints 
Committee (the Complaints Committee) handles complaints submitted to it in accordance 
with the equality acts4 referred to in Article 1 of the Act on the Administration of Matters 
Concerning  Equality  No. 151/2021,  and  gives  a  written  ruling  on  whether  or  not  the 
provisions  of  those  acts  have  been  violated.  If  the  Equality  Complaints  Committee 
concludes that there has been violation of the provisions of the acts, it may, in its ruling, 
instruct the entity in question to make specific improvements. 

Iceland is a party to all the main international and regional human rights treaties, such as 
the UN International Covenant on Civil and Political Rights, which was ratified in 1979. It 
ratified the Convention on the Elimination of All Forms of Discrimination Against Women 
(CEDAW)  on  18  June  1985  and  the  Council  of  Europe  Convention  on  Preventing  and 
Combating  Violence  against  Women  and  Domestic  Violence  (hereafter  the  Istanbul 
Convention) on 26 April 2018. Iceland has been a member of the Council of Europe since 
1950 and the European Convention on Human Rights was adopted into domestic law in 
1994.  

Iceland is a member of the European Economic Area (EEA). The EEA Agreement entered 
into force in 1994. The EEA Agreement provides for the inclusion of European Union (EU) 
legislation in all policy areas of the single market. The EEA Joint Committee is the forum 
where  decisions  are  taken  by  consensus  to  incorporate  EU  legislation  into  the  EEA 
Agreement. Whenever an EEA-relevant legal act is amended or a new one adopted by the 
EU,  a  corresponding  amendment  needs  to  be  made  to  the  relevant  annex  of  the  EEA 
Agreement. This is essential to maintain the homogeneity of the EEA. Such an amendment 
to the EEA Agreement is to be made as closely as possible to the adopted legislation on 
the EU side, with a view to permitting simultaneous application in the EU and in the EEA 
EFTA  States.  The  decisions  of  the  EEA  Joint  Committee  are  published  in  the  EEA 
Supplement to the Official Journal of the European Union. 

2   Code of Civil Procedure No. 91/1991: available https://www.government.is/library/01-Ministries/Ministry-

of-Justice/Code%20of%20Civil%20Procedure%20No.%2091,%2031%20December%201991..pdf.  

3   Code of Criminal Procedure No. 88/2008: available 

https://www.government.is/lisalib/getfile.aspx?itemid=bc7cb7af-0572-11ea-9450-005056bc4d74.  

4   The acts in the field of equality within the area covered by laws on equality, i.e. the Act on equal status and 
equal rights irrespective of gender, the Act on equal treatment irrespective of race or ethnic origin, and the 
Act on equal treatment on the labour market, cf., Article 1 of the Act on the administration of matters 
concerning equality No. 151/2020, which applies, among other things, to the activities of the Directorate of 
Equality and the Equality Complaints Committee. 

6 

 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

  List of main legislation transposing and implementing the directives 

EU  legal  acts  are  incorporated  into  the  EEA  Agreement by  decisions  of  the  EEA  Joint 
Committee (JCDs), which place acts into one of the annexes or protocols to the Agreement. 
The EEA Joint Committee Decisions specify the deadlines for the implementation of the EU 
legal acts into the legal order of the EEA country. 

Directive 2004/113/EC on equal treatment between men and women in goods and services 
has been fully implemented with the following legislation: 

- 

- 

Act  No. 79/2015  amending  Act  No. 10/2008  on  equal  status  and  equal  rights  of 
women and men, adding Article 24a; Article 17 of the new gender equality act (GEA) 
No. 150/2020 on equal status and equal rights irrespective of gender,5 approved by 
the Althingi (the national Parliament) on 17 December 2020, took effect on 6 January 
2021; and  

Act  No. 62/2014  amending  Act  No. 10/2008  on  equal  status  and  equal  rights  of 
women and men (employment, jobs); replaced by the GEA No. 150/2020. 

Directive 2006/54/EC  on  the  implementation  of  the  principle  of  equal  opportunities  and 
equal  treatment  of  men  and  women  in  matters  of  employment  and  occupation,  was 
implemented by: 

- 

Act  No. 62/2014  amending  Act  No. 10/2008  on  equal  status  and  equal  rights  of 
women and men; replaced by the GEA No. 150/2020. 

Directive 2010/41/EU  on  equal  treatment  between  men  and  women  engaged  in  a  self-
employed capacity has been fully implemented with the following legislation: 

- 

- 

- 

Act No. 150/2020 on equal status and equal rights irrespective of gender, replacing 
the previous GEA on the equal status and equal rights of women and men. The GEA 
was  approved  by  the  Althingi  on  17  December  2020  and  took  effect  on 
6 January 2021; 

Social security Act No. 100/2007; and 

Act  No. 144/2020  replacing  Act  No. 95/2000  on  maternity/paternity  leave  and 
parental leave (MPLPL). 

Directive 2010/18/EU  on  parental  leave  has  been  fully  implemented  with  the  following 
legislation: 

- 

- 

- 

Act  No. 144/2020  replacing  Act  No. 95/200  on  maternity/paternity  leave  and 
parental leave (MPLPL); 
Act  No. 150/2020  on  equal  status  and  equal  rights  irrespective  of  gender  (GEA); 
replacing the previous GEA No. 10/2008. The GEA was approved by the Althingi on 
17 December 2020, and took effect on 6 January 2021; and 
Act  No. 22/2006  on  payments  to  parents  of  chronically  ill  or  severely  disabled 
children.6 

5   Act No. 150/2020, https://www.government.is/library/04-

Legislation/Act%20on%20Equal%20Status%20and%20Equal%20Rights%20Irrespective%20of%20Gender.
pdf.  

6   Act No. 22/2006, https://www.government.is/media/velferdarraduneyti-media/media/acrobat-

enskar_sidur/Act-on-payments-to-parents-of-chronically-ill-or-severely-disabled-children-No-22-2006-with-
subsequent-amendments.pdf. 

7 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

Directive 2019/1158: 

- 

The EEA Joint Committee decided on 14 March 2024 to amend Annex XVIII (Health 
and safety at work, labour law, and equal treatment for men and women) to the EEA 
Agreement (2024/1956).7  

Directive EU 2019/1158 of the European Parliament and of the Council of 20 June 2019 
on work-life balance for parents and careers:  

- 

The  Work-Life  Balance  Directive  is  to  be  incorporated  into  the  EEA  Agreement, 
subsequently  repealing  Council  Directive  2010/18/EU  under  the  EEA  Agreement. 
However,  this  has  still  not  formally  happened.8  It  has  been  reviewed  within  the 
Ministry  of  Social  Affairs  and  Labour  and  passed  with  constitutional  reservation  to 
the Ministry of Foreign Affairs as it is anticipated that it will call for legal amendments. 
Consultation  with  stakeholders  on  the  labour  market  on  how  to  transpose  the 
Directive are ongoing and the results are expected in the spring of 2025.9  

Directives 2000/78/EC and 2000/43/EC were implemented by: 

- 
- 

Act No. 86/2018 on equal treatment in the labour market; and 
Act No. 85/2018  on  equal 
irrespective  of  race,  ethnic  origin, 
religion/belief, disability, diminished work ability, age, sexual orientation and gender 
identity, biological gender characteristics and gender expression. 

treatment 

Directive 79/7/EU on the progressive implementation of the principle of equal treatment 
for men and women in matters of social security was implemented by:  

- 

- 

Act No. 117/1993 on Social Security with later amendments, Article 11, paragraph 
2; and 
Act No. 100/2007 on Social Security with later amendments. 

Directive  2002/73  of  the  European  Parliament  and  of  the  Council  amending  Council 
Directive 76/207/EEC on the implementation of the principle of equal treatment for men 
and  women  as  regards  access  to  employment,  vocational  training  and  promotion,  and 
working  conditions  was  adopted  into  the  Annex  XVIII  to  the  EEA  Agreement  but  is  no 
longer in force. 10 

Directive 96/34 was adopted into Annex XVIII to the EEA Agreement but is no longer in 
force.11 

Directive 2014/27/EU of the European Parliament and of the Council of 26 February 2014 
amending  Council  Directives  92/58/EEC,  92/85/EEC,  94/33/EC,  98/24/EC  and  Directive 
2004/37/EC  of  the  European  Parliament  and  of  the  Council,  in  order  to  align  them  to 
Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and 
mixtures  has  been  adopted  into  the  EEA  Agreement  and  is  in  force.  The  following 
amendments have been made accordingly: 

- 

Regulation No. 454/2016, amending Regulation No. 426/1999 on the protection of 
children and young people at work.12 

7   Decision of the EEA Joint Committee No 74/2024 of 15 March 2024, https://eur-lex.europa.eu/legal-

content/EN/TXT/PDF/?uri=CELEX:22024D1596. 

8   Information obtained from the Ministry of Social Affairs on 18 February 2025. 
9   Information obtained from the Ministry of Social Affairs on 18 February 2025. 
10   See: https://www.efta.int/eea-lex/32002l0073#anchor-is. 
11   See: https://gagnagrunnur.ees.is/31996l0034.  
12   The text of regulations is only available in Icelandic. 

8 

 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

- 

- 

- 

Regulation No. 451/2016, amending Regulation No. 553/2004 on the protection of 
workers from risk of damage of health from substances at work. 
Regulation  No.  453/2016,  amending  Regulation  No.  931/2000  to  encourage 
improvements in working conditions for those who are pregnant, have recently given 
birth or are breastfeeding 
Regulation  No.  452/2016,  amending  Regulation  No.  98/2002  on  the  protection  of 
workers  from  risk  to  health  from  exposure  to  chemicals  that  can  cause  cancer  or 
mutation. 

Directive 96/97 amending Directive 86/378/EEC on the implementation of the principle of 
equal  treatment  for  men  and  women  in  occupational  social  security  schemes  was 
incorporated in to the EEA Agreement but is no longer in force. 

Directive (EU) 2022/2381 of the European Parliament and of the Council of 23 November 
2022 on improving the gender balance among directors of listed companies and related 
measures  (text  with  EEA  relevance).  The  following  amendments  have  been  made 
accordingly: 

- 

Act No. 13/2010 amended the Public Limited Companies Act No. 2/1995 as well as 
the Private Limited Companies Act No. 138/1994, implementing gender quotas on 
company boards. The Act took effect on 1 September 2013. The law establishes that, 
in companies with more than 50 employees, both genders must be represented on 
the board. 

  Sources of law 

Iceland has a civil law legal system and thus Icelandic law is characterised by written law. 
Its  most  pertinent  feature  is  that  its  core  principles  are  codified  in  a  referable  system, 
which  serves  as  the  primary  source  of  law.  The  Constitution  of  the  Republic  of  Iceland 
No. 33/1944 is the highest source of law,13 followed by statutory legislation and regulatory 
statutes. The tradition of culture is recognised (eðli máls) as referring to considerations of 
fairness, justice and feasibility as to the needs of society and has the same meaning as 
the English legal term ‘equity’, in particular when other sources of law have not been able 
to establish a rule of law. Icelandic courts rely on the ‘tradition of culture’ in some cases. 
Act No. 15/2005 stipulates how official material, including adopted acts, are published.14 

Being a civil law country, court practice in Iceland does not have the same authoritative 
role  as  in  common  law  countries. The  Supreme  Court  has  no  duty  to  follow  its  earlier 
decisions,  and  the  district  courts  are  not  obligated  to  adhere  to  earlier  decisions  of  the 
Supreme  Court.  The  Equality  Complaints  Committee  operates  as  an  independent  and 
autonomous entity and its rulings cannot be appealed to a higher authority. The Equality 
Complaints Committee’s rulings are binding for the parties to the case, who may, however, 
refer  a  ruling  by  the  committee  to  the  courts.  The  Supreme  Court  has  in  some  cases 
confirmed  the  ruling  of  the  Equality  Complaints  Committee  but  has  also  refuted  its 
rulings.15  

13   The Constitution of the Republic of Iceland, No. 33, 17 June 1944 has been revised as follows: 

30 May 1984, 31 May 1991, 28 June 1995 and 24 June 1999. Fundamental changes were made to the 
human rights chapter with the Constitutional Act No. 97/1995. The bill accompanying the Act made many 
references to the European Convention on Human Rights, as well as to other Council of Europe and United 
Nations human rights treaties that Iceland has ratified. 

14   Iceland, Lög um Stjórnartíðindi og Lögbirtingarblað nr. 15/2005, 

https://www.althingi.is/lagas/nuna/2005015.html. 

15   In a case where the Equality Complaints Committee had ruled there had been a breach of the GEA 

regarding the appointment in the post of district commissioner, a district court ruled differently while the 
Supreme Court confirmed the ruling of the Equality Complaints Committee. Supreme Court judgment 
121/2002. The Supreme Court judgment 686/2008 agreed with the ruling of the Equality Complaints 
Committee that the GEA had not been violated. 

9 

 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

  Main surveys, reports on gender equality and other issues 

- 

Haraldsdóttir,  R.  K.,  Rafnsdóttir,  G.  L.  and  Jónsdóttir,  G.  A.  (2022),  ‘Að  sníða 
verkfærið að veruleikanum eða veruleikann að verkfærinu? Um jafnlaunastaðal og 
afnám kynbundinna launa’ (To tailor the tool to match reality or reality to match the 
tool?  On  the  equal  pay  certification  system  and  the  abrogation  of  the  gender  pay 
gap), Icelandic Review of Politics and Administration (Stjórnmál & Stjórnsýsla), Vol. 
18, No. 2. 16 

In order to combat the gender pay gap in Iceland and promote equality in the labour 
market,  equal  pay  certification  was  enacted  with  the  equal  pay  standard  by  Law 
No. 56/2017. The purpose of the standard is for organisations to implement an equal 
pay  system,  which  ensures  that  decisions  do  not  include  discriminatory  practices 
based on gender. The main purpose of the research is to examine whether the equal 
pay  standard  has  achieved  its  goal.  Interviews  were  conducted  with  all  four 
certification  bodies  to  explore  the  implementation  and  the  certification  of  the 
standard.  Furthermore,  changes  in  the  gender  pay  gap  were  analysed  based  on 
Statistics Iceland’s data on wages between 2012 and 2020. The analysis is based on 
data  from  organisations  that  participated  in  the  wage  study  for  the  whole  time 
period. Wages of men and women within organisations before and after equal pay 
certification  were  also  compared.  Certification  bodies  see  the  certification  as  a 
successful  step  in  the  interest  of  pay  equality.  However,  serious  concerns  were 
expressed regarding lack of instructions from the Government. The gender pay gap 
has decreased by almost eight percentage points over the time period although little 
difference  is  visible  between  wage  trends  in  organisations  that  have  received 
certification  and  those  that  have  not.  Thus,  it  is  not  possible  to  confirm  that  the 
implementation of the standard has had any direct effect on the gender pay gap. It 
may have had an indirect effect through public discourse that has led to a general 
decrease. Although the equal pay standard has increased the quality of wage setting, 
there  are  concerns  about  inaccurate  work  practices  and  that  the  standard  lends 
legitimacy to the differences related to occupational segregation and the gender pay 
gap.  The  authors  note  that  a  lack  of  guidelines  for  precise  working  practices  is  a 
problem that the Government should respond to quickly and clearly.  

- 

Hafsteinsdóttir, G. B., Kristjánsdóttir, E. S. and Christiansen, Þ. H. (2020) ‘“Þetta er 
allt  mannanna  verk”:  Upplifun  stjórnenda  á  áhrifum 
jafnlaunavottunar  á 
kjaraumhverfi’, (Behind every system are people: Managers’ experience of the effect 
of the Equal Pay Certification on Wage Environment), Icelandic Review of Politics and 
Administration, Vol. 16, No. 2.17  

This research reviews the experience of managers regarding the effect of the equal 
pay  certification  on  the  wage  environment  using  interviews  with  managers  with 
experience  of  the  equal  pay  standard.  The  main  results  imply  that  the  managers 
experienced  increased  bureaucracy  and  systemisation  and  displacement  of  their 
decision-making powers, and concluded that the equal pay certification might give a 
false  impression.  The  results  also  showed  a  shift  in  the  emphasis  in  the  annual 
interview  and 
collective  agreement  right  of  employees  to  an  employee 

16   Haraldsdóttir, R. K., Rafnsdóttir, G. L. and Jónsdóttir, G. A. (2022), ‘Að sníða verkfærið að veruleikanum 
eða veruleikann að verkfærinu? Um jafnlaunastaðal og afnám kynbundinna launa’ (To tailor the tool to 
match reality or reality to match the tool? On the equal pay certification system and the abrogation of the 
gender pay gap), Icelandic Review of Politics and Administration, Vol. 18, No. 2, December 2022, 
https://pdfs.semanticscholar.org/141f/0af8921c2c9d6bd9a63fc0d655299be2654b.pdf. 

17   Hafsteinsdóttir, G.B., Kristjánsdóttir, E.S. and Christiansen, Þ. H.: ‘“Þetta er allt mannanna verk”: Upplifun 
stjórnenda á áhrifum jafnlaunavottunar á kjaraumhverfi’, in Icelandic Review of Politics and Administration, 
Vol. 16, Issue 2, December 2020. See also: RÚV, Árnadóttir, V (2020) ‘Equal pay certification adds 
bureaucracy’, 26 December 20202, https://www.ruv.is/frett/2020/12/26/jafnlaunavottun-eykur-skrifraedi-
og-er-jafnvel-talsyn?fbclid=IwAR1g0vx__9gSVtAxMm8ymAnqe0uzxUU2C9Y6c3USgCZEFyl0yn6zy0kmvF0; 
https://www.mbl.is/vidskipti/frettir/2020/12/27/jafnlaunavottun_se_mogulega_talsyn/. 

10 

 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

underutilisation of the flexibility of the certification as well as subjective performance 
assessments of employees and inconsistencies in the procedures of the certification 
bodies.  Even  though,  at  first  glance,  the  equal  pay  certification  seems  valid  and 
reliable, there are certain factors that make it possible to meet the requirements for 
equal pay certification even though there is a gender pay gap. 

- 

- 

Directorate of Labour (2022) Annual Report on the Maternity/Paternity Leave Fund 
2021.18 

Thorgeirsdóttir,  H.  K.  (2019)  ‘Protection  from  victimisation  in  the  workplace: 
Comparative  EU-Icelandic  perspectives’,  European  Equality  Law  Review  2019/1, 
pp. 44-59. 

18   See: https://vinnumalastofnun.is/media/3885/vms-arsskyrsla-faedingarorlofsjods-ens-080622.pdf.  

11 

 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

2 

General legal framework 

  Constitution 

2.1.1  Constitutional ban on sex discrimination 

Article 65 of the Constitution No. 33/1944, as amended in 1995, 19 provides that: 

‘(1): Everyone shall be equal before the law and enjoy human rights irrespective of 
sex, religion, opinion, national origin, race, colour, property, birth or other status; 
(2) Men and women shall enjoy equal rights in all respects.’ 

During the Constitutional amendment process in 1995 the latter paragraph was added to 
Article 65; a clear indicator of the strong emphasis on the need for affirmative action to 
achieve  gender  equality  without  explicitly  mentioning  the  need  for  temporary,  positive 
measures  in  favour  of  the  under-represented  sex. 20  The  need  to  guarantee  substantive 
gender equality is emphasised by adding the specific second paragraph, although equality 
irrespective of sex is provided for in the first paragraph. The latter paragraph exemplifies 
the intention to promote gender equality, including resorting to positive measures when 
necessary.  

2.1.2  Other constitutional protection of equality between men and women  

None. 

  Equal treatment legislation 

The Act on equal status and equal rights irrespective of gender, No. 150/2020 (GEA) was 
approved by the Althingi, the Icelandic Parliament, on 17 December 2020 and became Act 
No. 150/2020 on 29 December that same year (entered into force on 6 January 2021). It 
replaced  the  Act  on  equal  status  and  equal  rights  of  women  and  men  No. 10/2008  as 
amended  by  Acts  No. 162/2010,  No. 126/2011,  No. 62/2014,  No. 79/2015, 
No. 117/20916, No. 56/2017 and No. 80/2019. 

The GEA is comprehensive, adding to the general prohibition against gender discrimination 
a  prohibition  against  multiple  discrimination,  e.g.  discrimination  on  multiple  grounds 
protected under the new act. The objective of the GEA is to prevent discrimination on the 
basis of gender and to maintain gender equality and equal opportunities for the genders 
in all spheres of society. All people shall have equal opportunities to benefit from their own 
enterprise and to develop their skills irrespective of gender. The term ‘gender’ in the GEA 
means  women,  men  and  persons  whose  gender  is  registered  as  neutral  in  Registers 
Iceland, unless stated otherwise. 

This objective will be reached: 

- 

- 
- 

by observing gender equality perspectives and working towards gender and equality 
mainstreaming in policy making and decision taking in all spheres of society; 
by working to secure equal influence of women and men in society; 
by specifically improving the position of women and increasing their opportunities in 
society; 

19   Act No. 97/1995 amending the Constitution, https://www.stjornarradid.is/media/forsaetisraduneyti-

media/media/stjornarskra/Skyrsla_stjornlaganefndar_seinna_bindi_skyringar.pdf. (Stjórnskipunarlög um 
breyting á Stjórnarskrá Lýðveldisins Íslands, nr. 33/1944, með síðari breytingum), 
https://www.althingi.is/altext/stjt/1995.097.html. 

20   Act on equal treatment in the labour market, No. 86/2018 of 25 June 2019 (Lög um jafna meðferð á 

vinnumarkaði nr. 86/2018 frá 25. júní 2018), available at: https://www.althingi.is/altext/148/s/0551.html. 

12 

 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

- 

- 
- 
- 
- 
- 

- 

- 
- 

- 

by  working  against  pay  discrimination  and  other  forms  of  gender-based 
discrimination  in  the  employment  market,  including  by  having  companies  and 
institutions fulfil the conditions of equal pay certification or equal pay confirmation; 
by enabling everyone, irrespective of gender, to reconcile their work and family life; 
by increasing education and awareness-raising on gender equality; 
by analysing statistics according to gender; 
by increasing research in gender and equality studies; 
by  working  against  gender-based  violence,  gender-based  harassment  and  sexual 
harassment; 
by  changing  traditional  gender  images  and  working  against  negative  stereotypes 
regarding the roles of women and men; 
by promoting gender-neutral classification of jobs; 
by focusing especially on the status of people whose gender is registered as neutral 
in Registers Iceland; and 
by working against multiple discrimination.21 

Furthermore, the GEA does not require that people work for the same employer to demand 
equal pay and the equal pay certification provision is strengthened. 

The Act on the administration of matters concerning equality No. 151/202022 entered into 
force  in  January  2021,  followed  in  2024  by  the  Regulation  on  the  work  of  the  Equality 
Complaints  Committee,  No.  1320/2024.  It  applies  to  the  activities  of  the  Directorate  of 
Equality and the Equality Complaints Committee. The Directorate of Equality is a special 
institution  under  the  administration  of  the  Minister  of  Social  Affairs23  and  its  role  is  to 
handle the administration of all matters covered by laws on equality, i.e. the Act on equal 
status and equal rights irrespective of gender No. 150/2020, the Act on equal treatment 
irrespective of race and ethnic origin No. 85/2018, and the Act on equal treatment on the 
labour market No. 86/2020. An amendment to Act No. 85/2018 has been proposed so that 
more grounds will be added to the discriminatory grounds of race and ethnic origin, i.e. 
religion,  world  view,  disability,  age,  sexual  orientation,  gender  identity,  gender 
characteristics and gender expression.24 

In accordance with Directives 2000/78/EC and 2000/43/EC, Iceland adopted the Act on 
equal treatment in the labour market No. 86/201825 on 25 June 2019 and the Act on equal 
treatment irrespective of race and ethnic origin, No. 85/201826 on 25 June 2018, the first 
anti-discrimination legislation adopted in the country for grounds other than gender. These 
Acts  apply  both  to  the  public  and  private  sectors.  The  Acts  do  not  cover  differences  of 
treatment  based  on  nationality  or  statelessness  or  payments  of  any  kind  made  by  the 
state’s social security or social protection schemes, e.g. unemployment benefits, parental 
leave  payments  and  municipal  social  services.  Measures  for  public  security,  order, 
prevention of crime and protection  of health and the  rights and freedoms of  others are 
exempt and justified differences of treatment on grounds of age are permitted. Employers 

21   See summary here: https://www.government.is/topics/human-rights-and-equality/equality/about-gender-

equality/. 

22   Act No. 151/2021 on the Administration of matters concerning equality, 

https://www.government.is/library/04-
Legislation/Act%20on%20the%20Administration%20of%20Matters%20Concerning%20Equality.pdf. 
23   Following a decision of the Prime Minister, Mr Bjarni Benediktsson, who took office after the previous PM, 
Ms Katrín Jakobsdóttir, resigned in April 2024 (to run for President). Equality and human rights matters 
were transferred from the Prime Minister’s Office to the Ministry of Social Affairs on 1 September 2024.  

24   See: https://samradsgatt.island.is/oll-mal/$Cases/Details/?id=2926. 
25   See: https://www.government.is/media/menntamalaraduneyti-media/media/frettir2014/Thyding-log-um-

fjolmidla-mai-2015-Lokagerd-a-vef.pdf; https://www.government.is/library/04-
Legislation/Act%20on%20Equal%20Treatment%20on%20the%20Labour%20Market%20No%2086%20201
8%20m%20br%20Final%20SENT%20230519.pdf. 

26   Act No. 85/2018 on equal treatment irrespective of gender and ethnic origin (Lög nr. 85/2018 um jafna 

meðferð óháð kynferði og þjóðernisuppruna), available at: https://www.government.is/library/04-
Legislation/nr-85%202018-english.pdf. 

13 

 
 
 
 
Country report – Gender equality – Iceland – 2025 

are  obliged  to  provide  reasonable  accommodation  for  disabled  people  or  people  with 
diminished working capacity and positive action is permitted. 

Both  acts  took  effect  on  1 September  2019, 27  apart  from  the  provisions  on  differential 
treatment  based  on  age  under  the  Act  on  equal  treatment  in  the  labour  market,  which 
entered into force on 1 July 2019. 

The Maternity/Paternity Leave and Parental Leave Act No. 144/202028 entered into force 
on 1 January 2021. The Act was amended by Act No. 107/2021, Act No. 77/2022 and Act 
No. 73/2024. Its aim is to ensure that a child has access to both parents and to enable 
parents to reconcile work and family. Parents shall each have an independent entitlement 
to parental leave for up to six months, however, up to six weeks can be transferred from 
one parent to the other. 29 

The aim of the Termination of Pregnancy Act No. 43/201930 is to ensure that the right to 
self-determination  of  women  who  request  terminations  of  pregnancy  is  respected  by 
granting them secure access to the health services. Any woman who so requests will have 
the right to have her pregnancy terminated up to the end of the 22nd week of pregnancy. 
In all cases, pregnancy should be terminated as soon as possible, and preferably before 
the end of the 12th week of pregnancy. 

Following  amendments  to  the  laws  on cooperatives  (No. 22/1991) public  limited 
companies (No. 2/1995),31 private limited companies (No. 138/1994),32 and partnerships 
(50/2007), companies that have over 50 employees are required to have both women and 
men  on  their  company  boards  and  if  there  are  more  than  three  board  members,  the 
percentage  of women or men  cannot be below 40 %. These amendments also included 
changes that will make monitoring easier. 

Article 26 of the Media Act No. 38/201133 states that media service providers must, in all 
their activities, uphold democratic principles and ensure freedom of expression. They must 
respect human rights and equality as well as the right to personal privacy, except in cases 
where  the  media  service  provider’s  democratic  role  and  the  right  of  the  public  to 
information  dictate  otherwise.  Media  service  providers  must  take  care  to  meet 
requirements regarding impartiality and accuracy in news and current affairs content and 
ensure that a variety of opinions is expressed, including those of both men and women. 

In 2015, gendered budgeting was incorporated into law. Article 18 in the Public Finance 
Act  No. 123/201534  states  that  the  Minister  of  Finance  and  Economic  Affairs,  in 

27   Law No. 85/2018 on equal treatment irrespective of gender and ethnic origin (Lög nr. 85/2018 um jafna 

meðferð óháð kynferði og þjóðernisuppruna), available at: 
https://www.althingi.is/lagas/nuna/2018085.html; https://www.jafnretti.is/is/um-jafnrettisstofu/frettir/log-
um-bann-vid-allri-mismunun-hafa-tekid-gildi; https://www.althingi.is/lagas/nuna/2018085.html; 
https://www.jafnretti.is/is/um-jafnrettisstofu/frettir/log-um-bann-vid-allri-mismunun-hafa-tekid-gildi. 

28   See: https://www.althingi.is/lagas/nuna/2020144.html. 
29   Amended by Act No. 107/2021 which took effect on 1 January 2022, amending the Child Protection Act 
No. 80/2002, available at: https://www.government.is/media/velferdarraduneyti-media/media/acrobat-
enskar_sidur/Child-Protection-Act-as-amended-2016.pdf. 

30   Termination of Pregnancy Act No. 43/2019 (Lög um þungunarrof, nr. 43/2019). 

https://www.government.is/library/04-
Legislation/Termination%20of%20Pregnancy%20Act%20No%2043%202019.pdf. 

31   Act in respect of public limited companies No. 2/1995 with later amendments, 

https://www.government.is/lisalib/getfile.aspx?itemid=008e5636-3900-11e8-9427-005056bc4d74, Lög um 
hlutafélög nr. 2/1995, https://www.althingi.is/lagas/nuna/1995002.html. 

32   Act in respect of private limited companies, No. 138/1994 (Lög um einkahlutafélög No. 138/1994 með 

síðari breytingum), https://www.government.is/topics/business-and-industry/establishment-of-
company/company-law/. 

33   Media Act No. 38/2011, https://www.government.is/media/menntamalaraduneyti-
media/media/frettir2014/Thyding-log-um-fjolmidla-mai-2015-Lokagerd-a-vef.pdf. 

34   Public Finance Act No. 123/2015, https://www.government.is/library/01-Ministries/Ministry-of-

Finance/Public%20finance%20act.pdf. 

14 

 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

consultation with the minister responsible for gender equality, leads the formulation of a 
gender budgeting programme, which will be considered in the drafting of the Budget Bill. 
The Budget Bill must outline its effects on gender equality targets. 

The Gender Equality Fund, which was established in 2015 with parliamentary resolution 
No. 13/14435 and is operated in accordance with special rules on the allocation of funding 
No. 340/2019,36 was transferred to Rannís (the Icelandic Centre for Research).37 

The  Act  on  restaurants,  accommodation  and  festivities  No. 85/2007  stipulates  in 
Article 4(4) that restaurants are not permitted to provide nude shows or use their staff or 
others on the location to promote nudity.38 

35   See: https://www.althingi.is/altext/144/s/1456.html. 
36   See: https://www.stjornartidindi.is/Advert.aspx?RecordID=5464fe8a-b3e7-462d-8ac9-6766ec7df840. 
37   See: https://en.rannis.is/activities/. 
38   As provided for by Article 1 of Act No. 18/2010 amending Act No. 85/2007 on restaurants, 

accommodations, festivities, Lög um veitingastaði, gististaði og skemmtanahald, 
https://www.althingi.is/lagas/nuna/2007085.html. 

15 

 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

3 

Implementation of central concepts39 

  Sex/gender/transgender 

3.1.1  Definition of ‘gender’ and ‘sex’ 

The  GEA  No. 150/2020  has  a  new  title:  the  Act  on  equal  status  and  equal  rights 
irrespective of gender. Article 1 states that gender refers to women, men and people who 
are officially registered as gender neutral.40 There is really only one term in gender equality 
discourse (leaving aside more recent developments in LGBT concepts) to describe gender 
and sex, i.e. ‘kyn’. The Icelandic term ‘kyn’ (sex) refers to the difference between male, 
female  and  neutral  sex/gender  (karlkyn,  kvenkyn,  hvorugkyn)  –  the  term  ‘kyn’  is  both 
biological  and  sociological,  while  the  term  ‘kynferði’  (sexuality)  is  a  collective  term, 
including sex characteristics, gender, gender identity and gender expression.  

The  Act  on  Gender  Autonomy  No.  80  /2019  as  amended  by  Act  No.  159/2019,  No. 
152/2020 and No. 154/2020 entails the following definitions in Article 2: 

1. 

2. 

3. 
4. 
5. 

6. 

Gender (sexuality): a collective term, including sex characteristics, gender, gender 
identity and gender expression.  
Sex  characteristics:  biological  traits  related  to  gender,  such  as  sex  chromosomes, 
hormone function, gonads and genitals.  
Gender expression: a personal social expression with regard to one’s gender.  
Gender identity: the identification and definition of one’s gender.  
Physical integrity: the absolute right to autonomy over one’s body and entitlement 
to respect for one’s right to life, security, freedom and human dignity.  
Atypical sex characteristics: sex characteristics that fall outside traditional definitions 
of sex characteristics as male or female, e.g. as regards functionality or appearance. 

3.1.2  Protection of transgender, intersex and non-binary persons  

The  GEA clarifies in its  explanatory  report that the terms ‘men’ and ‘women’ in the law 
refer also to those who are trans. The term ‘woman’ also applies to a trans woman and 
the term ‘man’ to a trans man. The Act on Gender Autonomy No. 80/201941 provides for 
the  right  of  persons  to  define  their  own  gender,  thereby  aiming  to guarantee  the 
recognition of their gender identity. The prohibition of discrimination also applies to people 
who are registered as gender neutral. The objective of this Act is also to guard the rights 
of persons to physical integrity. The explanatory report to the law explains that the ‘gender 
identity’ of a person may conflict with their biological sex at birth leaving them unhappy 
with  their  sex  characteristics.  The  term  ‘gender’  refers  to  social  expectations  and 
paradigms based on sex characteristics. The categorisation of two biological sexes does 
not consider a trans person born with female sex characteristics but the gender identity of 
a  man  or  a  woman.  The  draft  also  refers  to  those  individuals  who  are  ‘non-binary’  or 
‘genderqueer’. The concepts ‘frjálsgerva’ and ‘kynsegin’ have been invented in Icelandic 
to refer to ‘non-binary’ and ‘genderqueer’. 

39   See Burri, S. (2018), EU gender equality law – update 2018, European network of legal experts in gender 
equality and non-discrimination, available at https://www.equalitylaw.eu/downloads/4767-eu-gender-
equality-law-update-2018-pdf-444-kb. 

40   CJEU, 30 April 1996. P v S and Cornwall County Council, C-13/94, ECLI:EU:C:1996:170. Cf. also 

Directive 2006/54/EC. 

41   See: https://www.government.is/library/04-

Legislation/Act%20on%20Gender%20Autonomy%20No%2080_2019.pdf.  

16 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

The Gender Autonomy Act42 No. 80/2019, replaces Act No. 57/2012 on the legal status of 
individuals with gender identity disorder which took effect on 27 June 2012.43 The Gender 
Autonomy  Act44  confirms  the  right  of  every  person  from  the  age  of  15  to  change  their 
gender in the official registry in accordance with their own experience and without having 
to  meet  conditions  for  diagnosis  or  medical  treatment.  The  Act  enables  trans  people  in 
Iceland to change their official gender according to their lived experience, and register as 
neither male nor female (denoted with an ‘X’ on documents). The Act also ensures that 
children under the age of 18 can change their registered gender and name in the National 
Registry with the consent of their parents or guardians. 

A child under the age of 15 may, with the assistance of its guardians, change its official 
gender registration. A child that does not have the support of one or both of its guardians 
in changing its gender registration may submit a request for a change of registered gender 
to an expert committee and have the registration changed if the committee accepts the 
request. The Act requires public and private bodies that register gender to provide for the 
possibility  of  registering  gender  as  neutral,  including  in  identity  documents,  forms  and 
databases. 

Permanent changes to genitals, gonads or other sex characteristics of persons 16 years of 
age or older are prohibited without their written consent. Furthermore, in cases involving 
children aged between 16 and 18, an assessment is needed from the Child and Adolescent 
Psychiatric  Department  team  on  gender  identity  pursuant  to  Article 13  of  the  Act,  to 
confirm  that  it  is  in  the  best  interests  of  the  child  to  perform  the  surgical  operation. 
Children  born  with  atypical  sex  characteristics  have  the  right  to  physical  integrity  in 
relation to their sex characteristics and the right to receive the best healthcare available 
at any given time. In implementing the Act, care must be taken to respect their right to 
self-determination regarding personal matters. 

Permanent  changes  to  the  sex  characteristics  of  a  child  born  with  atypical  sex 
characteristics can only be made in conformity with the will of the child. If a child under 
the age of 16 is unable to give its consent due to its young age or is  for  other reasons 
unable to express its will, the child’s sex characteristics may be changed if so required for 
health reasons, following a detailed assessment of the need for such changes and of their 
consequences  in  the  short  and  long  term.  Social,  psychosocial  and  appearance  related 
reasons are not to be regarded as health reasons. 

42   See: https://www.stjornarradid.is/efst-a-baugi/frettir/stok-frett/2019/06/18/Island-i-fremstu-rWod-i-

malefnum-hinsegin-folks-eftir-samthykkt-lagafrumvarps-forsaetisradherra-a-Althingi/. 

43   See: https://www.government.is/media/velferdarraduneyti-media/media/acrobat-enskar_sidur/Act-on-the-

legal-status-of-individuals-with-gender-identity-disorder-No-57-2012_220413.pdf. 

44   See: https://www.stjornarradid.is/efst-a-baugi/frettir/stok-frett/2019/06/18/Island-i-fremstu-rod-i-

malefnum-hinsegin-folks-eftir-samthykkt-lagafrumvarps-forsaetisradherra-a-Althingi/. 

17 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

Table 1: Protection of transgender, intersex and non-binary persons 

Are gender identity/transgender 
status/intersex status/sex 
characteristic etc. specific grounds of 
prohibited discrimination?  

The GEA No. 150/2020 clarifies in its 
explanatory report that the terms ‘men’ 
and ‘women’ in the law refer also to those 
who are trans.  

The Gender Autonomy Act No. 80/201945 
adopted in 2019 is intended to improve the 
legal status of trans and intersex 
individuals. 

3.1.3  Specific requirements 

Is discrimination against 
transgender, intersex and non-
binary persons forbidden on the 
basis of the existing prohibition on 
sex discrimination? 
Transgender, intersex and non-binary 
persons are protected from 
discrimination in the GEA No. 150/2020 
and the Gender Autonomy Act 
No. 80/2019. 

The  Gender  Autonomy  Act  ensures  that  children  under  the  age  of  18  can  change  their 
registered gender and name in the National Registry with the consent of their parents or 
guardians. If this consent is not available, the decision is put before an expert committee. 
The  Act  aims  to  respect  and  strengthen  the  self-determination  of  each  individual, 
recognising  that  their  own  understanding  of  gender  identity  is  the  basis  for  decision-
making regarding their public [gender] registration, as others are not better suited for this 
(according to a Government press release).46 The Act is also intended  to safeguard the 
individual’s right to bodily autonomy and a working group will be appointed to ensure the 
legal status of children born with atypical sex characteristics.47 

  Direct sex discrimination 

3.2.1  Explicit prohibition  

Article 16 of the GEA No. 150/2020 includes a general prohibition against discrimination, 
whether direct or indirect discrimination or multiple discrimination. 

Direct sex discrimination is defined in Article 2(1) of the GEA No. 150/2020 as being when 
an individual receives, based on gender, less favourable treatment than another individual 
receives,  has  received  or  would  receive  in  comparable  situations.  The  change  from  the 
previous  GEA  No. 10/2008  which  stated  ‘...  less  favourable  treatment  than  another 
individual  of  the  opposite  sex  receives  ...’  is  in  accordance  with  the  GEA  (Act  on  equal 
status  and  equal  rights  irrespective  of  gender  No. 150/2020),  which  prohibits 
discrimination on the bases of more genders than two so the reference to the ‘opposite’ 
sex  is  no  longer  relevant.  The  term  ‘gender’  is  defined  in  Article 1  of  the  GEA,  which 
provides  that  the  term  ‘gender’  means  women,  men  and  persons  whose  gender  is 
registered as neutral in Registers Iceland, unless otherwise stated. 

The definition complies with the EU definition in Directive 2006/54, Article 2(1)(a), which 
defines direct discrimination as: ‘where one person is treated less favourably on grounds 
of sex than another is, has been or would be treated in a comparable situation’.  

45   See: https://www.government.is/library/04-

Legislation/Act%20on%20Gender%20Autonomy%20No%2080_2019.pdf. 

46   See: https://www.stjornarradid.is/efst-a-baugi/frettir/stok-frett/2019/06/18/Island-i-fremstu-rod-i-

malefnum-hinsegin-folks-eftir-samthykkt-lagafrumvarps-forsaetisradherra-a-Althingi/. 

47   See: https://samradsgatt.island.is/oll-mal/$Cases/Details/?id=1301. 

18 

 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

3.2.2  General discrimination 

A prohibition of general discrimination can be easily derived from the existing rules in the 
GEA as well as in the Constitution. 

Article 65 of the Constitution has an explicit non-discrimination clause, stating: 

‘1. Everyone shall be  equal before the law and enjoy human rights irrespective of 
sex, religion, opinion, national origin, race, colour, property, birth or other status. 
2. Men and women shall enjoy equal rights in all respects.’ 

There are no cases on discrimination without an actual victim. The Code of Civil Procedure 
No. 91/1991 provides in Article 25(1) that: ‘Courts may not be required to give opinions 
on  legal  matters  or  on  whether  a  specific  event  has  taken  place  except  to  the  extent 
necessary to resolve a specific claim in a court case’.  

3.2.3  Specific difficulties 

None in particular. Direct discrimination is the most common ground of complaints to the 
Equality Complaints Committee. 

  Indirect sex discrimination48 

3.3.1  Explicit prohibition 

Article 16  of  the  GEA  No. 150/2020  includes  a  general  prohibition  of  discrimination 
(Article 16(1)). All forms of discrimination, direct or indirect, on grounds of gender, are 
prohibited.  

Indirect  discrimination  is  defined  in  Article 2(2)  of  the  GEA  No. 150/2020:  when  an 
apparently  neutral  provision,  criterion  or  practice  would  put  persons  of  either  sex  at  a 
disadvantage  compared  with  persons  of  the  other  sex,  unless  this  can  be  objectively 
justified  by  a  legitimate  aim,  and  the  means  of  achieving  that  aim  are  appropriate  and 
necessary.  In  defining  ‘indirect  discrimination’  in  Article 2(2),  the  words  ‘of  one  sex’ 
replace the words ‘opposite sex’ in the older law.  

When the concept of indirect discrimination was introduced in the GEA No. 96/2000, the 
explanatory report defined the concept in accordance with Article 2(2) of Directive 97/80, 
the most obvious exceptions are the jobs of actors and guards in swimming pools. 

The definition of indirect discrimination complies with the Recast Directive 2006/54. 

3.3.2  Statistical evidence 

Statistical  evidence  is  not  required  according  to  the  GEA.  This  was  clarified  in  the 
explanatory  report  to  the  previous  GEA  No. 10/2008,  which  stated  that  the  obligations 
that Iceland has on the basis of the EEA Treaty and in accordance with Directive 76/207/EC 
as  amended  by  Directive 2002/73/EC  (Equal  Treatment  in  Access  to  Employment),  it  is 
enough to adduce that a practice puts a person of either sex at a disadvantage. 

48   See for more information Mulder, J. (2021) Indirect sex discrimination in employment, European network of 

legal experts in gender equality and non-discrimination, available at: 
https://www.equalitylaw.eu/downloads/5362-indirect-discrimination-in-employment-pdf-1-434-kb. See 
also: Oddsson, H. (2009) ‘Indirect discrimination on the basis of personal characteristics - The legal status 
in European law and Icelandic law’ - master's thesis, 
https://skemman.is/bitstream/1946/2398/1/pd_fixed.pdf. 

19 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

3.3.3  Application of the objective justification test 

There is no case law regarding the objective justification test for indirect discrimination.  

The  Equality  Complaints  Committee,  which  deals  with  most  of  the  discrimination  cases 
iterates  that  it  does  not,  on  the  basis  of  Article 19(5),  have  independent  permission  to 
assess aspects or viewpoints other than those that the defendant him/herself has based 
their decision on. Neither does the Committee have permission to reassess the relevance 
of the aspects as long as they are objective and within the scope that the defendant has 
identified  (see  the  explanatory  report  to  Act  No. 150/2020).  It  is  not  within  the 
competence  of the  Committee to  reconsider the assessment which prevailed during the 
employment  process  unless  it  can  be  deduced  from  the  merits  of  the  case  that  the 
assessment was not justifiable. 

The Committee’s approach is very narrow and it is probably safe to assume that it has not 
always succeeded in applying the objective justification test correctly.  

3.3.4  Specific difficulties 

There  are  no  evident  specific  difficulties  in  applying  the  concept  of  indirect  sex 
discrimination as regards the legislation. The Equality Complaints Committee has not dealt 
with the issue explicitly although it may be adduced from the merits of some cases that 
the core issue was indirect discrimination. 

  Multiple discrimination and intersectional discrimination49 

The  term  ‘multiple  discrimination’  has  been  added  to  the  definitions  of  concepts  in 
Article 2(3) of the GEA No. 150/2020. 

Multiple discrimination has come to the forefront in recent years. The newly adopted Act 
on the administration on matters concerning equality No. 151/2020, adopted in January 
2021 applies to administration in the field of equality within the area covered by laws on 
equality, i.e. the Act on equal status and equal rights irrespective of gender, the Act on 
equal treatment irrespective of race or ethnic origin, and the Act on equal treatment on 
the labour market. Act No. 151/2020 applies, among other things, to the activities of the 
Directorate of Equality and the Equality Complaints Committee. Should the Directorate of 
Equality  have  a  reasoned  suspicion  that  an  institution,  company  or  civil  society 
organisation has violated the equality acts referred to in Article 1, it must check whether 
there  is  reason  to  request  that  the  matter  be  brought  before  the  Equality  Complaints 
Committee.  

3.4.1  Definition and explicit prohibition 

The Act on equal status and equal rights irrespective of gender No. 150/2020 defines the 
concept  of  multiple  discrimination  in  Article 2(3):  when  an  individual  is  subjected  to 
discrimination on the basis of more than one discrimination ground that the Act on equal 
treatment  irrespective  of  race  or  ethnic  origin,  and  the  Act  on  equal  treatment  on  the 
labour market provide protection against. Multiple discrimination can either be integrated 
in  such  a  way  that  two  or  more  grounds  for  discrimination  create  a  special  basis  for 
discrimination,  or  it  can  be  dual/multiple  so  that  the  discrimination  is  based  on  two  or 
more independent grounds of discrimination. 

The term intersectional discrimination remains a theoretical concept outside the law. 

49   See for more information Fredman, S. (2016), Intersectional discrimination in EU gender equality and non-
discrimination law, European network of legal experts in gender equality and non-discrimination, available 
at https://www.equalitylaw.eu/downloads/3850-intersectional-discrimination-in-eu-gender-equality-and-
non-discrimination-law-pdf-731-kb. 

20 

 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

The Act on equal treatment irrespective of race and ethnic origin No. 85/2018 entered into 
force on 1 September 2018. The objective of the law is to prevention discrimination on the 
basis of race and ethnic origin and to enhance social integration, prevent social isolation 
and  racial  prejudice.  This  act  applies  to  all  spheres  of  society,  although  not  family  and 
private  life,  and  it  is  not  geared  towards  the  labour  market,  which  comes  under  Act 
No. 86/2018 on equal treatment on the labour market. This latter act entered into force 
on  1 September  2018  and  is  intended  to  implement  the  principle  of  equal  treatment  of 
individuals  on  the  labour  market,  irrespective  of  their  race,  ethnic  origin,  religion,  life 
stance,  disability,  reduced  working  capacity,  age,  sexual  orientation,  gender  identity, 
sexual  characteristics  or  gender  expression,  for  example  as  regards:  a)  access  to  jobs, 
self-employment or occupational sectors, including recruitment and promotion; b) access 
to  educational  and  vocational  counselling,  vocational  education  and  vocational  training; 
c) decisions in connection with wages, other terms of service and notice of termination; 
and  d)  participation  in  workers’  and  employers’  organisations,  including  the  perquisites 
(benefits) that they provide to their members. 

3.4.2  Case law and judicial recognition  

The Equality Complaints Committee handles complaints submitted to it in relation equality 
legislation, i.e. the GEA No. 150/2020, the Act on equal treatment irrespective of race or 
ethnic origin and the Act on equal treatment on the labour market (see Articles 7 and 1 of 
the Act on the administration of matters concerning equality No. 151/2020, which entered 
into force in January 2021).  

In 2024, the Equality Complaints Committee ruled there had been multiple discrimination 
regarding employment in case 8/2023 (5 July 2024). A man complained that he had been 
discriminated  against  on  the  basis  of  gender  and  age  in  the  recruitment  of  a 
pharmacologist at the National Hospital (the job was given to a woman). Scrutinising the 
employment  process,  the  Equality  Complaints  Committee  held  that  the  decision  of  the 
defendant to hire the woman had not been based on an objective and factual approach 
and hence the defendant had not been able to prove that factors other than gender and 
age had prevailed in hiring the younger woman. 

In another case, although the Equality Complaints Committee did not find that there had 
been  multiple  discrimination,  it  nevertheless  concluded  that  the  claimant  had  been 
dismissed for seeking redress. The complaint concerning multiple discrimination stemmed 
from  the  dismissal  of  A  by  B  ehf.,50  after  A  demanded  redress  for  being  discriminated 
against  regarding  terms  of  employment  on  the  basis  of  gender,  race  and  ethnic  origin 
(case  No.  6/2024).  The  Equality  Complaints  Committee  did  not  find  that  A  had  been 
discriminated against regarding wages and other terms of employment, (Article 19(2) of 
the  GEA,  and  Articles  9  and  15  of  Act  No.  86/2018  on  Equal  Treatment  on  the  Labour 
Market). Accordingly, A had not been subject to multiple discrimination. On the other hand, 
the  Equality  Complaints  Committee  found  that  likelihood  had  been  adduced  that  A  had 
been  dismissed  for  demanding  redress  regarding  discrimination  in  respect  of  terms,  in 
accordance with Article 20(1) of the GEA and Article 13(1) of Act No. 86/2018, and that 
the employer had not been able to demonstrate that the dismissal was not based on A’s 
demand for redress. B ehf. was subsequently obliged to pay A’s legal costs. 

50   Ehf. stands for einkahlutafélag, a private limited company /limited liability company. 

21 

 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

  Positive action 51 

3.5.1  Definition and explicit prohibition 

The principle of equality enshrined in Article 65(1) of the Icelandic Constitution since 1995 
provides that everyone is equal before the law irrespective of sex and other enumerated 
factors.  Yet  despite  this,  a  second  paragraph  was  added  at  a  later  stage  during  the 
amendment process to Article 65 stating: ‘Men and women shall enjoy equal rights in all 
respects.’  This  paragraph  is  certainly  not  a  redundancy  but  was  seen  as  a  necessary 
addition to  strengthen  gender  equality in  society;52 it is a clear indication  of the  strong 
emphasis on the need for action to achieve gender equality without explicitly mentioning 
the need for temporary, positive measures in favour of the under-represented sex.  
Special measures / Affirmative action are defined in Article 2(8) of the GEA No. 150/2020 
as:  

‘special temporary measures that are intended to improve the position of, or increase 
the opportunities of, women or men aimed  at establishing the  equal  status of the 
sexes in a specific field where either sex is at a disadvantage. In such cases it may 
prove necessary to give either sex temporary priority in order to achieve balance. 
Furthermore, special temporary measures are intended to improve or increase the 
opportunities  of  people  in  the  fields  where  they  are  at  a  disadvantage  because  of 
neutral gender in the official register in order to conduce to equal treatment.’ 

The above definition is substantially the same as in the previous GEA No. 10/2008, adding 
the  last  paragraph  to  include  people  officially  registered  as  gender  neutral.  Affirmative 
action  is  not  seen  as  going  against  the  GEA,  as  it  is  justified  to  correct  an  imbalanced 
situation. 

Article 16 of the GEA No. 150/2020 includes a general prohibition against discrimination, 
whether  direct  or  indirect,  as  well  as  against  multiple  discrimination.  In  its  second 
paragraph  it  provides  that  special  measures  (affirmative  actions)  are  not  regarded  as 
contrary to the GEA. The same applies if there are valid reasons to support employing an 
individual of a particular gender in view of objective factors relating to the job. Paragraph 
3  under  this  provision  holds  that  special  consideration  to  women  in  connection  with 
pregnancy and childbirth shall not be regarded as discrimination. 

The  system  of  equal  pay  certification  under  Article 7  of  the  GEA  No. 150/2020  calls  for 
positive  action  on  the  part  of  the  employer,  i.e.  it  is  mandatory  to  prove  that  wage 
decisions are based on relevant considerations and not on gender. 

Article 4  of  the  GEA  No. 150/2020  provides  that  employers  and  trade  unions  must 
systematically  work  towards  equalising  the  position  of  women  and  men  in  the  labour 
market. Employers must specifically work towards equalising the position of women and 
men within their companies or institutions and promote a classification of jobs that does 
not  designate  them  as  specifically  women’s  or  men’s  jobs.  Special  emphasis  must  be 
placed on equalising the positions of women and men as regards managerial and influential 
positions. 

Article 12(2) of the GEA No. 150/2020 (on vacancies, vocational training, retraining and 
continuing  education  /  lifelong  learning)  stipulates  that  employers  must  take  special 
measures to  ensure that women, men and people  registered publicly  as gender neutral 

51   See for more information McCrudden, C. (2019), Gender-based positive action in employment in Europe. A 
comparative analysis of legal and policy approaches in the EU and EEA, 2019, European network of legal 
experts in gender equality and non-discrimination, available at: 
https://www.equalitylaw.eu/downloads/5008-gender-based-positive-action-in-employment-in-europe-pdf-
1-9-mb. 

52   Alþt. 1994-95, A-deild, þskj. 759, bls. 3888. 

22 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

have  equal  opportunities  regarding  retraining,  continuing  education  and  vocational 
training, and to attend courses held to enhance vocational skills or to prepare for other 
work  assignments.  Article 13  of  the  GEA  stipulates  that  employers  must  take  special 
measures  to  enable  workers  to  reconcile  their  professional  obligations  and  family  life 
independent of their sex. Such measures entail increased flexibility in the organisation of 
work and working hours and having regard to workers’ family circumstances and the needs 
of  the  labour  market,  including  facilitating  the  return  of  employees  to  work  following 
maternity/paternity or parental leave or leave from work due to pressing and unavoidable 
family  circumstances.  Article 14  of  the  GEA  stipulates  that  employers  and  directors  of 
institutions and NGOs must take special measures to protect employees, students and the 
users  of  services  from  gender-based  violence,  gender-based  harassment  or  sexual 
harassment in the workplace, in institutions and in their work, etc. 

Affirmative  action  is  defined  in  Article 3(5)  of  Act  No. 85/2018  as  special  temporary 
measures that are intended to improve the position of persons in fields where they are at 
disadvantage, with the exception of the labour market, based on their race or ethnic origin, 
to further equal treatment. 

3.5.2  Conceptual  distinctions  between  ‘equal  opportunities’  and  ‘positive  action’  in 

national law 

Preventing discrimination on the basis of sex and establishing and maintaining equal status 
and equal opportunities for women and men in all spheres of society are the stated aims 
of  the  Gender  Equality  Act  No. 150/2020  (GEA)  as  stipulated  in  its  Article 1.  What  is 
required to fulfil and promote these aims is specified in Sections (a) to (m), which include: 
working to secure equal influence of women and men; specifically improving the situation 
of  women  and  increasing  their  opportunities  in  society;  working  against  wage 
discrimination; and enabling everyone to reconcile their work and family life independent 
of their sex, etc. Promoting equal opportunities may mean guaranteeing the absence of 
legal discrimination, but may also involve the implementation of substantive measures to 
achieve this. 

The above objectives may require special measures / affirmative action which is explicitly 
defined in Article 2(8) of the GEA. The difference is that equal opportunities constitute a 
negative right, albeit with positive connotations, prohibiting gender-based discrimination 
by  law,  while  the  latter  term  always  calls  for  special  measures  to  be  taken  to  ensure  a 
more  substantive  contribution  to  gender  equality.  There  is,  however,  an  interaction 
between the concepts, as evident from the explanatory report where ‘equal opportunities’ 
in Article 1 of the GEA are seen in interaction with other means intended to increase the 
opportunities for women in society, such as gender mainstreaming. 

3.5.3  Specific difficulties  

Special measures to enhance gender equality are not necessarily costly although in some 
cases they entail financial burdens. The cost of implementing the equal pay certification 
system is high, and relatively so for smaller companies.53 The process is both time and 
work  consuming.  Another  example  is  the  Maternity/Paternity  Leave  Act  (Maternity, 
Paternity Leave and Parental Leave Act No. 95/2000), which has inter alia the objective of 
enabling both women and men to reconcile work and family life (Article 2). This is based 
on a fund that is financed through the collection of an insurance levy that every employer 
and self-employed person must pay in the form of a tax (under the Insurance Levy Act). 
This is a burden for many self-employed people who have limited revenues. Guaranteeing 
rights, such as gender equality, is costly when such special measures are called for.  

53   A survey in 2024 by the Confederation of Icelandic Enterprise (SA) shows that the real cost of those firms 

implementing the equal pay standard was ISK 7.6 million (EUR 52 660), available at 
https://www.sa.is/frettatengt/frettir/jafnlaunavottun-mikill-kostnadur-litill-avinningur. 

23 

 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

3.5.4  Measures to improve the gender balance on company boards54 

Act  No. 13/2010  amended  the  Public  Limited  Companies  Act  No. 2/1995  as  well  as  the 
Private Limited Companies Act No. 138/1994, implementing gender quotas on company 
boards. The Act took effect on 1 September 2013. The law establishes that, in companies 
with more than 50 employees, both genders must be represented on the board. As regards 
the question whether the Act No 80/2019 impacts the implementation of this requirement 
it must be highlighted that the said Act concerns the right of persons to define their own 
gender identity. The Act on Public Limited Companies has not been amended to include 
neutral gender representation and here it must be taken into account that women are half 
of the population while the number of gender neutral individuals registered in 2022 were 
70.When  the  board  is  composed  of  more  than  three  members,  the  proportion  of  each 
gender  must  not  be  lower  than  40 %.  The  same  applies  to  the  gender  ratio  among 
alternates. In addition, all companies falling under the scope of the Act must take gender 
ratio  perspectives  into  consideration  in  the  recruitment  of  CEOs,  and  all  public  limited 
companies with more than 25 employees must report the relevant statistics to the register 
of  limited  companies.  Furthermore,  both  the  Public  Limited  Companies  Act  55  and  the 
Gender Equality Act provide that employers must take steps to avoid jobs being classified 
as  specifically  women’s  or  men’s  jobs  and  that  particular  emphasis  must  be  placed  on 
achieving equal representation of women and men in managerial and influential positions, 
the beneficiary being the under-represented sex. 

According to Article 63(2) of the Public Limited Companies Act, a board of directors must 
be elected by a shareholders’ meeting. It is permissible for articles of association to grant 
authorities or others the right to nominate one or more directors. The majority of a board 
of  directors  must,  however,  at  all  times  be  elected  by  a  shareholders’  meeting.  The 
directors who are elected must all be elected at the same meeting. 

The law covers the boards of state-owned public companies, corporations, public limited 
companies  and  private  limited  companies,  as  well  as  pension  funds  with  more  than 
50 employees on an annual basis. In 2011 the boards of pension funds were also subject 
to gender quotas by amendments to the 1997 pension fund legislation (129/1997),56 which 
took effect on 1 September 2013. 

There  are  stricter  requirements  for  public  limited  companies  than  private  limited 
companies.  Only  1 %  of  private  limited  companies  in  Iceland  have  more  than 
50 employees on an annual basis.57 These must observe special rules on gender equality 
on company boards. If the board of directors of a private limited company with more than 
50  employees  comprises  two  or  three  board  members,  each  gender  must  have  a 
representative.  If  there  are  three  or  more  board  members  the  40 %  gender  ratio  rule 
applies. 

The amendments to the Icelandic acts on public and private limited companies concerning 
gender  balance  on  company  boards  were  adopted  many  years  earlier  than 
Directive 2022/2381 and do not lag behind the required measures. 

54   See for more information Senden, L. and Kruisinga S., (2018) Gender-balanced company boards in Europe. 
A comparative analysis of the regulatory, policy and enforcement approaches in the EU and EEA Member 
States, available at https://www.equalitylaw.eu/downloads/4537-gender-balanced-company-boards-in-
europe-pdf-1-68-mb. 

55   Gender Equality Act No. 10/2008 and the Public Limited Companies Act (No. 2/1995 with later 

amendments), https://www.government.is/lisalib/getfile.aspx?itemid=008e5636-3900-11e8-9427-
005056bc4d74. 

56   Act No. 129H/1997 on mandatory pension insurance and on the activities of pension funds (Lög um 

skyldutryggingu lífeyrissréttinda og starfsemi lífeyrissjóða, nr. 129/1997), 
https://www.althingi.is/lagas/nuna/1997129.html. 

57   See: https://hagstofa.is/utgafur/frettasafn/fyrirtaeki/stjornir-fyrirtaekja-2022/. 

24 

 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

3.5.5  Positive action measures to improve the gender balance in other areas  

The quota rules apply to all firms above a certain size on the labour market and there is 
furthermore  an  obligation  to  ensure  gender-balanced  appointments  in  Government  and 
municipal  committees,  councils  and  boards.  Article 28  of  the  GEA  No. 150/2020  adds  a 
paragraph  (the  fourth)  stating  that  this  provision  does  not  prevent  the  appointment  in 
Government  and  municipal  committees,  councils  and  boards  of  people  who  are  publicly 
registered as gender neutral where  care must  be taken to  ensure the representation of 
women and men is as equal as possible and not lower than 40 % for each gender. This 
provision also applies to the boards of publicly-owned limited companies and enterprises 
in which the state or a municipality is the majority owner. The proportion of women must, 
however, never be lower than 40 %. 

As regards lists of candidates prior to elections it is up to the political parties whether they 
present gender balanced lists, which most of them do. 

Further to that, there is a general duty imposed on all employers on the labour market to 
put women and men on an equal footing within their enterprise or institution and to take 
steps to avoid jobs being classified as specifically women’s or men’s jobs (see Article 1(k) 
stating the aims of the GEA). 

  Harassment and sexual harassment 

3.6.1  Definition and explicit prohibition of harassment 

Article 2(4)  of  the  GEA  No. 150/2020  defines  gender-based  harassment  as:  behaviour 
linked to the affected person’s gender, having the purpose or effect of offending the dignity 
of the person involved and creating circumstances that are threatening, hostile, degrading, 
humiliating or insulting for the person in question, or which has this effect.  

The  provision  does  not  include  the  word  ‘unwanted’  before  the  word  ‘conduct’  from 
Article 2(1)(c  )  of  Directive 2006/54  or  the  word  ‘intimidating’  in  describing  the 
circumstances  but  uses  ‘threatening’  instead.  The  word  ‘unwanted’  was  considered 
unnecessary,  according  to  the  explanatory  report  to  the  GEA,  as  the  carrying  out  of 
gender-based  and  sexual  harassment  aims  to  offend  the  dignity  of  the  person  involved 
and create circumstances that are threatening, hostile, degrading, humiliating or insulting 
for  the  person  in  question.  The  word  ‘unwelcome’,  which  was  in  the  previous  GEA 
No. 10/2008  in  relation  to  gender-based  and  sexual-harassment  is  seen  as  placing  the 
liability on the victim rather than perpetrator and was not included in the definition of the 
GEA No. 150/2020.  

3.6.2  Scope of the prohibition of harassment 

Employers and directors of institutions and NGOs must take special measures to protect 
employees, students and the users of services from gender-based violence, gender-based 
harassment and sexual harassment in the workplace, in institutions, in their work for, or 
the functions of, their organisations or in schools, as stipulated in Article 14(1) of the GEA 
No. 150/2020. If a superior is charged with any of the above forms of conduct, they will 
not be entitled to take decisions regarding the working conditions of the claimant during 
the  examination  of  the  case,  and  the  immediate  superior  must  take  such  decisions, 
(Article 14(2)).  

3.6.3  Definition and explicit prohibition of sexual harassment 

Article 2(5)  of the  GEA  No. 150/2020 defines  sexual harassment as:  any kind of sexual 
behaviour having the purpose or effect of offending the dignity of the person involved and 

25 

 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

creating  circumstances  that  are  threatening,  hostile,  degrading,  humiliating  or  insulting 
for the person in question. The behaviour can be verbal, symbolic or physical.  

the  EU  definition 

This  definition  complies  with 
in  Article 2(1)(d)  of 
Directive 2006/54/EC and grants even broader protection to the victim. The previous GEA 
No. 10/2008  required  that  the  sexual  behaviour  must  be  ‘unwelcome  to  the  person 
affected by it’. This is no longer a requirement as it is viewed as onerous for the victim. 
Hence, the Icelandic definition goes further than the EU definition condemning the conduct 
without requiring proof that it was ‘unwanted’ or ‘unwelcome’. 

found 

3.6.4  Scope of the prohibition of sexual harassment 

As  stipulated  in  Article 14(1)  of  the  GEA  No. 150/2020,  employers  and  directors  of 
institutions  and  NGOs  must  take  special  measures  to  protect  employees,  students  and 
users  of  services  from  gender-based  violence,  gender-based  harassment  and  sexual 
harassment in the workplace, in institutions, in their work for, or the functions of, their 
organisations or in schools. If a superior is charged with any of the above forms of conduct, 
they will not be entitled to take decisions regarding the working conditions of the claimant 
during the examination of the case, and the immediate superior must take such decisions.  

Regulation  on  measures  against  sexual  harassment,  gender-based  harassment  and 
violence in workplaces No. 1009/2015 provides that an employer must react swiftly when 
receiving notice of such conduct or circumstances in the workplace and immediately act 
to prevent such incidents. Under Chapter II of the regulation, employers must produce a 
written  plan  regarding  health  and  safety  in  the  workplace  to  reduce  the  likelihood  of 
circumstances  that  can  foster  harassment,  sexual  as  well  as  gender-based  harassment 
and violence. 58 

3.6.5  Understanding of (sexual) harassment as discrimination 

Gender-based  harassment  and  sexual  harassment  constitute  discrimination  under 
Article 16 of the GEA in accordance with Article 2(2)(a) of Directive 2006/54). 

3.6.6  Specific difficulties  

The  definitions  of  gender-based  harassment  and  sexual  harassment  in  the  glossary  in 
Article 2(4)  and  (5)  of  the  GEA  no.  150/2020  are  based  on  the  EU  directives,  as  in 
2002/73/EU. After the adoption of the previous GEA No. 10/2008 the EFTA Surveillance 
Authority  (ESA)  observed  that  the  definitions  were  not  fully  in  line  with  the  Recast 
Directive 2006/54/EU.  This  was  corrected  through  Act  No. 62/2014  amending  the  GEA 
No. 10/2008, but the main observation of ESA concerning the previous provisions was the 
requirement that to qualify as gender-based harassment or sexual harassment the conduct 
had to continue despite being declared as unwelcome. This was considered to obstruct the 
burden  of  proof  for  the  alleged  victims  and  to  be  standing  in  way  of  achieving  the 
Directive’s objective. The previous GEA was accordingly amended. The GEA No. 150/2020 
has additionally removed the word ‘unwelcome’ from the previous definition as including 
such a word in prescribing the conduct was believed to put too much of a burden on the 
victim instead of the offender. 

In 2022 there was a discrepancy between the amended definition of sexual and gender-
based  harassment  in  the  GEA  No. 150/2020  and  the  regulation  on  measures  against 
sexual  harassment,  gender-based  harassment  and  violence 
in  workplaces 
No. 1009/2015,59  which  provides  that  an  employer  must  react  swiftly  when  receiving 
notice of such conduct or circumstances in the workplace and immediately act to prevent 

58   See: https://www.reglugerd.is/reglugerdir/eftir-raduneytum/velferdarraduneyti/nr/19859. 
59   See: https://www.reglugerd.is/reglugerdir/eftir-raduneytum/velferdarraduneyti/nr/19859. 

26 

 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

such incidents. In 2022, the regulation was still based on the older definition of sexual and 
gender-based  harassment  in  accordance  with  the  Act  No. 10/2008,  which  required  that 
such  behaviour  must  be  ‘unwelcome  to  the  person  affected  by  it’. 60  With  regulation 
No. 211/202361 amending regulation No. 1009/2015, the words ‘unwelcome’ and ‘against 
somebody’s wishes’ were  removed from the definition as including them was viewed as 
onerous for the victim of such conduct. 

  Instruction to discriminate 

3.7.1  Explicit prohibition 

Article 16  of  the  GEA  No. 150/2020  (general  prohibition  of  discrimination)  stipulates 
explicitly that giving instructions to discriminate on the grounds of gender also constitutes 
discrimination under the act.  

The EFTA Surveillance Authority (ESA) found that Article 2(2)(b) of Directive 2006/54 had 
not been transposed correctly in the previous GEA No. 10/2008 after it was adopted. ESA 
noted that Article 2(2)(b) applied to ‘any type of discrimination, whether it relates to pay, 
working conditions, and/or harassment. Furthermore, this provision makes it possible to 
challenge, for example, the behaviour of employers drawing on the services of recruitment 
agencies if they require candidates to be screened according to discriminatory criteria’.62 

The current definition is fully in line with Directive 2006/54 except it uses the term ‘gender’ 
instead of ‘sex’ as the GEA applies to women, men and persons whose gender is registered 
as neutral in Registers Iceland. 

3.7.2  Specific difficulties 

The author is not aware of any specific difficulties. 

  Other forms of discrimination 

Apart  from  Article 65  of  the  Constitution  (already  discussed  in  sections  2.1  and  3.2.2 
above)  and  Article 14  of  the  European  Convention  on  Human  Rights  adopted  into  the 
domestic  legal  system  in  1994,  other  forms  of  discrimination  are  covered  by  the  legal 
provisions outlined below. 

Article 1  of  the  Act  on  part-time  work,  No. 10/200463  is  intended  to  prevent  part-time 
workers from being discriminated against. 

Article 37 of Act No. 38/2011 (Media Act)64prohibits subliminal techniques in audio-visual 
commercial communications that include or promote any discrimination based on gender, 
racial or ethnic origin, nationality, religion, belief, disability, age or sexual orientation.  

Act  No. 27/2000  on  the  prohibition  on  termination  of  employment  due  to  family 
responsibilities states in Article 1:  

‘No  person’s  employment  may  be  terminated  solely  because  of  his  or  her  family 
responsibilities. 
the  employee’s 
responsibilities towards his or her children, spouse or close relatives who live in the 
employee’s home and clearly need his or her care or custody, for example as a result 
of illness or disability.’ 

responsibilities”  here 

“Family 

refers 

to 

60   Regulation No. 211/2023 amending regulation No. 1009/2015. 
61   See: https://www.reglugerd.is/reglugerdir/eftir-raduneytum/velferdarraduneyti/nr/23483. 
62   See: https://www.eftasurv.int/cms/sites/default/files/documents/gopro/3194-628301.pdf.  
63   Lög um starfsmenn í hlutastörfum nr. 10/2004, https://www.althingi.is/lagas/nuna/2004010.html. 
64   Media Act No. 38/2011 (Lög um fjölmiðla, nr. 38 20. apríl 2011). 

27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

  Evaluation of implementation 

The provisions of national law appear to satisfactorily cover the area under scrutiny. 

In the recent GEA No. 150/2020, the word ‘gender’ replaces the word ‘sex’. The main aim 
of  the  act  is  that  all  people  should  have  equal  opportunities  to  benefit  from  their  own 
enterprise and to develop their skills irrespective of gender. The term ‘gender’ in the GEA 
means  women,  men  and  persons  whose  gender  is  registered  as  neutral  in  Registers 
Iceland, unless otherwise stated. Another issue where Iceland has led the way concerns 
gender-balanced representation on company boards; following amendments to the laws 
on cooperatives  (No. 22/1991) public  limited  companies  (No. 2/1995),65  private  limited 
companies (No. 138/1994),66 and partnerships (50/2007), companies that have over 50 
employees  are  required  to  have  both  women  and  men  on  their  company  boards  and  if 
there are more than three board members, the percentage of women or men cannot be 
below 40 %. These amendments also included changes that will make monitoring easier. 
The  amendments  of  Act  No. 13/2010  took  effect  in  2013,  almost  a  decade  before 
Directive 2022/2381 was introduced.  

 Remaining issues 

There do not appear to be any remaining issues regarding the central concepts of gender 
equality law that have not been discussed so far.  

65   Act in respect of public limited companies No. 2/1995 with later amendments, 

https://www.government.is/lisalib/getfile.aspx?itemid=008e5636-3900-11e8-9427-005056bc4d74, Lög um 
hlutafélög nr. 2/1995, https://www.althingi.is/lagas/nuna/1995002.html. 

66   Act in respect of private limited companies, No. 138/1994 (Lög um einkahlutafélög No. 138/1994 með 

síðari breytingum), https://www.government.is/topics/business-and-industry/establishment-of-
company/company-law/. 

28 

 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

4 

Equal  pay  and  equal  treatment  at  work  (Article 157  of  the  Treaty  on  the 
Functioning of the European Union (TFEU) and Recast Directive 2006/54) 67 

  General (legal) context 

The objective of the GEA is to work against pay discrimination and other forms of gender-
based  discrimination  in  the  employment  market,  including  by  having  companies  and 
institutions fulfil the conditions of equal pay certification or equal pay confirmation. Despite 
the legal prohibition against pay discrimination, the gender pay gap persists and has only 
changed  minimally  throughout  the  years.  The  unadjusted  pay  gap  between  men  and 
women was 10.2 % in 2021, which is a slight improvement on the previous year when it 
was  11.9 %.68  The  pay  gap  increases  with  age:  the  gap  is  0.9 %  in  the  24  years  and 
younger age group, 10 % in the 35-44 age group and 16.7 % in the  55-64 age group. 
There is a huge difference in pay between different spheres of work. In the financial and 
insurance business, the gender pay gap is 29.7 %. The smallest gender pay gap is in the 
heating, gas and electricity services where it is 4.3 %. 

The pay gap between men and women on the basis of their work sector is 0.5 % between 
office workers and 21.5 % amongst those with technical or special education. According 
to research from 2021, the main explanation for this pay gap is the gender-based division 
in job sectors. 69 The research showed that 43 % of women on the labour market in 2019 
were employed in the public sector while only 15 % of men. The gender pay gap on the 
labour market was 13.9 %: 10 % amongst those working in the public sector and 6.1 % 
for those employed by municipalities. 

There  are  proportionally  more  women  in  lower  paid  jobs  than  men.  There  is  sectoral 
segregation in the labour market meaning that women are proportionally more numerous 
in lower paid jobs. In general, men tend to work overtime and thus have higher pay per 
hour.70 

4.1.1  Political and societal debate and pending legislative proposals 

The equal pay certification system was adopted with Act No. 56/2017 amending Article 19 
of  the  GEA  on  wage  equality  and  took  effect  on  1  January  2018.  The  purpose  of  the 
obligatory  equal  pay  certification  is  to  enforce  the  current  legislation  prohibiting 
discriminatory practices based on gender and requiring that women and men be paid equal 
wages  and  enjoy  equal  terms  of  employment  for  the  same  jobs  or  jobs  of  equal  value. 
Companies and institutions employing 25 or more workers are required on an annual basis 
to obtain equal pay certification of their equal pay system and the implementation thereof. 
In accordance with the legislation, certification must meet the requirements of the equal 

67   See on equal pay Burri, S. (2019), National Cases and Good Practices on Equal Pay, European network of 

legal experts in gender equality and non-discrimination, available at 
https://www.equalitylaw.eu/publications/thematic-reports. 
See also Foubert, P. (2017), The enforcement of the principle of equal pay for equal work or work of equal 
value: A legal analysis of the situation in the EU Member States, Iceland, Liechtenstein and Norway, 
European network of legal experts in gender equality and non-discrimination, available at 
https://www.equalitylaw.eu/downloads/4466-the-enforcement-of-the-principle-of-equal-pay-for-equal-
work-or-work-of-equal-value-pdf-840-kb. 
See on the issue of pay transparency: Veldman, A. (2017), Pay transparency in the EU A legal analysis of 
the situation in the EU Member States, Iceland, Liechtenstein and Norway, European network of legal 
experts in gender equality and non-discrimination, available at 
https://www.equalitylaw.eu/downloads/4073-pay-transparency-in-the-eu-pdf-693-kb. 

68   See Statistics Iceland, available at https://www.hagstofa.is/utgafur/frettasafn/laun-og-tekjur/oleidrettur-

launamunur-kynjanna-2021/. 

69   Registers Iceland (2021) Rannsókn á launamun 2008-2020 (Research on the pay gap 2008_2020), 
https://hagstofa.is/utgafur/frettasafn/laun-og-tekjur/oleidrettur-launamunur-kynjanna-2021/ ; 
https://www.stjornarradid.is/efst-a-baugi/frettir/stok-frett/2021/09/07/Kynbundinn-launamunur-fer-
minnkandi-samkvaemt-nyrri-rannsokn-/. 

70   Statistics Iceland, available at https://hagstofa.is/utgafur/frettasafn/laun-og-tekjur/oleidrettur-

launamunur-kynjanna-2021/. 

29 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

pay standard (ÍST 85,  Equal wage management system –  requirements and guidance). 
Equal  pay  certification  under  the  ÍST  85  standard  is  designed  to  confirm  that  when 
decisions on wages are taken they are based only on relevant consideration.  

A survey by the Confederation of Icelandic Enterprise (SA) in September 2024 reviewing 
the experience of managers regarding the effect of the equal pay certification shows that 
the perception is generally negative. The overall response rate was 31 % (598 companies), 
out of which only 22 % had a positive view of the procedure. The main reasons given for 
the  negative  attitude  concerned:  the  cost  of  implementing  the  standard;  that  the 
procedure is cumbersome and time consuming; that it does not serve a purpose given the 
nature  of  the  firms;  that  it  is  not  consistent  with  collective  agreements;  and  that  the 
assessments  are  too  frequent.  Furthermore,  the  procedure  made  it  difficult  to  reward 
outstanding employees independent of their sex. The view of those who perceived it as 
negative is that the equal pay certification ought to be optional rather than mandatory. 71  

One drawback of the equal pay certification is that employers can take advantage of it by 
providing  objective  reasons  for their decisions  and hence meet the  requirements  of the 
certification  system  while  not  actually  improving  the  gender  pay  gap  within  their 
companies.  There  are  various  discrepancies  in  the  way  that  the  certification  process  is 
conducted by the various bodies conducing the certification. 72 

A 2022 study73 focused on the strength and weaknesses of the certification standard. The 
survey shows that the decrease in the gender pay gap by 7–8 % from 2012 to 2020 cannot 
be assigned to the impact of the certification standard as there is no traceable difference 
between the companies that have received certification and those that have not. Thus, it 
is not possible to confirm that the implementation of the standard has had any direct effect 
on the gender pay gap. There appears however to be an indirect impact of the certification 
standard  leading  to  more  determination  on  behalf  of  companies  to  diminish  the  gender 
pay gap – not least in light of the public discourse and the quest for transparency. The 
weakness according to this survey is that it cannot really be demonstrated that there is 
no gender bias in the benchmark classifying the jobs.74 

The Confederation of Icelandic Enterprise (SA),75 maintain its position that the equal pay 
certification system should never have been adopted as law, although SA claims that it is 
not  against  the  certification  system  per  se  and  that  it  participated  in  the  standard’s 
development. SA maintains that the certification standard is a burden and should therefore 
not be a legal obligation, referring to the complexity of its implementation and incoherence 
with general management. SA emphasises that the standard can be particularly onerous 

71   Confederation of Icelandic Enterprise (SA) (2024) ‘Equal pay certification – high costs, low benefits’, 

https://www.sa.is/en/frettatengt/frettir/jafnlaunavottun-mikill-kostnadur-litill-avinningur. The equal pay 
certification system was adopted with Act No. 56/2017 amending Article 19 of the GEA on wage equality 
and took effect on 1 January 2018. 

72   Hafsteinsdóttir, G.B., Kristjánsdóttir, E.S. and Christiansen, Þ. H. (2020) ‘“Þetta er allt mannanna verk”: 
Upplifun stjórnenda á áhrifum jafnlaunavottunar á kjaraumhverfi’, in Icelandic Review of Politics and 
Administration, Vol. 16, No. 2, December 2020. See also: 
https://www.ruv.is/frett/2020/12/26/jafnlaunavottun-eykur-skrifraedi-og-er-jafnvel-
talsyn?fbclid=IwAR1g0vx__9gSVtAxMm8ymAnqe0uzxUU2C9Y6c3USgCZEFyl0yn6zy0kmvF0; 
https://www.mbl.is/vidskipti/frettir/2020/12/27/jafnlaunavottun_se_mogulega_talsyn/. 

73   Haraldsdóttir, R.K., Rafnsdóttir, G.L. and Jónsdóttir, G.A. (2022), ‘Að sníða verkfærið að veruleikanum eða 
veruleikann að verkfærinu? Um jafnlaunastaðal og afnám kynbundinna launa’ (To tailor the tool to match 
reality or reality to match the tool? On the equal pay certification system and the abrogation of the gender 
pay gap), Icelandic Review of Politics and Administration (Stjórnmál & Stjórnsýsla), Vol. 18, No. 2. 

74   RUV (Icelandic State Broadcasting Service) (2023) ‘Að sníða verkfærið að veruleikanum eða veruleikann að 
verkfærinu? Um jafnlaunastaðal og afnám kynbundinna launa’, (an interview with one of the authors of the 
survey in the Icelandic Review of Politics and Administration, Guðbjörg Andrea Jónsdóttir and with the 
representative of the SA Business, Maj-Britt Hjördís Briem), Kastljós, TV programme broadcast on 9 
January 2023, available at: https://www.ruv.is/sjonvarp/spila/kastljos/33550/9vukn5/kostir-og-gallar-
jafnlaunavottunar. 

75   The Confederation of Icelandic Enterprise (SA) is a confederation of business associations in all sectors of 

the Icelandic economy. 

30 

 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

for smaller companies and even useless in the cases of homogeneous firms (where, for 
example, the employees are all women). SA points out that the cost of implementing the 
standard is estimated around EUR 132.9 million (ISK 20 billion). On average, the cost for 
each  company  is  around  EUR 110 000  (ISK 16 million)  and  there  are  around  1 200 
undergoing the process. Many companies need to invest in expertise, technical equipment 
or  allocate  staff  time  to  this  endeavour.76  SA  further  maintains  that  the  equal  pay 
certification system does not strike at the root of the gender pay gap, which is the sectoral 
segregation  on  the  labour  market,  as  the  standard  only  measures  biases  within  each 
company. The same critics also point out that it is hard to harmonise the right to negotiate 
with the system. SA claims the certification system is a blunt tool that should not have 
been made legally mandatory.77 

Since 2024 there has been growing scepticism and criticism of the equal pay certification 
system. Critics maintain that the benefit of the system is highly questionable and that it 
entails  considerable  cost.  The  implementation  process  is  regarded  as  particularly 
cumbersome  for  smaller  companies  and  therefore  the  application  ought  to  be  optional 
rather  than  mandatory.  At  the  end  of  2023,  the  Centre  Party  (Miðflokkurinn)  in  a 
parliamentary  resolution78  proposed  that  the  equal  pay  certification  system  should  be 
abolished as the objective of closing the pay gap (with the aim of having eliminated it by 
2022)79 had failed. In spite of the obligation for equal pay certification, a company which 
employs  an  average  of  25–49  employees  can  choose  to  either  undergo  an  equal  pay 
certification  or  to  receive  an  equal  pay  confirmation  following  the  submission  of 
documentation showing that its equal pay system and its implementation comply with the 
requirements of the Directorate of Equality. All the timeframes for the different categories 
of  companies  were  postponed  for  12  months.  By  the  end  of  2022  only  443  firms  and 
institutions  out  of  1 094  had  been  accredited  while  651  companies  and  institutions  had 
not yet obtained the accreditation.  

  Equal pay 

4.2.1  Implementation in national law 

The  GEA  No. 150/2020  has  in  Article 6  a  general  provision  on  pay  equality  for  women, 
men and people who are officially registered as gender neutral for the same jobs or jobs 
of equal value. Equal pay is pay determined in the same way for people independent of 
their sex and must not involve any sex discrimination. Workers are at all times, upon their 
choice, be permitted to disclose their wage terms; this last point was  introduced in the 
GEA No. 10/2008. The Act on the Equal Treatment on the Labour Market No. 86/2018 has 
the same principle regarding pay in its Article 9.80 

The equal pay provision in Article 6 of the GEA must be interpreted in accordance with the 
provisions of the EEA Treaty with its inclusion of EU legislation. 

The provision in Article 6 of the GEA does not require that people demanding equal pay 
work for the same employer, as in the older Law No. 10/2008. 

76   See: https://www.sa.is/frettatengt/frettir/jafnlaunavottun--varnadarord-raungerast.  
77   See: https://www.sa.is/frettatengt/frettir/jafnlaunavottun--varnadarord-raungerast.  
78   See: https://www.althingi.is/altext/154/s/0557.html; https://www.visir.is/g/20232490190d/vilja-leggja-

jafn-launa-vottunina-nidur. 

79   Reykjavik Grapevine (2018) ‘Iceland’s equal pay law sets new world standard’, 7 February 2018, 

https://grapevine.is/news/2018/02/07/9981264/. 

80   Act on equal treatment on the labour market, No. 86/2018, 

https://www.jafnretti.is/static/files/English_gogn_a_ensku_sidu/act-on-equal-treatment-on-the-labour-
market-no-86-2018-m-br-final-sent-230519.pdf. 

31 

 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

Article 7  of  the  GEA  No. 150/2020  includes  a  provision  on  the  equal  pay  certification 
system  that  was  introduced  with  Act  No. 56/201781  providing  that  companies  and 
institutions  employing  25  or  more  workers,  on  an  annual  basis,  are  required  to  obtain 
equal  pay  certification  of  their  equal  pay  systems  and  the  implementation  thereof.  The 
purpose  of  this  obligatory  certification  is  to  enforce  the  current  legislation  prohibiting 
discriminatory practices based on gender and requiring women and men working for the 
same employer to be paid equal wages and enjoy equal terms of employment for the same 
jobs or jobs of equal value.  

Article 2(11) of the GEA No. 150/2020 defines certification as: a written statement from 
the certifying body which provides a certification certificate, following the certifying body’s 
audit of a company’s  or an institution’s equal pay system, in which it is stated that the 
equal pay system and its implementation meet the requirements of the ÍST 85 standard 
(according to Article 1(c) of that standard).  

Article 2(12)  of  the  GEA  No. 150/2020  defines  equal  pay  confirmation  as:  a  written 
statement  from  the  Centre  for  Gender  Equality82  which  is  provided  to  an  enterprise  or 
institution  where  25-49  people  work  on  an  annual  basis  with  a  confirmation  certificate, 
following the audit of a company’s or institution’s equal pay system, in which it is stated 
that the equal pay system and its implementation meet the requirements of the ÍST 85 
standard (according to Article 1(b) of that standard).83 

According to the explanatory report of the GEA No. 150/2020, the main changes are the 
following:  the  Centre  for  Gender  Equality  is  responsible  for  monitoring  the  equal  pay 
certification. The ‘annual basis’ term to assess the size of the company from the number 
of  employees  under  Article 2(13)  is  explained  with  regard  to  changes  in  the  size  of  a 
company due to growth or merger. 

Article 8 of the GEA No. 150/2020 concerns the equal pay confirmation. Both measures, 
the  equal  pay  certification  and  the  equal  pay  confirmation,  are  intended  to  prove  that 
objective reasons underlie pay decisions although individual aspects are not excluded so 
that people can have higher wages on the basis of more experience, additional education, 
performance or other factors that the employer deems valuable as long as sex is not the 
determining  factor.  It  must  be  transparent  which  objective  paradigms  underlie  the  pay 
decisions  of  individuals  in  the  pay  system  and  that  these  same  paradigms  apply  to  all 
employees. 

Articles 9 and 10 of the GEA No. 150/2020 concern the oversight role of the Directorate 
of  Equality84  and  Article 11  stipulates  that  the  minister  must  assess  the  progress  and 
success of the equal pay certification and confirmation system every three years. 

The Directorate of Equality oversees the administration of equal pay certification and equal 
pay confirmation in accordance with Article 9 of the Act on equal status and equal rights 
irrespective of gender; monitors equal pay certification and equal pay confirmation (under 
Article 10 of the same act); and grants equal pay confirmation (under Article 8 of that act, 
and  according  to  Article 4(l)  of  the  Act  on  the  administration  of  matters  concerning 
equality).  

81   See: https://www.althingi.is/altext/146/s/1054.html. A bill of law (amendments to Article 19 of the Gender 
Equality Act No. 10/2008) was passed by the Icelandic Parliament (Althingi) with a substantial majority on 
1 June 2017 (Law No. 56/2017) and came into force on 1 January 2018. 

82   The previous definition said ‘from a stakeholder’ in, for example, an employees’ representative 

organisation. See here: https://www.althingi.is/altext/erindi/146/146-1230.pdf. 

83   Article 1 of Act No. 56/2017. 
84   See Act on administration on matters concerning equality No. 151/2020. 

32 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

4.2.2  Definition in national law 

Article 6 of the GEA No. 150/2020 provides: 

‘Women,  men  and  all  persons  whose  gender  is  registered  as  neutral  in  Registers 
Iceland shall be paid equal pay and enjoy equal terms of employment for the same 
jobs or jobs of equal value. 

“Equal pay” means that pay shall be determined in the same manner for all persons 
regardless of gender. The criteria on the basis of which pay is determined shall not 
involve gender discrimination. 

Workers shall at all times be permitted to disclose their pay terms, should they so 
choose.’ 

The criteria for comparisons to be made with employees of the same employer have been 
removed from the provision in Article 6 of the GEA No. 150/2020 on pay equality, so one 
can compare with someone hired by a different employer doing the same job or work of 
equal value. This is in accordance with Directive 2006/54. 

Article 2(9)  of  the  GEA  defines  pay  as:  ordinary  remuneration  for  work  and  further 
payments  of all types,  direct and indirect, whether they take the  form of perquisites  or 
other forms, paid by the employer to the employee for their work. 

The definition of pay complies with Article 157(2) of the TFEU as also detailed in Article 6. 

Article 2 of the GEA No. 150/2020 (Glossary) does not include a definition of ‘worker’.  

Article 18 of the GEA No. 150/2020 prohibits discrimination in terms on the basis of sex 
(women,  men  and  trans  people  of  either  sex  or  gender  neutral)  in  the  public  register. 
Article 18(2) provides that if there is a likelihood that a woman, man or people officially 
registered as gender neutral, receives different wages for the same work, or for work of 
equal value, then the employer must demonstrate, if there is a difference in their wages, 
that the difference is explained on grounds other than gender. 

4.2.3  Explicit implementation of Article 4 of Recast Directive 2006/54 

The pay equality provision is in full accordance with Article 4 of the Recast Directive and, 
after  the  amendments  to  the  GEA  No. 10/2008  which  became  effective  in  2018,  goes 
further than the EU legal framework requires, as does the GEA No. 150/2020.85 

4.2.4  Related case law 

The general principles in jurisprudence regarding equal pay originate from the first main 
cases  in  the  early  21st  century,  where  the  Supreme  Court  was  faced  with  the  issue  of 
whether jobs at the same level in the municipal hierarchy were of equal value; the job of 
an equality officer in the municipality where wages were based on a job evaluation linked 
to collective agreements as opposed to the job of an employment officer with higher wages 
as  the  post  was  held  by  an  engineer  and  the  evaluation  was  linked  to  the  collective 
agreements for engineers. The Equality Complaints Committee had ruled prior to the case 
going to a court of law that the job evaluation was based on gender considerations and 
that the municipality had not respected the wage equality clause of the Gender Equality 
Act. The Supreme Court held that, in order for jobs to be considered of equal value, an 
all-inclusive evaluation was needed; although aspects of the jobs were different, the Court 

85   See: https://www.stjornarradid.is/efst-a-baugi/frettir/stok-frett/2022/05/27/Jafnlaunavottun-naer-nu-yfir-

100-thusund-starfsmenn/. 

33 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

considered the aim of the Gender Equality Act would not be achieved if wage equality was 
only to reach people within the same class of work, as freedom of contract on the labour 
market was subject to the wage equality provided for in the GEA. In this case the claimant 
had  shown  that  she  had  been  discriminated  against  as  the  jobs  were  comparable  in 
substance and form. 86 

In  2024  the  Equality  Complaints  Committee  ruled  in  only  one  case  of  multiple 
discrimination (case No. 6/2024), concerning pay inequality, dismissal in connection with 
demand for redress and discrimination on grounds of ethnic origin.87 The committee ruled 
that the claimant had not been able to demonstrate that the difference in terms was on 
the grounds of gender. Accordingly, there had been no multiple discrimination although 
there had been a violation regarding dismissal in connection with demand for redress. The 
Equality Complaints Committee, in accordance with Article 8(4) of Act No. 151/2020 on 
the administration of matters concerning equality, ruled that the employer should pay the 
complainant’s cost of bringing proceedings before the Committee. 

There  was  no  ruling  by  the  Equality  Complaints  Committee  in  2024  regarding  pay 
discrimination on the basis of the GEA. 

4.2.5  Permissibility of pay differences 

Equal pay certification does not prevent a company from implementing a payroll system 
that  is  100 %  performance  based  if  the  different  wages  are  based  on  relevant 
considerations and not on gender. 

4.2.6  Requirement for comparators 

The  prevailing  comparator  is  the  equal  pay  certification,  which  is  now  required  for  all 
employers with 25 or more employees, confirming that they meet the equal pay standards. 

4.2.7  Existence of parameters for establishing the equal value of the work performed 

One of the biggest challenges Icelandic enterprises face in the implementation of the equal 
pay standard is classifying which jobs are of the same or equal value. Equal wage analysis 
requires that jobs are classified by evaluating them against each other and assigning them 
weight. 

The equal pay standard is intended to make pay, and any differences in pay for similar 
work,  more  transparent  but  it  does  not  demand  the  same  uniform  pay  system  for  all 
companies and institutions. Instead, it requires that each workplace introduce the same 
four  to  five  key  criteria  and  sub-criteria.  The  standard  highlights  four  main  criteria 
(IST 85: 2012,  Annex  B):  expertise/competence,  responsibility,  strain  and  working 
conditions.  

These  must  be  elaborated  with  specific  content.  Companies  may  have  different 
(sub)criteria that make sense for each business, but the standard obliges them to work 
out a more formalised system for their pay decisions, e.g. by carrying out wage analysis. 
These are then used as a uniform measure to classify all jobs, so that the jobs within each 
workplace  are  comparable  to  each  other  on  the  basis  of  the  uniform  classification  and 
salary system.  

By the same token, the implementation of the law does not require an employer to pay 
everyone  performing  in  the  same  or  equal  job  the  same.  Differences  in  pay,  however, 
need to be justified by relevant considerations (use of the criteria and the sub-criteria) as 

86   Supreme Court case No. 11/2000, judgment of 31 May 2000. 
87   See section 3.4.2. above. 

34 

 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

opposed  to  irrelevant  ones  including  gender  (which  could  constitute  discrimination).  In 
short, each employer needs to apply its equal pay system (criteria and sub-criteria) equally 
to  all  its  positions  (employees).  The  employer  also  needs  to  document  and  qualify  why 
one  employee  serving  in  the  same  position  as  another  gets  a  higher  salary  when  they 
otherwise have the same qualifications and credentials and are doing a job of the same or 
equal value. 88 

4.2.8  Other relevant rules or policies 

Article 6 (3) of the GEA No. 150/2020 permits workers to disclose their wage terms (as 
did Article 19(3) of the previous act). In a competitive environment it is unlikely that such 
disclosures will occur.  

4.2.9  Job evaluation and classification systems 

A job classification system was previously used at the municipal level in Iceland. Under 
such systems the evaluation does not assess the performance of the employee but entails 
an  analysis  of  the  basic  requirements  that  apply  to  those  carrying  out  the  job.89  This 
changed following the adoption of the equal pay certification standard with the amendment 
of Article 19 of the GEA, which became effective on 1 January 2018. Companies with 25 
or more employees are now obliged to obtain equal pay certification which meets the equal 
pay standard and prove that their wage decisions are relevant considerations and are not 
based on gender. 

4.2.10 Wage transparency90 

Equal pay certification, administered by the Directorate of Equality, according to Article 7 
of  the  GEA  No. 150/2020,  is  intended  to  provide  wage  transparency  to  guarantee  that 
gender is not the main factor in deciding wages. According to Statistics Iceland, the whole 
workforce is around 200 000. In May 2022, 385 companies, institutions and other public 
bodies had obtained the equal pay certification. The employees of these bodies amount to 
around  100 000  or  70 %  of  the  employees  to  whom  the  equal  pay  certification  system 
applies. Smaller firms with 25-89 employees that had not obtained equal pay certification 
or  confirmation  are  now  also  required  to  complete  the  process.91  The  Directorate  of 
Equality, which oversees the administration of equal pay certification,92 admonished the 
entities in question about the impending per diem fines. 93 

Article 9  of  GEA  No. 150/2020  provides  that  a  company  or  institution  employing,  on 
average,  25  to  49  employees  per  annum,  can  choose  either  to  undergo  equal  pay 
certification in accordance with Article 7 of the GEA or to receive equal pay confirmation 
from the Directorate of Equality, following the submission of documentation demonstrating 
compliance  with  its  equal  pay  system  and  its  implementation,  as  assessed  by  the 
Directorate of Equality. 

88   Thorgeirsdottir, H.K. (2019) ‘Equal Pay discussion paper’, delivered at the EU Learning Programme in 

Gender Equality in Iceland, 27-28 May 2019: https://herdis.is/wp-content/uploads/2019/06/Discussion-
paper_IS-2019.pdf. 

89   Report by a working group on the equal rights pay policy in the general labour market (2008), p. 40, 

http://www.velferdarraduneyti.is/media/08frettir/Skyrsla_starfshops_um_jafnlaunastefnu_a_almennum_vi
nnumarkadi.pdf. 

90   Directive (EU) 2023/970 of the European Parliament and of the Council of 10 May 2023 to strengthen the 
application of the principle of equal pay for equal work or work of equal value between men and women 
through pay transparency and enforcement mechanisms (Text with EEA relevance), OJ L 132, 17.5.2023, 
p. 21–44. 

91   See: https://www.stjornarradid.is/efst-a-baugi/frettir/stok-frett/2022/05/27/Jafnlaunavottun-naer-nu-yfir-

100-thusund-starfsmenn/. 
92   Act No. 151/2020, Art. 4(k). 
93   Act No. 151/2020, Art. 6. 

35 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

4.2.11 Implementation of the transparency measures set out by European Commission’s 
Recommendation  of  7  March  2014  on  strengthening  the  principle  of  equal  pay 
between  men  and  women  and/or  Directive (EU)  2023/970  of  the  European 
Parliament and of the Council of 10 May 2023 to strengthen the application of the 
principle  of  equal  pay  for  equal  work  or  work  of  equal  value  between  men  and 
women through pay transparency and enforcement mechanisms 

This recommendation did not play a role in the establishment of the equal pay certification 
system, which had been under development for many years and is the result of a thorough 
collaboration between various stakeholders. 

4.2.12 Other measures, tools or procedures 

Institutions, companies and civil society organisations are obliged to supply the Directorate 
of Equality with any general information that is vital to its activities  on the basis of the 
equality acts referred to in Article 1. Should the Directorate of Equality have a reasoned 
suspicion that an institution, company or civil society organisation has violated the equality 
acts referred to in Article 1, it is required to check whether there is reason to request that 
the  matter  be  brought  before  the  Equality  Complaints  Committee.  The  institution, 
company or  civil  society organisation in question is obliged to supply  the Directorate of 
Equality with the information and data it considers to be necessary to establish the facts 
of the case. If the entity in question does not respond to this request from the Directorate 
of Equality within a reasonable time limit, the Directorate can decide that the entity will 
be subject to per diem fines until the requested information and data have been supplied, 
in accordance with Article 6. Should the Directorate of Equality request that the Equality 
Complaints Committee address the case, the entity in question will be notified thereof in 
writing. However, this provision only applies to cases that may pertain to the interests of 
many  and  have,  according  to  the  Directorate  of  Equality,  a  general  application,  (under 
Article 5 of the Act on the administration of matters concerning equality No. 151/2020). 

  Access to work, working conditions and dismissal 

4.3.1  Definition of the (material) scope (Article 14(1) of Recast Directive 2006/54) 

Article 1(c) of the GEA provides that the aim of gender equality legislation is specifically 
to improve the position of women and increasing their opportunities in society. 

The GEA assumes that employers as well as trade unions will systematically work towards 
improving equality and protect the rights of people who are registered as gender neutral. 

Article 19  of  the  GEA  concerns  the  general  prohibition  of  discrimination  at  work  and  on 
engagement  in  employment  on  the  basis  of  sex.  Employers  are  prohibited  from 
discriminating  between  applicants  for  jobs  on  grounds  of  their  sex.  The  same  goes  for 
promotion, changes of position, retraining, continuing education, vocational training, study 
leave, notice of termination, the working environment and employees’ working conditions. 
Paragraph 2 of Article 19 prohibits allowing maternity/paternity or parental leave, or other 
circumstances relating to pregnancy and childbirth, to have a negative effect on decisions 
regarding paragraph 1. 

Article 19(4) and (5) of the GEA No. 155/2020, sets out the procedural rules on evidence 
and assessment. It is still presumed that the Equality Complaints Committee94 will decide 
whether the provision was violated, according to paragraph 1 of Article 8 of the Act on the 
administration of gender equality, which was adopted at the same time as the GEA.  

94   See Act on administration on matters concerning equality No. 151/2020. 

36 

 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

In  assessing  whether  there  has  been  discrimination  in  the  appointment  of  public  posts, 
the  employer  is  obliged  to  adhere  to  the  written  rules  as  well  as  unwritten  general 
principles of administrative law. As regards general principles, the employer must employ 
the  most  qualified/competent  applicant  on  the  basis  of  an  objective  evaluation  in 
accordance with the principle of equality and non-discrimination (réttmætisregla) that all 
conduct  of  the  authorities  must  be  based  on  an  objective  assessment.  Apart  from  the 
general  principle  of  competence,  the  objective  evaluation  focuses  on  education, 
experience,  and  other  personal  qualities/characteristics.  As  stated  in  the  explanatory 
report,  the  employer  has  considerable  discretion  in  deciding  which  elements  he/she 
prioritises  in  the  employment  process.  These  must,  however,  be  indicated  in  the 
advertisement for the post/job, although there are exceptions to this which demands more 
scrutiny on behalf of the employer and gives applicants a chance to present their views 
(see  Parliamentary  Ombudsman  opinion  No. 26/1999).  The  employer  furthermore  has 
discretion  to  determine  the  significance  of  each  objective  element  given  that  the 
assessment  is  based  on  coherent,  objective  scrutiny.  The  explanatory  report  further 
explains that it is not within the competence of the Equality Complaints Committee95 to 
review the assessment  of the  employer on which applicant best fitted  the requirements 
for  the  post/job  unless  it  may  be  adduced  from  matters  of  the  case  that  his/her 
assumptions  were  unjustified  and  contrary  to  the  principle  of  equality  and  non-
discrimination. All the same, as stated in the explanatory report, it may prove unavoidable 
for the Equality Complaints Committee to assess the competence of the applicant within 
the framework set out in Article 19(5) of the GEA No. 155/2020 to scrutinise whether the 
employer discriminated between applicants  on the basis  of sex –  see the Parliamentary 
Ombudsman’s  opinion No. 6395/2011 and the Supreme Court decision from 15 January 
2015,  No. 364/2015,  where  the  Equality  Complaints  Committee  was  not  seen  as 
overstepping its competence when ruling that the employer had violated Article 26 of the 
previous  GEA No. 10/2008 (the predecessor of the  current Article 19). In this case, the 
Complaints  Committee  rightly  scrutinised  the  requirements  that  had  been  set  out  in  an 
advertisement for the post in question and other  factors that the employer asserted he 
had  based  his  decision  on  to  assess  whether  these  requirements  and  other  factors  had 
been objectively applied. The Complaints Committee had not revised the assessment of 
the  employer  but  only  based  its  ruling  on  the  documented  material  underlying  the 
employer’s decision. 

4.3.2  Implementation of the exception on occupational activities (Article 14(2) of Recast 

Directive 2006/54) 

Paragraph 3 of Article 19 of the GEA No. 150/2020 prohibits advertising or publishing an 
advertisement for a vacant position that indicates a preference for one gender over the 
other. However, as stated in the second sentence of this paragraph: This provision shall 
not apply if the aim of the advertiser is to promote more equal representation of women 
and  men  within  an  occupational  sector,  in  which  case  this  must  be  stated  in  the 
advertisement. The same shall apply if there are valid reasons for advertising for a person 
of a specific gender.” 

This exception has nothing to do with sexist or stereotypical advertising. They only provide 
guidance for advertising if the aim is to promote a more equal representation. An example 
is  advertising  for  a  woman  when  women  are  obviously  under-represented  in  a  given 
occupational  field,  such  as  the  fishing  industry,  where  men  are  in  the  majority,  or 
advertising for male nurses where women are  in the majority or advertising for gender 
neutral individuals in managerial positions. 

Article 22 of the GEA provides that advertisers shall ensure that advertisements are not 
belittling or disrespectful for a specific gender and that they do not in any way run contrary 

95   See Act on administration on matters concerning equality No. 151/2020. 

37 

 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

to  the  equal  status  and  equal  rights  of  the  genders.  Such  advertisements  may  not  be 
published in the media or any other public venue. 

The  human  rights  policy  of  the  municipality  of  Reykjavík  prescribes  that  job 
advertisements must be gender neutral,  yet underscores the need for exceptions which 
are not to be regarded as discriminatory when, for example, advertising for staff in the 
women’s or men’s changing rooms at municipal swimming pools. 

4.3.3  Protection  against  the  non-hiring,  non-renewal  of  a  fixed-term  contract,  non-
continuation  of  a  contract  and  dismissal  of  women  connected  to  their  state  of 
pregnancy and/or maternity 

An  employee  seeking  a  job  is  not  obliged  to  inform  her  potential  employer  about  her 
pregnancy.  It  is  only  in  the  case  of  intended  maternity/paternity  leave  that  employees 
need  to  give  notice  to  their  employer  (see  Article 12  of  the  MPLPL  No. 144/2020).96  In 
such cases employers are prohibited from dismissing employees due to their intention to 
go on maternity leave (Article 30 of the MPLPL No. 144/2020). 

The  employment  relationship  between  an  employee  and  her  employer  should  remain 
unchanged during maternity leave (Article 49 of the MPLPL). The provision confirms that 
rights established in working relations cannot be altered. As regards fixed contracts, which 
are not mentioned anywhere in the law or explanatory notes, it must be presumed, based 
on  the  above  provision,  that  the  protection  afforded  to  pregnant  workers  on  a  fixed 
contract  is  the  same.  This  means  that,  in  the  case  of  a  fixed  term  contract  which  ends 
after they  return from  maternity leave, they are  entitled to return to  the same job and 
finish working the contract. As regards contract renewal, the right of the employer to make 
necessary changes in the working  environment cannot be curtailed due to the  rights  of 
employees, as stated in the explanatory notes on Article 29 of the MPLPL. 

Changes in the working environment may not lead to pay cuts or curtailment of job-related 
rights. 

4.3.4  Implementation  of  the  exception  on  the  protection  for  women  in  relation  to 

pregnancy and maternity (Article 28(1) of Recast Directive 2006/54) 

The health and safety of a pregnant worker or a woman who has recently given birth or a 
woman who is breastfeeding a child is guaranteed by Article 16 of the MPLPL No. 144/2020 
(previously Article 11 of the Act on MPLPL No. 95/2000). The provision is substantially the 
same although it is clarified that it applies only to pregnant parents who are employees, 
as defined in Article 4(4): ‘Employee: A parent who works in a paid job in the service of 
others continuously for at least 25 % of full-time employment every month.’ A parent who 
works  in  his  own  business  continuously  for  at  least  25 %  of  full-time  employment  in  a 
company in which he owns a share of 25 % or less is also considered an employee. This 
law  furthermore  covers  the  rights  of  parents  outside  the  labour  market  or  in  less  than 
25 % employment and parents in full-time education to maternity allowance. An employee 
and self-employed person is defined in Article 4(5) as any parent who works continuously 
in a total of at least of 25 % of full-time employment each month shall be considered as 
an employee in accordance with point 4 if they have worked as an employee in 50 % or 
more  full  time  employment;  otherwise  they  shall  be  considered  as  self-employed  in 
accordance with point 3 of Article 4: A parent who works at its own business, continuously, 
in at least 25 % of full-time employment, irrespective of the corporate structure involved, 
providing that its share of the company is greater than 25 %, and the parent is required, 
every  month  or  in  another  regular  manner  in  accordance  with  a  decision  by  the  tax 
authorities, to pay social security tax.  

96   Maternity/Paternity and Parental Leave Act, No. 144/2020, 

https://www.althingi.is/lagas/nuna/2020144.html. 

38 

 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

The concept of an employee applies to everyone who works in the service of others (see 
also the Act on the health and safety in workplaces No. 46/1980 with later amendments 
where students and apprentices are also to be considered as employees, even though they 
work without payment, providing that their work constitutes part of formal studies97). 98 
Employers must take special measures to ensure the safety of a parent who has recently 
given birth and/or is breastfeeding by arranging temporary working conditions or working 
time.  If  for  technical  or  other  reasons  this  is  not  possible,  the  employer  must  give  the 
parent other tasks or else grant them leave for the time necessary to protect their health 
and  safety,  where  the  parent  gains  a  right  to  longer  leave  and  payments  from  the 
maternity/paternity/parental leave fund. Those changes which are considered necessary 
in a woman’s working conditions and/or working time (see Article 16, Paragraph 1 and 2 
of the MPLPL No. 144/2020)99 must not affect her wages so as to reduce them or limit her 
other job-related rights.  

4.3.5  Particular difficulties 

One of the most significant threats to equal access to work and promotion is nepotism, in 
particular political nepotism, which is a recognised problem in Iceland. This appears to be 
most  relevant  in  relation  to  posts  in  the  public  sphere  where  candidates  with  political 
affiliations are favoured over those who have none. In 2024 there was a 29 % increase in 
jobs in the public sphere.100 To give the hiring process an aura of professionalism, hiring 
agencies are used to interview the job applicants – where the staff of the agencies’ often 
lack the qualification to interview highly qualified candidates – while at the same time it 
makes little difference as it has already been decided who will be hired. There appears to 
be no political will to reduce nepotism, which also characterises semi-public institutions. 
This means that contesting promotion or access to employment on the basis of the GEA 
becomes complicated. 

4.3.6  Positive action measures (Article 3 of Recast Directive 2006/54)  

The  equal pay certification system,  setting aside its  effectiveness,  represents a positive 
action measure aimed at achieving full practical equality between men and women in the 
workplace, in compliance with Article 3 of the Recast Directive. 

  Evaluation of implementation 

The rulings of the Equality Complaints Committee regarding equal pay and access to jobs 
may be described as rather prudential and conservative and neither exceed EU law nor fall 
short of it. 

  Remaining issues 

The main issues are mentioned above.  

97   Act No. 68/2003, Article 6, amending Act No. 46/1980. 
98   Act on the working environment and health and safety in workplaces No. 46/1980 with later amendments, 

(Lög nr. 46/1980 um aðbúnað, hollustuhætti og öryggi á vinnustöðum), 
https://www.government.is/library/04-
Legislation/Act%20No%2046%201980%20with%20subsequent%20amendments%202018.pdf. 

99   Maternity/Paternity and Parental Leave Act, No. 144/2020, 

https://www.althingi.is/lagas/nuna/2020144.html. 

100  Ministry of Finance and Economic Affairs (2024) ‘The general market share of job growth is 71 %’, 27 
August 2024, https://www.stjornarradid.is/efst-a-baugi/frettir/stok-frett/2024/08/27/Hlutur-almenna-
markadarins-i-fjolgun-starfa-er-71/. 

39 

 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

5  Work-life  balance  issues:  pregnancy,  maternity,  family-related  leave  and 
flexible  working  arrangements  (Directive 92/85,  relevant  provisions  of 
Directives 2006/54, and Directive 2019/1158)101 

  General (legal) context 

5.1.1  Overview of national acts on work-life balance issues 

On 14 March 2024, the EEA Joint Committee decided to amend Annex XVIII (Health and 
safety  at  work,  labour  law,  and  equal  treatment  for  men  and  women)  to  the  EEA 
Agreement  (2024/1956).102  Directive  EU  2019/1158  of  the  European  Parliament  and  of 
the  Council  of  20  June  2019  on  work-life  balance  for  parents  and  careers  is  to  be 
incorporated  into  the  EEA  Agreement,  subsequently  repealing  Council  Directive 
2010/18/EU under the EEA Agreement, although this has not yet happened.103 It has been 
reviewed within the Ministry  of Social Affairs and Labour and passed  with constitutional 
reservation to the Ministry of Foreign Affairs as it is anticipated that it will call for legal 
amendments. Consultation with stakeholders on the labour market on how to transpose 
the Directive are ongoing and the results are expected in the spring of 2025. No legislative 
measures  have  been  formulated  thus  far  based  on  the  matters  covered  by  the  WLB 
Directive. It is, however, anticipated that the transposition process of Directive 92/85 into 
national law will be conducted in co-operation with labour market stakeholders. The laws 
that will probably be amended are the MPLPL Act No. 144/2020 and the Act on Working 
Environment, Health and Safety in Workplaces, No. 46/1980 with later amendments. 104 

5.1.2  Political and societal debate and pending legislative proposals 

The drafting of the MPLPL Act began in the autumn of 2019 when the Minister of Social 
Affairs  established  a  committee  to  review  Act  No. 95/2000.  The  main  challenges  of  the 
current system are to ensure that both parents get a chance to take care of their newborn 
child without risking their position on the labour market.  

Iceland  as  an  EEA  State  shares  the  goals  and  objectives  of  the  Directive on  Work-life 
Balance  for  parents  and  carers.  Iceland  however,  as  the  other  EEA  and  EFTA  States, 
believes that the Directive must allow room for national models and respect the principle 
of  subsidiarity.  Member  States  should  therefore  be  granted  space  to  decide  which 
measures work best in their political and societal context.  

In  line  with  the  gender-neutral  policy  underlying  the  legislation  of  the  MPLPL 
No. 144/2020, the law no longer refers to separate ‘maternity’ or ‘paternity leave’, but to 
birth leave of up to six months (Article 8) for each parent.105 The MPLPL refers to ‘parents’ 
(not to mothers or fathers). 

101  See Masselot, A. (2018), Family leave: enforcement of the protection against dismissal and unfavourable 
treatment, European network of legal experts in gender equality and non-discrimination, available at 
https://www.equalitylaw.eu/downloads/4808-family-leave-enforcement-of-the-protection-against-
dismissal-and-unfavourable-treatment-pdf-962-kb and De la Corte-Rodríguez, M. (2024), The transposition 
of the Work-Life Balance Directive in EU Member States (II): Considerable work still to be done, available at 
https://www.equalitylaw.eu/downloads/6048-the-transposition-of-the-work-life-balance-directive-in-eu-
member-states-ii-considerable-work-still-to-be-done. 

102  Decision of the EEA Joint Committee No 74/2024 of 15 March 2024, https://eur-lex.europa.eu/legal-

content/EN/TXT/PDF/?uri=CELEX:22024D1596. 

103  Information obtained from the Ministry of Social Affairs on 18 February 2025. 
104  Act on Working Environment, Health and Safety in Workplaces, No. 46/1980, as amended by Acts 
No. 15/1986, No. 61/1990, No. 7/1996, No. 52/1997, No. 83/1997, No. 17/2003, No. 68/2003, 
No. 90/2004, No. 138/2005, No. 88/2008, No. 162/2010, No. 126/2011, No. 59/2013, No. 45/2015, 
No. 80/2015, No. 128/2016 and No. 93/2017. See: https://www.government.is/library/04-
Legislation/Act%20No%2046%201980%20with%20subsequent%20amendments%202018.pdf.  

105  Lög um fæðingar- og foreldraorlof Nr. 144/2020 literally means Act on Birth and Parental Leave, but is still 

referred to as the Maternity, Paternity, Parental Leave Act. See Committee on Economic, Social and Cultural 
Rights (2021) Iceland’s Fifth Periodic Report on the International Covenant on Economic, Social and 

40 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

  Pregnancy and maternity protection106 

5.2.1  Definition in national law (Article 2 of Directive 92/85) 

Article 4 of the MPLPL defines the terms used in the Act. The Act does not define the term 
‘pregnant worker’. It defines the following terms: 4.1. Full-time studies; 4.2. Continuous 
employment; 4.3. Self-employed person, 4.4 Employee, 4.5. Employee and self-employed 
person.  

An employee refers to ‘anybody who is employed in a salaried position in the service of 
others  amounting  to  at  least  25 %  of  a  full-time  position  each  month.  A  self-employed 
individual refers to anybody who works for themselves for at least 25 % of the time and 
owns 25 % of their company, irrespective of the type of company, to the effect that she/he 
is obliged to pay an insurance levy every month, or in another manner decided by the tax 
authorities.’ 

5.2.2  Obligation to inform employer (Article 2 of Directive 92/85) 

Under Article 12 of the MPLPL, employees intending to exercise their maternity/paternity 
leave entitlements must notify their employers of this at the earliest opportunity and no 
later than eight weeks prior to the expected date of the birth, primary adoption or taking 
of a child into permanent foster care. Employees who wish to change a previously notified 
date of commencement of maternity/paternity leave, or to give notification of a new period 
of maternity/paternity leave (Article 8(2)), must notify their employers of this three weeks 
prior to the proposed new date of commencement of maternity/paternity leave.  

If the employee first gives notification of the taking of maternity/paternity leave after the 
birth,  primary  adoption  or  taking  of  a  child  into  permanent  foster  care,  this  notification 
must be received by the employer not less than eight weeks before the employee intends 
to exercise their maternity/paternity leave entitlement, and the leave will be structured in 
accordance with Article 13. If employee and employer fail to agree on the arrangement, 
the employee will in all cases have the right to take maternity/paternity leave in a single 
period  following  the  other  parent’s  maternity/paternity  leave  or  if  the  child  becomes  so 
seriously  ill  as  to  necessitate  the  parent’s  presence.  In  other  cases,  the  employer  may 
defer the taking of maternity/paternity leave by the employee, if special circumstances in 
the operation of the business or institution necessitate this, for a maximum of eight weeks, 
although  not  for  more  than  will  result  in  the  leave  period’s  being  concluded  before  the 
child attains the age of 24 months.  

Notifications  of  the  taking  of  maternity/paternity  leave  must  be  made  in  the  form 
determined by the Directorate of Labour, e.g. as to whether they are to be electronic or 
in writing, and must state the proposed starting date of the leave, its length and how it is 
to be structured. The employer will then write the date of receipt of the notification on it 
and  give  the  employee  a  copy.  The  employer  may  demand  proof  that  the  employee 
exercises custody of the child, or that the consent of the custodial parent has been given 
for  the  non-custodial  parent’s  having  access  to  the  child  during  the  period  of  the  non-
custodial  parent’s  maternity/paternity  leave  (Article 10)  if  the  employer  considers  this 
necessary.  

Cultural Rights in keeping with Articles 16 and 17 of the Covenant; the Government website on Human 
Rights and Equality refers to Act No. 144/2020 in English although it has not been translated: Other 
legislation: Maternity/paternity leave and parental leave.  

106  Directive 92/85/EEC of 19 October 1992 on the introduction of measures to encourage improvements in the 

safety and health at work of pregnant workers and workers who have recently given birth or are 
breastfeeding (tenth individual Directive within the meaning of Article 16 (1) of Directive 89/391/EEC), OJ L 
348, 28.11.1992. 

41 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

Regulation  No. 193/2000  as  amended  by  Regulation  No. 453/2016107  provides  in  its 
Article 2  that  the  concepts  of  ‘pregnant  woman’,  ‘woman  who  has  just  given  birth’  and 
‘woman who is breastfeeding’ only apply to women who have notified their employer about 
their condition. 

5.2.3  Case law on the definition of a pregnant worker, a worker who has recently given 
birth  and/or  a  worker  who  is  breastfeeding  and  the  obligation  to  inform  the 
employer 

No recent cases touch upon these issues. 

5.2.4  Implementation of protective measures (Articles 4-6 of Directive 92/85) 

Article 16 of the MPLPL concerns health and safety in the workplace, stipulating that if the 
health and safety of a pregnant worker, a woman who has recently given birth to a child, 
or a  woman who is breastfeeding a child, is  considered to be in danger, according to a 
special assessment, her employer must make the necessary arrangements to ensure the 
woman’s safety by temporarily changing her working conditions and/or working hours, in 
accordance with EU Directive 92/85. If this is not possible for technical reasons, or other 
valid  reasons,  the  woman’s  employer  must  entrust  her  with  other  tasks.  If  this  is  not 
possible, the employer must grant her leave of absence for the length of time necessary 
to protect her health and safety. A woman who is granted leave on the basis of Article 11 
is entitled to payment. 

5.2.5  Case law on issues on protective measures 

There is no case law concerning these issues. 

5.2.6  Protection against night work (Article 7 of Directive 92/85) 

The security measures that employers are obliged to implement to ensure the safety of 
pregnant  women  or  women  who  are  breastfeeding,  such  as  temporarily  changing  their 
working conditions or working hours, are listed in Article 16 of the MPLPL.  

Article 6 of Regulation No. 193/2000 as amended by Regulation No. 453/2016 stipulates 
that  it  is  prohibited  to  oblige  an  employee  who  is  pregnant  to  work  at  night.  This  also 
applies for the six months after she gives birth, if it is necessary for her health and safety 
and is confirmed with a medical certificate. 

5.2.7  Case law on protection against night work 

None. 

5.2.8  Prohibition of dismissal (Article 10(1) of Directive 92/85) 

Article 50 of the MPLPL grants protection against dismissal without reasonable cause, both 
when an employee has announced their intention to take birth leave or during the birth 
leave;  if  they  are  dismissed  during  this  time  the  reasonable  cause  must  be  provided  in 
writing. Dismissal is prohibited from the time that the employer has been notified of the 
employee’s condition and intention to take a maternity/paternity leave. Article 50 of the 
MPLPL states that ‘employees may not have their employment terminated by reason  of 
having  notified  the  employer  of  their  intention  of  taking  maternity/paternity  leave  or 
parental  leave  under  Article 12  or  Article 46,  or  being  on  maternity/paternity  leave  or 
parental leave unless valid reasons apply, in which case reasons for the termination shall 

107  Regulation No. 453/2016, https://www.reglugerd.is/reglugerdir/allar/nr/931-2000. 

42 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

accompany  notice  of  termination.  The  same  shall  apply  regarding  termination  of 
employment of pregnant employees who have recently given birth.’  

An employer who violates this provision is liable to pay compensation according to general 
rules. This is one of the few provisions in Icelandic labour law where the employers’ right 
to dismiss employees is constrained. As stated in the explanatory report to this new act: 
the provision is intended to protect people in delicate and personal matters like pregnancy 
and giving birth. Obtaining employment while pregnant is challenging, and the likelihood 
of not being rehired if a job is lost during pregnancy is high. Therefore, it is imperative to 
establish  legal  safeguards  for  pregnant  women  and  parents  during  their  maternity  or 
paternity leave. 

5.2.9  Employer’s  obligation  to  substantiate  a  dismissal  in  writing  (Article 10(2)  of 

Directive 92/85) 

In accordance with Article 50 of the MPLPL, the employer is required to substantiate any 
dismissal  in  writing.  This  includes  providing  reasons  for  termination,  which  must 
accompany the notice of termination. The same obligation applies when terminating the 
employment  of  pregnant  employees  who  have  recently  given  birth.  As  stated  in  the 
explanatory  report  regarding  Article 50  of  the  MPLPL,  covering  protection  against 
dismissal,  emphasis  is  placed  on  protecting  employees  who  have  submitted  a  written 
notification that they intend to use their right to take maternity or parental leave or are 
on maternity or parental leave. If an employer decides to dismiss an employee who is in 
such a situation, he must specify the reasons for the dismissal and justify them in writing. 
Article 50 is a necessary provision to prevent negative consequences for an employee from 
exercising  their  rights  under  the  Act.  The  same  conditions  apply  to  the  dismissal  of 
pregnant parents and parents who have recently given birth, but the parent is considered 
to  have  recently  given  birth  when  the  child  is  14  weeks  or  younger.  There  is  a 
corresponding  provision  in  Article 10(2)  of  the  Council  Directive 92/85/EEC  on  the 
implementation of measures to increase  safety and health at work for workers who are 
pregnant, have recently given birth or are breastfeeding. 

5.2.10 Table on the protection against dismissal during pregnancy and maternity leave 

Table 2: Protection against dismissal during pregnancy and maternity leave 

Yes/no 
Yes. 
Article 50 
of the 
MPLPL. 

Protected period 
During pregnancy from time of 
announcement to employer 
until the end of leave 
(six months + six weeks, either 
parent may assign six weeks of 
their independent entitlement 
to the other parent). 

Exceptions  Specific procedure? 
No 
exceptions. 

Cf., Article 7 of the 
MPLPL the Welfare 
Complaints Committee 
shall deliver rulings on 
matters of dispute which 
may arise on the basis 
of the Act. 

5.2.11 Maintenance  of  income  and  other  employment  rights  (Article 11(1)  and  (4)  of 

Directive 92/85)  

The GEA No. 150/2020 protects pregnant employees and those embarking on maternity, 
paternity  or  parental  leave  from  discrimination  as  regards  terms  of  employment, 
promotion and other factors, as stipulated in Article 19(2) of the GEA. 

Article 14  of  the  MPLPL  covers  the  accumulation  and  protection  of  entitlements  and 
provides that maternity/paternity leave is calculated as working time for the purpose of 
assessing  employment-related  entitlements,  such  as  the  right  to  take  vacation  and  to 
extended vacation under collective agreements, age-related wage increases, entitlement 
to sick leave, notice period and unemployment benefits. 

43 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

Article 16  of the MPLPL concerns the health and safety conditions in the workplace that 
the employer must ensure and this is further elaborated on in Regulation No. 193/2000 
as  amended  by  Regulation  No. 453/2016.  Article 3  of  Regulation  No. 931/2000  further 
stipulates  that  the  changes  considered  necessary  in  the  working  conditions  or  working 
time of the woman in accordance with the provision may not impact her wages, i.e. reduce 
them, or other job-related rights. It also states that if it is necessary to grant a pregnant 
worker  leave  from  work  in  accordance  with  Article 11  then  she  is  entitled  to  pay  in 
accordance with Articles 11 and 13 (of the previous MPLPL No. 95/2000). 

This provision does not apply to self-employed individuals – see the rulings of the Welfare 
Appeals Committee Nos. 43/2007, 56/2008 and 36/2011.  

5.2.12 Case law on the protection against dismissal and the maintenance of income and 

other employment rights 

The Equality Complaints Committee ruled in case No. 1/2023 on 20 August 2024 that there 
had been no violation on behalf of the employer where a man complained that his dismissal 
was due to the pregnancy of his spouse on the one hand and his ethnic origin on the other. 
According  to  the  termination  letter,  the  reason  for  his  dismissal  was  an  anticipated 
recession. Two other employees were dismissed, one of them Icelandic and the contracts 
of twelve other employees had not been renewed. The Complaints Committee held that 
likelihood  had  not  been  adduced  that  the  man’s  dismissal  was  linked  to  circumstances 
related to pregnancy (Article 19, paragraph 4 of the Act No. 150/2020 (the GEA) or his 
ethnic  origin  and  Article  15  of  the  Act  No.86/2018  on  Equal  Treatment  on  the  Labour 
Market).  

The Equality Complaints Committee on 13 April 2023108 in the case A v. Mini Market ehf., 
ruled that the company had violated Article 19(2) of GEA No. 150/2020 when dismissing 
A at the end of her maternity leave and revoking her employment contract. The notice of 
termination stated that the reason for dismissal was that A had not returned to work after 
the maternity leave. The company was, however, not able to demonstrate that the decision 
to  dismiss  A  was  based  on  grounds  other  than  the  taking  of  maternity  leave  or  other 
circumstances relating to pregnancy and childbirth (GEA Article 19(4)).  

The  Equality  Complaints  Committee  on  27  April  2023  in  case  9/2022,  A  v  Dýralæknum 
Sandhólaferju  ehf.,  ruled  that  the  employer  S  had  violated  the  GEA,  Article 19(2)  by 
dismissing the employee during her pregnancy. The notice of termination letter stated that 
the  reasons  for  the  dismissal  concerned  changes  in  planning  because  of  an  expected 
recession. The employer S was not able to demonstrate that the dismissal was based on 
grounds  other  than  the  taking  of  maternity  leave  or  other  circumstances  relating  to 
pregnancy and childbirth (GEA Article 19(4)).  

A ruling of the Equality Complaints Committee on 29 December 2023 in case No. 21/2022, 
A v B, concerning dismissal related to pregnancy and childbirth did not find a breach of 
the  GEA  No. 150/2020,  Article 19(2),  which  prohibits  allowing  maternity/paternity  or 
parental  leave,  or  other  circumstances  relating  to  pregnancy  and  childbirth,  to  have  a 
negative  effect  on  decisions  regarding  termination  of  employment.109  The  dispute 
concerned whether the defendant had violated Article 19, paragraphs 1 and 2 of the GEA 
No. 150/2020 allowing issues related to pregnancy to have an impact on the dismissal of 
the  complainant  who  had  been  undergoing  hormonal  therapy  due  to  intended  artificial 
insemination. Potential pregnancy was hence expected when the complainant was 

108  Equality Complaints Committee, case No. 4/2022 on 13 April 2023, A v Mini Market ehf.  
109  Equality Complaints Committee, case No. 21/2022 on 29 December 2023, A v B.  

44 

 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

dismissed. As the complainant was not already pregnant at the time of the dismissal the 
Equality Complaints Committee did not find the defendant in breach of the said provisions 
of the GEA. 110 

One case dealt with by the Equality Complaints Committee in 2021 concerned dismissal 
during pregnancy and failure to pay wages during the notice period. A complained that F 
had dismissed her during her pregnancy, refused to pay her wages during the notice period 
and  disregarded  her  when  re-hiring  for  the  job.  As  the  complaint  concerned  a  dispute 
regarding  the  settlement  of  wages  at  the  termination  of  work,  the  Equality  Complaints 
Committee  decided  that  the  dispute  was  not  within  the  scope  of  its  powers  and  hence 
dismissed that part of the complaint. The Committee  ruled that it had not been proven 
that the maternity leave or other circumstances related to pregnancy or birth had led to 
the  claimant’s  dismissal  or  influenced  the  re-employment  of  a  former  employee.  The 
employer F was hence acquitted of having violated the GEA No. 10/2008.111 

  Maternity leave 

5.3.1  Maternity leave in national law (Article 8(1) and (2) of Directive 92/85) 

The MPLPL No. 144/2020, no longer refers to separate ‘maternity’ or ‘paternity leave’, but 
to  birth  leave  of  up  to  six  months  (Article 8)  for  each  parent.112  The  MPLPL  refers  to 
‘parents’  (rather  than  mothers  or  fathers)  and  provides  in  Article 3  that  each  has  an 
independent right of up to six months’ leave due to birth, primary adoption or reception 
of a child into permanent foster care. This right is not transferable, apart from six weeks 
of their independent right that one parent can transfer to the other.  

If  the  other  parent  dies  during  the  gestation  period,  the  remaining  parent  acquires 
12 months of leave if the child is born alive (Article 9(1)).113 The same applies in the case 
of  a  single  parent  who  has  undergone  assisted  fertilisation  or  a  single  parent  who  has 
adopted  a  child  or  taken  a  child  into  permanent  foster  care. 114  Furthermore,  there  is  a 
right to leave after stillbirth after 22 weeks or miscarriage after 18 weeks. 

A parent who has given birth is entitled to 12 months’ leave if not able to adhere to the 
duty  of  confirming/acknowledging  the  paternity  of  the  child  (Article 9(2)).  The  right  to 
maternity/paternity leave is conditioned on custody and the beginning of the leave. In the 
case of a non-custodial parent, the consent of the parent exercising custody is needed. 

If a parent is subject to a restraining order in respect of their child or have been removed 
from the home due to incapability of taking care of the child, their independent entitlement 
to leave is transferred to the other parent. The same applies in the case of adoption or 
permanent  foster  care  irrespective  of  whether  the  parents  have  joint  custody. 
Furthermore, there is a right to leave after stillbirth after 22 weeks or miscarriage after 
18 weeks. 

Even though entitlement to maternity/paternity leave is established by the birth of a child 
(Article 8(2)), parents may begin taking maternity/paternity leave up to one month prior 
to the expected date of the birth, which may be confirmed by a certificate by a midwife; 
the period will be counted as part of the parent’s independent maternity/paternity leave 

110  Equality Complaints Committee, case No. 21/2022, A v. B, 29 December 2023.  
111  Equality Complaints Committee case No. 21/2020, 3 March 2021. 
112  Lög um fæðingar- og foreldraorlof Nr. 144/2020 literally means Act on Birth and Parental Leave, but is still 

referred to as the Maternity, Paternity, Parental Leave Act. See Committee on Economic, Social and Cultural 
Rights (2021) Iceland’s Fifth Periodic Report on the International Covenant on Economic, Social and 
Cultural Rights in keeping with Articles 16 and 17 of the Covenant; the Government website on Human 
Rights and Equality refers to Act No. 144/2020 in English although it has not been translated: Other 
legislation: Maternity/paternity leave and parental leave.  

113  Act No. 74/2008, Article 5. 
114  Act No. 143/2012, Article 1.  

45 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

entitlement to six months’ leave. It is not compulsory to take leave two weeks before the 
birth of a child, but the parent who has given birth (Article 8(3)) must be on leave for the 
first half month after the birth of the child and the leave cannot begin later than at the 
birth of the child. If the parent who gave birth does not adhere to this duty, the above 
period will still be considered used as part of the independent entitlement. 

The  right  to  maternity/paternity  leave  is  repealed  when  the  child  reaches  the  age  of  2 
years (24 months). 

Parents have a joint right to an extension of maternity/paternity leave by three months 
for each child after the first in a multiple birth that is born alive or stillborn after 22 weeks’ 
pregnancy (Article 15(1)).  

5.3.2  Paid maternity leave (Article 11(2)(b), (3) and (4) of Directive 92/85)  

The monthly payment from the MPLPL fund (2023) for a parent who has been active on 
the domestic labour market for six consecutive months prior to the birth of a child, or the 
date on which a child enters the home in the case of adoption or permanent foster care, 
is 80 % of their salary up to a maximum of EUR 4 000 (ISK 600 000).115 Act No. 73/2024 
amended Article 24 paragraph 1 of the MPLPL to provide that monthly payments can at no 
time  exceed  ISK  900  000  (EUR  6 200)  and  to  add  two  interim  provisions:  after  1  April 
2024,  the  monthly  payment  will  not  exceed  ISK  700 000  (EUR  4 800)  for  parents  of 
children born or adopted before 1 January 2025 and ISK 800 000 (EUR 5 800) for parents 
of  children  born  or  adopted  between  1  January  2025  and  31  December  2025.  Monthly 
payments, in respect of a child born the same year, to a parent in 50-100 % job are never 
lower than EUR 1 407 (ISK 210 695) and for a 25-49 % job the payment is never lower 
than EUR 1 002 (ISK 150 025).116 

The MPLPL also applies to the  entitlement to  maternity/paternity grants of parents  who 
are not active  on the labour market, or are in less than 25 %  of full-time employment, 
and  to  parents  pursuing  full-time  studies.  The  monthly  amount  in  2023  was  EUR 627 
(ISK 91.937). 

If  a  parent  is  entitled  neither  to  maternity/paternity  leave  nor  to  a  maternity/paternity 
grant under the MPLPL, and has no independent entitlement to maternity/paternity leave 
or  a  maternity/paternity  grant  in  another  state,  the  other  parent  will  acquire  an 
entitlement to up to 12 months’ maternity/paternity leave due to the birth of a child, a 
primary adoption or the taking of a child into permanent foster care, as per Article 9(7) of 
the MPLPL. 

5.3.3  Maintenance of employment rights (Article 11(2)(a) of Directive 92/85) 

Article 14  of  the  MPLPL  covers  accumulation  and  protection  of  entitlements. 
Maternity/paternity  leave  is  calculated  as  working  time  for  the  purpose  of  assessing 
employment-related  entitlements,  such  as  the  right  to  take  vacation  and  to  extended 
vacation  under  collective  agreements,  age-related  wage  increases,  entitlement  to  sick 
leave, notice periods and unemployment benefit.  

A parent on maternity leave pays a minimum of 4 % to the pension fund and the maternity 
paternity  leave  fund  pays  a  minimum  of  8 %.  A  parent  is  allowed  to  pay  into  a  private 
fund,  although  the  maternity  paternity  leave  fund  does  in  that  case  not  make  a 
corresponding  contribution.  A  parent  on  maternity  leave  can  request  not  to  pay 
membership fees to their trade union, but that means that their rights within the union 
will (temporarily) expire. 

115  See: https://vinnumalastofnun.is/faedingarorlofssjodur/reiknivel-og-fjarhaedir/fjarhaedir. 
116  See: https://www.vinnumalastofnun.is/faedingarorlofssjodur/starfsmadur. 

46 

 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

5.3.4  Right to return to the same or an equivalent job (Article 15 of Directive 2006/54) 

Article 49 of the MPLPL stipulates:  

‘The employment relations between an employee and her/his employer shall remain 
unchanged during maternity/paternity leave and parental leave. The employee shall 
be entitled to return to her/his job upon the completion of maternity/paternity leave 
or  parental  leave.  Should  this  not  be  possible,  she/he  shall  be  entitled  to  a 
comparable position with the employer according to a contract of employment.’  

This  is  substantially  the  same  provision  as  guaranteed  under  Article 29  of  the  previous 
MPLPL. 

5.3.5  Case law on maternity leave 

A judgment of the District Court of Reykjavík of 10 March 2023 in Case E-582/2021, Anna 
Bryndís  Einarsdóttir  v.  the  Icelandic  Treasury,  concerned  the  decision  of  the  Icelandic 
maternity/paternity  leave  fund  and  the  Welfare  Complaints  Committee  not  to  take  into 
account Ms Einarsdóttir’s income earned in Denmark when determining the amount of her 
maternity payments. 117 

The  Reykjavík  District  Court  had  referred  the  above  question  to  the  EFTA  Court,  which 
delivered its judgment in C-E-5/21 on 29 July 2022.118 The referring court sought guidance 
on  whether  income  received  in  other  EEA  States  should  be  taken  into  account  when 
calculating maternity/ paternity benefits. The first part of the referred question concerned 
whether Article 6 of the Regulation obliges an EEA State to calculate the benefit in question 
on the basis of a person’s aggregated wages on the labour market across the entire EEA. 
The second part of the question was whether a calculation that was based on a person’s 
aggregate wages only on the domestic labour marked is an infringement of Article 29 of 
the EEA Agreement. 

The EFTA Court noted that Article 6 of the Regulation concerns the entitlement to benefits, 
and not how benefits are calculated. Furthermore, that pursuant to Article 21(2) and (3) 
of  the  Regulation,  the  calculation  of  cash  benefits  is  linked  to  the  income  paid  in  the 
domestic labour market. Accordingly, the competent institution is not obliged to calculate 
the  amount  of  a  benefit  such  as  that  at  issue  in  the  main  proceedings,  on  the  basis  of 
income received in another EEA State. 

However, the Court held that Article 21 of the Regulation must be interpreted in light of 
Article 29  EEA,  which  entails  that  migrant  workers  must  not  lose  their  right  to  social 
security  benefits  or  have  the  amount  of  those  benefits  reduced  because  they  have 
exercised their right to free movement. Thus, the Court found that attributing no income 
to periods of employment completed in other EEA States is incompatible with Article 21(2) 
and  (3).  The  Court  therefore  concluded  that  Article 21(2)  and  (3),  interpreted  in 
accordance  with  the  objective  set  out  in  Article 29  EEA,  requires  that  the  amount  of  a 
benefit, such as that at issue in the main proceedings, granted to a migrant worker who, 
during the reference period set out in national law only had income in another EEA State, 
must  be  calculated  by  taking  into  account  the  income  of  a  person  who  has  comparable 

117  Reykjavík District Court Judgment in Case E-582/2021, A v the Icelandic State, 10 March 2021: 

https://www.heradsdomstolar.is/default.aspx?pageid=347c3bb1-8926-11e5-80c6-
005056bc6a40&id=0bb1c562-240e-4f56-ad88-4c7e46029250. 

118  EFTA Court, Case E-5/21, Anna Bryndís Einarsdóttir v the Icelandic Treasury, 29 July 2022, 

https://eftacourt.int/press-publications/judgment-in-case-e-521-anna-bryndis-einarsdottir-v-rikissjodur-
islands/. 

47 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

experience and qualifications and who is similarly employed in the EEA State in which that 
benefit is sought.119 

In  its  judgment,  the  district  court  referred  to  the  previous  version  of  the  MPLPL  Act 
No. 95/2000, prevailing at the time of the ruling of the Welfare  Complaints Committee, 
which applies to the rights of parents working in the domestic labour market. According to 
Article 13  (1)  of  that  Act,  a  parent  requires  the  right  to  payments  from  the 
maternity/paternity leave fund after he/she has been active on the domestic labour market 
for six consecutive months prior to the birth of a child. As stipulated in Article 13(12) when 
a  parent  has  worked  on  the  domestic  labour  market  for  at  least  the  last  month  of  the 
rights  acquisition  period,  the  Directorate  of  Labour  must,  to  the  extent  necessary  take 
account of his/her working periods as an employee or self-employed individual in another 
Member  State  of  the  EEA  and  other  agreements  enumerated  in  the  said  provision, 
providing that the parent’s work conferred rights on him/her under the legislation of the 
state in question regarding maternity/paternity leave. A condition for this is that the parent 
began work on the domestic labour market within 10 working days of stopping work on 
the labour market of the other state within the EEA. It was not contested that the claimant 
met these conditions and had been active on the labour market during the reference period 
mentioned in Article 13(1) of Act No. 95/2000. 

The  dispute  concerned  whether  the  wages  that  the  claimant  earned  when  working  in 
Denmark  ought  to  be  taken  into  account  when  the  average  total  payments  from  the 
Maternity/Paternity Leave fund were calculated. The district court held that the provision 
of  Article 13(1)  is  peremptory  and  that  a  parent  acquires  the  right  to  payments  after 
having been active on the domestic labour market for six consecutive months prior to the 
birth of a child. The term ‘domestic labour market’ cannot be interpreted so widely as to 
include all labour markets within the EEA as if there were one common labour market of 
the EEA Member States. The Icelandic Treasury was hence acquitted of the claim and the 
claimant’s  request  to  invalidate  the  ruling  of  the  Welfare  Complaints  Committee 
No. 261/2020 failed. 

Supreme  Court  Case  No. 199/2006  concerned  a  woman  who  had  been  on  leave  for  13 
months and was supposed to return to her job on 1 February 2005. During her leave, new 
owners took over the company and general changes were made in her job area and she 
was offered another job. This led the woman to conclude that her job no longer existed. 
She  subsequently  decided  not  to  work  during  what  she  perceived  as  the  three-month 
period of notice of employment termination. The Supreme Court held that, as she had not 
turned up for work when she was supposed to, she was not in a position to assess whether 
the new job offered to her was different from the previous one and that hence she was at 
fault, according to the terms of agreement with the company which was acquitted of her 
claims.120 

119  EFTA Court (2022), ‘Case E-5/21 – Anna Bryndís Einarsdóttir v the Icelandic Treasury’, press release 

04.2022, https://www.llv.li/serviceportal2/amtsstellen/stabstelle-ewr/pdf-llv-sewr-
eftacourt_annual_report_2022.pdf. 
120  Supreme Court case No. 199/2006. 

48 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

5.3.6  Table on maternity leave 

Table 3: Maternity leave 

Duration  Obligatory 

period 

2 weeks. 

6 
months. 

  Paternity leave 

Possibility to 
share maternity 
leave? 
Six weeks out of 
six months 
transferable to 
other parent. 

Payment or 
allowance 

80 % of their salary 
up to a maximum of 
ISK 700 000 
(EUR 4 842). 

Right to return 
after the end of 
maternity leave 
Employment 
relations remain 
unchanged 
(Art. 49). 

5.4.1  Paternity  leave  in  national  law  (recital  26  Directive of  2006/54  and  Articles  3(a) 

and 4 of Directive 2019/1158)  

A non-transferable paid paternity leave was introduced with the MPLPL Act No. 95/2000; 
hence the focus on fathers’ greater participation in childcare has been in existence for a 
quarter of a century. Under the current Icelandic law there is no special ‘paternity’ leave, 
but  rather  a  leave  for  parents.  Article 8  of  the  MPLPL  refers  to  ‘parents’  (rather  than 
mothers  or  fathers  because  parents  can  be  of  same  sex),  providing  that  each  has  an 
independent right of up to six months’ leave due to birth, primary adoption or reception 
of a child into permanent foster care. This right is not transferable, apart from six weeks 
of the independent six-month right that one parent can transfer to the other. The right is 
available to any parent with custody or joint custody with the other parent in the case of 
the birth of their child, primary adoption or reception of a child into permanent foster care 
(Article 8 of the MPLPL). A non-custodial parent is entitled to parental leave if the consent 
of the parent exercising custody is obtained. 

In  addition  to  the  six  months,  parents  have  a  joint  entitlement  to  an  additional  three 
months’ leave for each child after the first in a multiple birth that is born alive or stillborn 
after 22 weeks of pregnancy (Article 15(1)), which either parent may use in its entirety or 
the parents may divide between them.121 

If  the  other  parent  dies  during  the  gestation  period  and  the  child  is  born  alive,  the 
remaining parent acquires the right to a 12-month period of leave if the child is born alive 
(Article 9(1)).122 The same applies to a single parent who has adopted a child or taken a 
child into permanent foster care. 123  

The aim of the MPLPL is to enable parents to co-ordinate family life and work outside the 
home  (as  stated  in  Article 2).  Article 13  of  the  MPLPL  concerns  the  structure  of 
maternity/paternity leave, enabling employees by arrangement with their employers, to 
structure their leave in such a way that it is divided into more than one period and/or that 
it will be taken concurrently with work in reduced job proportion (subject, however, to the 
conditions in the third paragraph of Article 8). At no time may maternity/paternity leave 
be taken in periods of less than two weeks at a time. The employer should nevertheless 
try to accommodate the employee’s wishes regarding maternity/paternity leave. 

121  Statistics show that Icelandic fathers use 30 % of the total permissible leave. See: BSRB (2017) ‘Even 

fewer fathers take advantage of their right to paternity leave’, 5 April 2017, 
https://www.bsrb.is/is/frettakerfi/enn-faerri-fedur-nyta-rett-sinn-til-faedingarorlofs. 

122  Act No. 74/2008, Article 5. 
123  Act No. 143/2012, Article 1.  

49 

 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

According  to  a  recent  survey,  mothers  use  the  additional  three  months  in  most  cases, 
while the proportion of fathers who do not make use of their independent rights is going 
down.124 

5.4.2  Paid paternity leave (Article 8(1) and (2) of Directive 2019/1158) 

The monthly payment from the MPLPL fund (2023) for a parent who has been active on 
the domestic labour market for six consecutive months prior to the birth of a child, or the 
date on which a child enters the home in the case of adoption or permanent foster care, 
is  80 %  of  their  salary  up  to  a  maximum  of  EUR 4 000  (ISK 600 000).125  Monthly 
payments, in respect of a child born the same year, to a parent in 50-100 % job are never 
lower than EUR 1 407 (ISK 210 695) and for a 25-49 % job the payment is never lower 
than EUR 1 002 (ISK 150 025).126 

5.4.3  Legal  protection  of  the  right  to  paternity  leave  (Articles  10,  11  and  12  of 

Directive 2019/1158) 

The MPLPL No. 144/2020, no longer refers to separate ‘maternal’ or ‘paternal leave’, but 
to birth leave of up to  six months (Article 8) for  each parent.127 The provision refers to 
‘parents’ (rather than mothers or fathers) and provides that each has an independent right 
of  up  to  six  months’  leave  due  to  birth,  primary  adoption  or  reception  of  a  child  into 
permanent  foster  care.  This  right  is  not  transferable,  apart  from  six  weeks  of  their 
independent right that one parent can transfer to the other. In addition, parents have a 
joint right to two additional months that they can either divide between them or wholly 
transfer to the other parent. In the previous law, the independent three-month right was 
not  transferable.  The  right  to  maternity  leave  is  established  upon  the  birth  of  a  child. 
Despite this clause, however, a parent acquires the right to a 12-month period of leave if 
the  other  parent  dies  during  the  gestation  period  and  the  child  is  born  alive 
(Article 9(1)).128  The  same  applies  to  a  single  mother  who  has  undergone  assisted 
fertilisation or a single  parent who has  adopted a child or taken a child into permanent 
foster care.129 A parent who has given birth is entitled to 12 months’ leave in cases where 
the paternity of the child cannot be confirmed (Article 9(2)). 

Article 49 of the MPLPL stipulates that the contractual relationship between employee and 
employer  must  remain  unchanged  during  maternity/paternity  leave.  The  employee  has 
the right to return to their job after maternity/paternity leave. If this is not possible, then 
they  are  entitled  to  a  comparable  position  with  the  employer  in  accordance  with  the 
employment contract. 

Furthermore  Article 50  of  the  MPLPL  grants  protection  against  dismissal  without 
reasonable cause, when an employee has announced their intention to take either birth or 
parental leave.  

124  Directorate for Gender Equality (2021) Kortlagning kynjasjónarmiða Stöðuskýrsla 2021 (Mapping gender 

perspectives 2021). 

125  See Directorate of Labour, Maternity Paternity Leave Fund, Amounts website: 

https://vinnumalastofnun.is/faedingarorlofssjodur/reiknivel-og-fjarhaedir/fjarhaedir. 

126  See Directorate of Labour, Maternity Paternity Leave Fund website: 

https://www.vinnumalastofnun.is/faedingarorlofssjodur/starfsmadur. 

127  Lög um fæðingar- og foreldraorlof Nr. 144/2020 literally means Act on Birth and Parental Leave, but is still 

referred to as the Maternity, Paternity, Parental Leave Act. See Committee on Economic, Social and Cultural 
Rights (2021) Iceland’s Fifth Periodic Report on the International Covenant on Economic, Social and 
Cultural Rights in keeping with Articles 16 and 17 of the Covenant; the Government website on Human 
Rights and Equality refers to Act No. 144/2020 in English although it has not been translated: Other 
legislation: Maternity/paternity leave and parental leave.  

128  Act No. 74/2008, Article 5. 
129  Act No. 143/2012, Article 1.  

50 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

5.4.4  Case law on paternity leave 

None. 

5.4.5  Table on paternity leave 

Table 4: Paternity leave 

Who is entitled? 

Duration  Payment or 

Parents have an independent entitlement to 
(maternity) paternity leave of up to 6 months 
each following the birth of a child, the primary 
adoption or the taking of a child into permanent 
foster care. 

Six 
months. 

allowance 
80 % of their salary up 
to a maximum of 
ISK 700 000 (EUR 4 
842). 

  Adoption leave 

5.5.1  Adoption leave in national law (recital 27 of Directive 2006/54)130 

The MPLPL refers to leave from salaried employment in the event of primary adoption of 
a child (Article 8(4)) or permanent foster care. In the case of adoption or permanent foster 
care, the time reference is based on the date that the child enters the home, provided that 
it is confirmed by the  relevant competent bodies. If the parents have to fetch the child 
from another country, the maternity/paternity leave may begin at the start of the journey, 
providing the relevant authorities or institutions have confirmed that permission has been 
granted for the adoption of a child.  

Parents who adopt, or take into permanent foster care, more than one child at the same 
time, have a joint right to extend maternity/paternity leave by three months in respect of 
each child after the first (Article 15(2)). 

5.5.2  Legal protection of the right to adoption leave (Article 16 of Directive 2006/54) 

The  rights  entailed  in  the  MPLPL  apply  equally  to  adoptive  parents  as  they  do  to  those 
giving birth. Adoptive parents may not be dismissed due to their intention to exercise their 
right  to  take  a  period  of  leave,  stated  according  to  Articles  12  or  46  of  the  MPLPL,  as 
provided for in its Article 50. 

5.5.3  Case law on adoption leave 

None in relation to adoption. 

  Parental leave 

5.6.1  Parental leave in national law (Article 5 (1), (2) and (4) of Directive 2019/1158) 

Article 44 of the MPLPL No. 144/2020 concerns parental leave, where each parent (under 
the first paragraph of Article 1) has an independent right to parental leave, which is not 
transferable. Parental leave is not accompanied by payment from the maternity/paternity 
leave fund. 

130  Adoption leave is defined at EU level as an individual and non-transferable right to leave of men and 

women subsequent to the adoption of a child. While in the case of birth there are two distinct rights to 
create an early bonding with the child, i.e. maternity leave for the delivering mother and paternity leave for 
the other parent, in the case of adoption there is an only right to leave (adoption leave), which under the 
EU definition should be the same for each adoptive parent. 

51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

Parental leave can be taken for four months and is established upon the birth of a child. 

In the case of adoption, or permanent foster care of a child, account must be taken of the 
time  when  the  child  enters  the  home,  providing  this  is  confirmed  by  the  child  welfare 
committee in question, or other competent bodies. If a parent has to fetch the child from 
another  country,  parental  leave  may  begin  at  the  start  of  the  journey,  providing  the 
relevant authorities or institutions have confirmed that permission has been granted for 
the adoption of a child. 

5.6.2  Period of notice (Article 5(3) of Directive 2019/1158) 

An  employee  who  intends  to  exercise  their  right  to  parental  leave  must  notify  their 
employer thereof as soon as possible and at the latest six weeks prior to the intended first 
day of the leave, as per Article 12 of the MPLPL. Notice of parental leave should be given 
in writing and state the intended starting day of the leave, its length and its structure. The 
employer  signs  the  notification  with  the  date  of  receiving  it  and  delivers  a  copy  to  the 
employee. The employer must record the taking of parental leave, enabling the employee 
to obtain a certificate stating the number of days of parental leave if they wish. 

5.6.3  Postponement of parental leave (Article 5(5) of Directive 2019/1158) 

If the employer is unable to grant the employee’s wishes regarding the structure of the 
parental  leave,  they  must,  in  consultation  with  the  employee,  propose  a  different 
arrangement within one week from the day of receipt of the notification (as per Article 47 
(1)). This must be done in writing, stating the reasons and, if it involves a postponement, 
the length of the postponement. 

As stated in Article 47, postponement is only permitted in extraordinary circumstances in 
the  operations  of the company/institution that necessitate it. Postponement is possible, 
e.g.  in  the  case  of  seasonal  work,  or  if  no  qualified  substitute  can  be  found,  or  if  a 
considerable number of the employees apply to take parental leave simultaneously, or if 
the employee in question holds a key position in the top management of the company or 
institution. At no time may an employer postpone parental leave by more than six months 
from the time it was to start, according to the employee’s request, without the employee’s 
approval.  

Parental leave directly following maternity/paternity leave, or where serious illness of the 
child renders the parent’s presence necessary, may never be postponed (Article 47(4)). 
Furthermore,  postponement  is  not  permitted  when  the  employer  has  already  agreed  to 
the taking of parental leave, or the period of notice under the first paragraph has passed 
without a response from the employer. If a parent is not enabled to take the leave before 
the child reaches the age of eight years, the period during which parental leave may be 
taken is extended to the child’s ninth birthday. 

5.6.4  Flexible take-up of parental leave (Article 5(6) of Directive 2019/1158) 

Parental leave may be taken in one session. It may be divided up into shorter periods, or 
it may be taken with a reduced full-time/part-time ratio. 

5.6.5  Special rules for adoptive parents, parents with a disability and parents of children 

with a disability or a long-term illness (Article 5(8) Directive 2019/1158) 

See 5.6.3 above. There are no other specific rights in this regard. 

52 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

5.6.6  Paid parental leave (Article 8(1) and (3) of Directive 2019/1158) 

Parental leave is not accompanied by payment from the maternity/paternity leave fund. 
Employers are under no obligation to partially pay an employee who is on parental leave 
and no collective agreements contain such requirements, as the law is clear that this is 
unpaid leave. 

It  is  not  envisaged  that  a  parent  will  continue  to  receive  wages  during  parental  leave. 
However, emphasis is placed on the fact that the employment relationship between the 
employer  and  the  employee  remains  in  force  for  the  duration  of  the  parental  leave.  No 
other  payments  are  made  by  the  state  or  municipalities,  and  an  employee  on  parental 
leave is not entitled to unemployment benefits, as they are not considered to be seeking 
employment during the leave. 

5.6.7  Legal  protection  of  the  right  to  parental  leave  (Articles  10,  11  and  12  of 

Directive 2019/1158) 

Article 48 of the MPLPL covers the protection of accumulated entitlements during parental 
leave. The said provision provides that entitlements that an employee has already earned, 
or is earning on the starting date of parental leave, remain unchanged until the end of the 
leave  period,  and  that  these  entitlements,  together  with  any  changes  that  may  have 
occurred on the basis of legislation or collective agreements, remain in force.  

Article 49 of the MPLPL provides that the contractual relationship between employee and 
employer remains unchanged during parental leave. The employee has the right to return 
to their job after the leave. If this is not possible, then they are entitled to a comparable 
position with the employer in accordance with the employment contract. 

Article 50  of  the  MPLPL  covers  the  protection  against  termination  by  reason  of  having 
notified the employer of their intention of taking parental leave or being on parental leave 
unless  valid  reasons  apply,  in  which  case  reasons  for  the  termination  must  accompany 
notice of termination. 

5.6.8  Case law on parental leave 

None. 

5.6.9  Table on parental leave 

Table 5: Parental leave 

Duration 
of leave 

Right to leave 
individual and 
non-transferable? 

Paid 
period 

4 months.  Not transferable. 

0. 

Right to payment or 
allowance individual 
and non-
transferable? 
N/A. 

Payment or 
allowance 

N/A. 

  Child-related leave in relation to surrogacy 

5.7.1  Prohibition of surrogacy 

Surrogacy is prohibited by Act No. 55/1996.  

5.7.2  Child-related leave in relation to surrogacy 

A draft law on altruistic surrogacy was put before the Althingi during its 144th session in 
2014-2015  but  has  not  been  adopted.  It  is  ‘stuck’  in  the  Parliament’s  Welfare 

53 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

Committee.131 According to the draft, the surrogate mother while pregnant has the same 
rights as any pregnant woman with regard to health services. According to Article 23 of 
the  draft  law,  the  surrogate  mother  and  her  spouse,  if  relevant,  and  the  prospective 
parents  are  entitled  to  maternity/paternity  leave  and  parental  leave  under  the  Act  on 
Maternity/Paternity Leave and Parental Leave No. 95/2000. 

5.7.3  Case law on child-related leave in relation to surrogacy 

As surrogacy is prohibited in Iceland, individuals have tried to get confirmation of parental 
legal recognition using surrogacy abroad where permitted. The Supreme Court in 2017132 
rejected the claim to invalidate the refusal of the Ministry of Justice to recognise a parental 
link between the claimants and the child.  The  claimants claimed confirmation  of a birth 
certificate  issued  in  California  stating  that  they  were  the  legitimate  parents  of  the  child 
born to them via a surrogate mother. They based their claim on Article 71 of the Icelandic 
Constitution and Article 8 of the European Convention on Human Rights (right to respect 
for private and family life). The Supreme Court held that with a counter-argument based 
on  the  law  prohibiting  surrogacy:133  a  woman  who  had  given  birth  after  artificial 
fertilisation was according to Icelandic law the only legitimate mother. Hence the claimants 
could not be recognised as legitimate parents. Further to that the Supreme Court held in 
accordance with the principle of international civil law that authorities had no obligation to 
recognise the decision of a foreign state regarding personal rights if such decisions were 
contrary to the domestic law of the state in question. 

The Supreme Court decision was referred to the European Court of Human Rights,134 which 
confirmed that the ruling had sufficient basis in domestic law. 

  Carers’ leave 

5.8.1  Carers’  leave  in  national  law  (Articles  3(1)(c),  (d)  and  (e)  and  6  of 

Directive 2019/1158) 

Icelandic trade union agreements entail limited rights for workers to take leave to care for 
their sick children. Directive 2019/1158 has still not been formally incorporated into the 
EEA agreement.135 It has been reviewed within the Ministry of Social Affairs and Labour 
and  passed  with  constitutional  reservation  to  the  Ministry  of  Foreign  Affairs  as  it  is 
anticipated that it will call for legal amendments. Consultation with stakeholders on the 
labour market on how to transpose the Directive are ongoing and results are expected in 
the  spring  of  2025.136  The  Icelandic  Confederation  of  Labour  has  aired  the  view  that  in 
accordance  with  the  Directive,  the  right  to  care  leave  will  be  extended  to  other  close 
relatives dependent on the worker and that the leave will be paid, albeit with the same 
time limit as that concerning children.137 

Parents may have rights to take paid leave because of their sick children under 13 years 
of  age  depending  on  their  trade  union  agreements.  If  the  duration  of  the  illness  of  the 
child is lengthy, the parent may have a right to per diem sickness payments from their 
trade union’s sickness benefit funds. Act No. 104/2024 amended the Act on payments to 

131  See: https://www.althingi.is/thingstorf/thingmalalistar-eftir-thingum/ferill/?ltg=145&mnr=229.  
132  Supreme Court case no. 367/2016, 30 March 2017. 

https://www.haestirettur.is/default.aspx?pageid=347c3bb1-8926-11e5-80c6-005056bc6a40&id=5470fe9c-
fda8-4c08-a1dd-ff014544612f. 

133  Act on artificial fertilisation and use of human gametes and embryos for stem-cell resarch, No. 55/1996, 

Art. 5, para. 4. https://www.government.is/library/04-
Legislation/Act%20No%2055%201996%20on%20Artificial%20Fertilisation%20etc%20as%20amended%20
2023_updated%202024.pdf.  

134  European Court of Human Rights, Valdís Fjölnisdóttir and Others v. Iceland, No. 71552/17, 18 May 2021. 
135  Information obtained from the Ministry of Social Affairs on 18 February 2025. 
136  Information obtained from the Ministry of Social Affairs on 18 February 2025. 
137  See: https://www.mbl.is/frettir/innlent/2019/07/29/geta_fengid_leyfi_til_ad_annast_nakomna/.  

54 

 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

parents  of  chronically  ill  or  severely  disabled  children,  No.  22/2006,  so  that  the  term 
‘pension payments’ in paragraph 2 of Article 29 is replaced by ‘pension- or sickness- or 
rehabilitation payments’.138 

The Social Assistance Act No. 99/2007139 provides that parents of disabled or chronically 
ill children can apply for financial support from the Social Insurance Administration (TR). 
This public assistance is provided when caring for the children is demanding and costly. 
Certain conditions for disability and illness must be fulfilled in order for parents to receive 
payments. 140  

Carers’ payments are based on Article 4 of the Social Assistance Act No. 99/2007,141 which 
stipulates  that  the  Social  Insurance  Administration  may  pay  a  home-care  allowance  to 
persons who support disabled and chronically ill children who live at home or in a hospital 
and/or  take  a  larger  part  in  the  payment  of  medical  expenses  if  the  child’s  mental  or 
physical disability involves substantial expenses and special care or looking after. Home-
care  allowance  may  be  paid  to  persons  supporting  children  with  serious  developmental 
disorders  that  may  be  regarded  as  the  equivalent  of  disabilities,  and  of  children  with 
serious  behavioural  problems  that  may  be  regarded  as  the  equivalent  of  psychiatric 
illnesses. Under special circumstances, payments of home-care allowance may be raised 
by up to 25 %.  

The home-care allowance is based on Article 4 of the Social Assistance Act No. 99/2007 
and  Regulation  No. 504/1997.  Regulation  No. 504/1997  distinguishes  between  five 
different categories of payments depending on different conditions. The highest amount 
(2024) is EUR 1 812 (ISK 260 427).  

Article 5 of the Act No. 99/2007 covers spouse’s benefit and home-care benefit. It provides 
that  if  special  circumstances  obtain,  old-age  and  invalidity  pensioners  may  be  paid 
spouse’s  benefit  amounting  to  up  to  80 %  of  the  full  invalidity  pensions  and  pension 
supplements under Articles 18 and 22 of the Social Security Act. Furthermore, if special 
circumstances obtain, other persons who maintain households with old-age and invalidity 
pensioners may be paid home-care benefit.  

The aim of Act No. 22/2006 on payments for chronically ill or severely disabled children is 
to counter the loss of income or working time when job-related rights and social assistance 
measures have been exhausted. Payments are taxable.142 

5.8.2  Legal  protection  of  the  right  to  carers’  leave  (Articles  10,  11  and  12  of 

Directive 2019/1158) 

Article 13  of  the  Act  No. 22/2006  on  payments  to  parents  of  chronically  ill  or  severely 
disabled children,143 concerns the accumulation and protection of rights. It provides that 
a parent (who according to Article 3(d) of the same act is a wage earner who engages in 
paid employment in the service of others in at  least 25 %  of full-time  employment and 
Article 3(e)  self-employed  individuals,  i.e.  any  person  who  runs  his  own  business, 
irrespective of its corporate structure, at a level of operations sufficient for them to pay 
social security tax each month or at other regular intervals) must make payments of at 

138  The amendments to Act No. 22/2006 have not yet been translated into English. 
139  Social Assistance Act No. 99/2007, https://www.althingi.is/lagas/nuna/2006022.html (English translation 

has not been updated since 2017). 

140  See: Iceland (2020) ‘Care payments and payments to parents of chronically ill or disabled children’.  
141  See: https://www.government.is/library/04-

Legislation/Social%20Assistance%20Act%20No%2099%202007%20as%20amended%202018.pdf.  

142  Iceland Insurance Agency, ‘Parental allowances for chronically ill or severely disabled children’, 
https://island.is/foreldragreidslur-vegna-langveikra-eda-alvarlega-fatladra-barna/foreldrar-a-
vinnumarka%C3%B0i. 

143  Act No. 22/2006 on payments to parents of chronically ill or severely disabled children with later 

amendments. 

55 

 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

least 4 % into a pension fund and the Treasury will pay a corresponding contribution of 
8 %. In addition, a parent may ask to continue to pay contributions to their trade union, 
in which case the executive party is responsible for making the payments to the relevant 
trade union. 

5.8.3  Case law on carers’ leave 

A  Supreme  Court  judgment  in  2016  concerned  a  case  in  which  the  Social  Insurance 
Administration (TR) had, in 2013, approved an application by a woman, the mother of a 
son with multiple disabilities, to purchase a special car but deducted from the amount a 
prior allowance granted to the same person in 2009. The woman’s claim was to receive a 
full  allowance  the  second  time,  maintaining  that  the  TR’s  decision  did  not  comply  with 
Article 76 of the Constitution on assistance in cases of disability, the Social Assistance Act 
No. 99/2007,  and  Regulation  No. 170/2009  on  allowances  and  compensation  for  multi-
handicapped individuals needing special cars. 

The Supreme Court did not accept the Social Insurance Administration’s (TR) defence that, 
due to the mother’s lack of legal standing, the TR should be acquitted in accordance with 
Article 16, paragraph 2 of the Code of Civil Procedure No. 91/1991. The Court emphasised 
that although the mother had applied for the allowance on behalf of her son, the Social 
Insurance Administration had considered her as the applicant for the allowance. The TR 
had paid the allowance to the mother, who had purchased the car and was registered as 
its  owner.  The  Court  reiterated  that,  in  accordance  with  Article 60  of  the  Constitution, 
judges settle all disputes regarding the competence of the authorities. However, it was not 
within the competence of the Court to assess with expertise whether the Social Insurance 
Administration  should  have  granted  the  allowance  and  subsequently  the  amount, 
considering the son’s medical condition, multiple disabilities, and other factors. 

The Court referred to the Social Assistance Act No. 99/2007, Article 10(3), which provides 
that the Social Insurance Administration may grant allowances at five-year intervals for 
the same individual, which was the case here. Hence, the Social Insurance Administration 
was acquitted. 

5.8.4  Table on carers’ leave 

Table 6: Table on carers’ leave 

National 
leave and 
duration 
Up to 6 
months. 

Type of entitlement 

Beneficiaries  Situations 

80 % of paid salary – 
maximum payment ISK 
1 060 000 before taxes. 

Children. 

covered 

Chronically ill or 
severely disabled 
children. 

  Time off for force majeure 

5.9.1  Time off for force majeure (Article 7 of Directive 2019/1158) 

In trade union agreements, it is standard practice to exempt occurrences resulting from 
unforeseeable  external  factors  (force  majeure).  These  factors  may  include  events  like 
natural disasters, fires, and more. 

Although Icelandic legislation does not provide general rules for force majeure, the Act on 
respecting labourers’ right to advance notice of termination of employment and to wages 
on account of absence through illness and accidents, No. 19/1979, entails a provision in 
Article 3 that is applicable to employment contracts, referring to an ‘unforeseen calamity’, 
such as on account of fire or the loss of a vessel, the employer will not be required to pay 

56 

 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

indemnity  to  his  wage  earners  although  their  work  does  not  amount  to  130  hours  per 
month,  provided  that  wage  earners  do  not  forfeit  their  right  to  advance  notice  of 
termination while such a condition prevails. If a worker loses his employment due to the 
aforementioned reasons and he is offered another job that he wishes to accept he is not 
bound by the provisions of Article 1(5) relating to advance notice of termination, provided 
that he/she gives the employer immediate notice that he is taking up another job for the 
future. 

5.9.2  Legal protection  of the  right to time-off for force majeure (Articles 10 and 11  of 

Directive 2019/1158) 

Currently, Icelandic law contains no special legislation on time off for force majeure; such 
situations are handled through collective agreements or employer discretion. This is a gap 
that will need to be addressed upon transposition of Directive 2019/1158. 

5.9.3  Case law on time off for force majeure 

No case law. 

5.9.4  Table on time-off for force majeure 

Table 7: Table on time-off for force majeure  

National measure and duration  Type of entitlement  Situations covered 
N/A. 

N/A. 

N/A. 

 Flexible working time arrangements (FWAs) 

5.10.1 Right to FWAs (Article 3(1)(d) and (f) and 9 of Directive 2019/1158) 

One of the objectives of the GEA No. 150/2020 as stated in Article 1(e) of the Act is to 
enable everyone, irrespective of gender, to reconcile their work and family life. Article 13 
of the GEA on the reconciliation of work and family life is substantially the same as in the 
previous  GEA No. 10/2008 (Article 21). It provides that employers must take measures 
necessary to enable employees (instead of ‘women and men’ in the previous GEA due to 
the adoption of the law on Gender Autonomy No. 80/2019) to reconcile their professional 
obligations  and  family  responsibilities,  adding  ‘irrespective  of  gender’.  Amongst  other 
things, such measures are aimed at increasing flexibility in the organisation of work and 
working hours in such a way as to take account of both workers’ family circumstances and 
the  needs  of  the  labour  market,  including  facilitating  the  return  of  employees  to  work 
following maternity/paternity or parental leave or leave from work due to pressing family 
circumstances. The word ‘unavoidable’ was removed from the previous GEA No. 10/2008 
and the word ‘pressing’ is used instead.144 The requirement that employers take measures 
to enable women and men to reconcile work and family life means that they must try to 
meet the requests of their employees to reduce working hours when needed.  

At present, Icelandic  employees  cannot  rely  on a legal  right to request flexible working 
arrangements. This is a clear gap compared with Article 9 of Directive 2019/1158. 
Incorporation  of  the  Directive  into  the  EEA  Agreement  will  require  new  legislation  or 
amendments to ensure this right is recognised. 

144  The English translation of the new GEA No. 150/2020 still includes the word ‘unavoidable’ which is not in 

the Icelandic version. See: https://www.government.is/library/04-
Legislation/Act%20on%20Equal%20Status%20and%20Equal%20Rights%20Irrespective%20of%20Gender.
pdf, Article 13. 

57 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

5.10.2 Duration of FWAs (recital 35 and Article 9(1) and (3) of Directive 2019/1158)  

The  forthcoming  transposition  of  the  WLB  Directive will  require  legal  amendments. 
Therefore, the requirement of Article 9(1) of the WLB Directive is not timely in the current 
context.  Flexible  working  arrangements  (FWA)  and  their  duration  are  based  on  an 
agreement  between  the  employer  and  the  employee  since  there  is  no  legal  obligation 
guaranteeing that workers with children up to a specified age, (which will be at least eight 
years),  and  caregivers,  have  the  right  to  flexible  working  arrangements  for  caregiving 
purposes. 

Article 13 of the GEA provides that the employer must facilitate the return of employees 
to  work  following  maternity,  paternity,  or  parental  leave,  or  leave  from  work  due  to 
pressing  family  circumstances.  There  are,  however,  no  explicit  rules  on  the  amount  of 
reduced working hours, flexible working hours and flexibility in place of work. 
5.10.3 Legal protection of the right to FWAs (Articles 11 and 12 of Directive 2019/1158) 

After the incorporation of Directive 2019/1158 into the EEA Agreement, the procedure of 
transposition into national law will take place. Most likely that procedure will strengthen 
the right to request flexible working arrangements, although it is too soon to say. 

5.10.4 Case law on FWAs and legal protection of the right to FWAs 

The Gender Complaints Committee in case No. 1/2018145 (21 June 2018) ruled that the 
Fisk Seafood company had violated the right of an employee regarding reconciliation of 
work and family life (Article 21 of the previous GEA No. 10/2008). The company rejected 
the  employee’s  request  to  temporarily  reduce  her  working  hours  in  the  wake  of  her 
maternity leave due to difficulties in finding day care for her infant child. The Committee 
ruled that the complainant had proven that she had undertaken the measures she deemed 
necessary  to  return  to  her  job  after  the  maternity  leave  without  success.  Hence  the 
employer  was  to  blame  for  not  having  accommodated  the  needs  of  the  employee  with 
temporary measures and so was liable for violating Article 21 of the GEA. 

5.10.5 Table on FWAs 

Table 8: Table on FWAs  

National 
system/s 
N/A. 

Absolute or relative 
right 
N/A. 

FWAs covered and workers 
entitled 
N/A. 

 Evaluation of implementation 

A 2022 global parent pay index146 shows that Iceland ranks among the top five globally 
as  regards  the  length  of  maternity/paternity  leave,  which  in  Iceland  is  six  months  with 
parents getting 80 % of their total salary from the MPLPL fund.  

The assessment of the author of this report is that Icelandic law does not fall short of EU 
law and has achieved the goals set out in this area. 

145  Equality Complaints Committee No. 1/2018, 21 June 2018, A v Fisk Seafood efh. 
146  See: Lensa (2022) ‘Global parent pay index’, 13 May 2022, https://lensa.com/insights/global-parent-pay-

index/#h-the-best-countries-for-paid-parental-leave.  

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

 Remaining issues 

It might be of interest here that the fertility rate is constantly going down. In 2022 147 it 
was 1.59 which is the lowest since measures started in 1853. 148  

It  has  been  pointed  out  that  in  cases  when  expecting  parents  intending  to  take  their 
maternity/paternity leave are dismissed, such instances are not necessarily contested in 
a formal process, which is the paradigm that the legislature looks at when assessing the 
effectiveness of the law. In some cases, employees reluctantly accept dismissal without 
making a formal complaint. It appears that in such cases the employee manages to find a 
new job and hence decides not to proceed with their case, which would have been costly 
and  time  consuming.  Some  dismissal  cases  are  presented  to  the  relevant  trade  union, 
which may have an impact on the course of events and some end up in the pages of the 
newspapers without any conclusion before a court of law. 149 

Iceland has the highest share of parental leave taken by fathers among all Nordic countries 
(31 %).150 
On 16 April 2024, the  Government announced a new fiscal policy for  2025-2029 where 
there will be an ISK 8 billion increase in funding for the maternity/paternity leave fund. 
This decision comes in the wake of recent wage agreements where maximum payments 
from the fund go from ISK 600 000 to ISK 700 000 (EUR 4 000 to 4 800), starting on 1 
April 2024.151 There will be further increases of the maximum payments taking place in 
2025  and  2026.  The  first  increase  in  2024  applies  to  parents  of  children  born  before  1 
January 2025.  

147  No new statistics for 2023. 
148  See: Statistics Iceland (2023) https://hagstofa.is/utgafur/frettasafn/mannfjoldi/faedingar-2022/.  
149  Gretarsdóttir, S. (2016) ‘Right to protection from dismissal during pregnancy’, ML dissertation, 

https://skemman.is/bitstream/1946/25539/1/Lokaútgáfa%20til%20prentunar_pdf.pdf. 

150  See: International Social Security Association (2022), ‘Iceland wins international social security award’, 
press release, 28 October 2022, https://ww1.issa.int/news/iceland-wins-international-social-security-
award.  

151  Ministry of Social Affairs and Housing (2024) ‘Increase in contributions to the Maternity Leave Fund’, 16 

April 2024, https://www.stjornarradid.is/efst-a-baugi/frettir/stok-frett/2024/04/16/Haekkun-a-framlogum-
til-Faedingarorlofssjods-utvikkun-sorgarleyfis-og-adgerdir-til-ad-adstoda-folk-med-mismikla-starfsgetu-ut-
a-vinnumarkad/. 

59 

 
 
 
 
Country report – Gender equality – Iceland – 2025 

6 

Occupational social security schemes (Chapter 2 of Directive 2006/54) 

  General (legal) context 

The Icelandic pension system is based on three main pillars: the social security system, 
an occupational pension system and supplementary pension savings.  

The first pillar is a tax-financed public pension (minimal social security benefits) of which 
all  Icelanders  are  members,  with  the  primary  objective  of  providing  mutual  insurance, 
income equalisation and a social safety net for pension recipients. Social security includes 
pensions, health insurance and disability insurance.  

The  second  pillar  consists  of  mandatory  occupational  pension  funds,  which  are  the 
dominant  feature  of  the  pension  system 152  and  accounts  for  two  thirds  of  total  pension 
income. These are mainly industry-wide pension funds where membership is governed by 
labour contracts. Managers, specialists and the self-employed are free to choose pension 
funds (‘free pension funds’). These are regulated and fiscally stimulated by the authorities. 
Contributions are tax exempt up to a certain limit (percentage of wages).The fund system 
covers the whole working population and is based  on the mandatory  membership  of all 
employed  persons  from  16  to  70  years  of  age,  and  are  intended  to  provide  retirement 
pensions and mutual insurance. Supplementary pension savings are an optional route for 
saving for senior years. 

The Act on mandatory insurance of pension rights and on the activities of pension funds, 
otherwise known as the Pension Act No. 129/1997,153 was passed into law in 1997 (the 
basis of this  system goes back to 1969 when  employer’s associations and other parties 
involved in the labour market set out to adopt this system) and is intended to provide a 
comprehensive legal framework for all general pension funds. In the Pension Act the rights 
of  pension  fund  members  are  clearly  defined,  the  obligations  of  pension  funds,  both  as 
payers of pensions and investors, are spelled out and the transfer of members from one 
fund  to  another  is  facilitated  without  a  loss  of  accumulated  rights.  In  addition  to  the 
Pension Act, several pension funds – notably the Government Employees’ Pension Fund – 
are subject to special legislation, Act No. 1/1997.154 

The  Pension  Act  is  designed  to  protect  the  rights  of  individuals’  pensions,  even  if  they 
change jobs and membership of pension funds throughout their working lives. It  sets a 
framework for the operation of pension funds to provide for a pension fund system that is 
to carry the bulk of pension needs in Iceland. 

Both  employees  and  employers  are  required  to  pay  premiums  into  pension  funds: 
collectively a minimum of 15,5 % of the gross salary. The employee pays 4 %, deductible 
from  the  income  tax  base, 155  and  the  employer  provides  a  minimum  of  11,5 %.156  The 
employer’s  contribution  was  increased  by  3,5 %  in  three  steps  following  trade  union 

152  Total pension income: Pillar II - 67 %, Pillar I - 23 % and Pillar III -10 % (Information from the Icelandic 

Pension Fund Association: https://www.lifeyrismal.is/en), 
https://www.lifeyrismal.is/static/files/Fundargogn/2017pensions-in-iceland.pdf.  

153  Act on mandatory insurance of pension rights and on the activities of pension funds, (Lög um 

skyldutryggingu lífeyrisréttinda og starfsemi lífeyrissjóða, nr. 129/1997), 
https://www.althingi.is/altext/lagasofn/131b/1997129.html. English version on the site of the Government 
website: https://www.government.is/media/fjarmalaraduneyti-
media/media/laws_regulations/Act_no_129_1997.pdf.  

154  Lög um lífeyrissjóð starfsmanna ríkisins, nr. 1/1997, https://www.althingi.is/lagas/nuna/1997001.html. 
155  Income Tax Act no. 90/2203, Art. 30 (Lög um tekjuskatt, nr. 90/2003).  
156  The employer will pay 11.5 % from 1 January 2023. 

60 

 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

agreements between the Icelandic Confederation of Labour (ASI)157 and the Confederation 
of Icelandic Enterprise (SA)158 in 2016 until 2018.  

Furthermore,  employees  may  choose  to  make  additional  payments  of  up  to  4 %  into 
pension  funds.  If  employees  choose  to  make  the  additional  payments,  the  employer  is 
obliged to pay an additional 2 % premium to the pension funds for the benefit of these 
employees. 

Not all trade unions have reached agreement. Fishermen’s collective agreements with the 
Association of Companies in the Fisheries Sector have now been open for almost four years 
and the companies refuse to pay a higher contribution than 8 %. 

A  general  overview  of  the  Icelandic  pension  system  is  provided  in  a  publication  by  the 
National Pension Fund Association.159 

6.1.1  Issues related to gender equality and social security 

In  Iceland,  over  the  years,  women  have  accrued  comparatively  lower  occupation  and 
supplementary pensions, and their reliance on social security (the first pillar) has exceeded 
that of men. Despite the fact that the labour force participation of women is the highest 
among all OECD countries (75.1 %), women constitute a majority of those relying on old-
age pension from the social security system.  

Persistent  factors  such  as  the  gender  pay  gap,  uncompensated  domestic  labour,  and 
women’s  reduced  working  hours  in  paid  employment  have  perpetuated  gender-based 
labour market disparities throughout their later years. Statistics for 2022 strongly suggest 
that  there  is  an  unequal  distribution  of  child-rearing  responsibilities  between  men  and 
women:  there  were  10,838  single  mothers  responsible  for  the  care  of  16,337  children, 
while single fathers numbered 1,566, caring for 1,946 children.160 

The sharing of pension funds as per Article 13 of the Act No. 129/1997 is an improvement, 
in particular for women, as it provides for pension payments to surviving spouses that are 
paid in full for a minimum period of two years. If the surviving spouse has children she/he 
receives full pension until the youngest child attains the age of 18. Certain pension funds 
extend the duration of full spouse pensions, providing continued support until the end of 
the recipient’s life. When the recipient is disabled at the time of the spouse’s passing the 
and is below the age of 67, they are eligible to receive a full spouse pension for the duration 
of their disability. 

In cases where women are not receiving pension from an occupational pension fund the 
Social  Insurance  Administration  covers  the  gap.  The  current  old-age  pension  from  the 
Social  Insurance  Administration  (TR)  is  EUR 1 858  (ISK 278 271)  per  month.  Any 
occupational retirement pension amount received is deducted from the TR payments.  

157  The Icelandic Confederation of Labour (ASI) is built up of 46 trade unions of general workers, office and 

retail workers, seamen, construction and industrial workers, electrical workers and various other 
professions in the private sector and part of the public sector. These trade unions affiliate to 5 national 
federations which in turn are affiliate to ASI. In addition there are 7 national unions which directly 
affiliate to ASI. About 
 of organised labour in Iceland are members of trade unions which affiliate to ASÍ. 
The total number of members of ASÍ today is about 133.000; thereof 120 000 members are active on the 
labour market. The union density in Iceland is over 80%. The two largest trade unions in Iceland are VR 
with approx. 40 000 members and Efling-stéttarfélag with approx. 30 000 members, both of them are 
members of ASI. 

⅔

158  SA and its member associations include about 2 000 businesses. The organisation accounts for about 70% 
of all salaried employees on the Icelandic labour market. This wide representation puts SA in a strong 
position as the voice of Icelandic business. 

159  See: https://www.lifeyrismal.is/static/files/Fundargogn/2017pensions-in-iceland.pdf. 
160  See: 

https://px.hagstofa.is/pxis/pxweb/is/Ibuar/Ibuar__fjolsk__Fjolskyldan/MAN07108.px/table/tableViewLayou
t2/. 

61 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

6.1.2  Political and societal debate and pending legislative proposals 

There are no pending legislative proposals concerning the pension fund system, despite 
criticism of how the pension funds are operated. The occupational funds have been subject 
to constant criticism since the financial collapse in 2008 for their investment decisions in 
various private projects, etc.161 A further criticism is that the board of directors are not 
chosen by the funds’ members but appointed by the directors of the union of the relevant 
fund  (half  employers  and  half  representatives  of  the  employees),  whereas  there  is  a 
growing  demand  for  the  actual  members  of  the  fund  to  be  able  to  elect  the  board 
directly.162  Subsequently,  the  40 %  gender  quota  rule  cannot  be  viewed  as  sufficiently 
serving the democratic/egalitarian interest of the general fund members.  

  Direct and indirect discrimination 

No one may be refused membership of a pension fund for reasons of health, age, marital 
status, family size or gender, as stated in Article 2 of the Pension Act No. 129/1997. All 
employers  are  required  to  deduct  pension  contributions  from  their  employees’  wages 
(4 %) and submit them to the relevant pension funds together with their corresponding 
contributions of 8 %. In addition, an employee can pay 2 % into a private pension fund 
where the employer’s corresponding contribution would then be 2 %. 

Article 16 of the GEA prohibits all forms of discrimination, direct or indirect, on grounds of 
gender, albeit affirmative action is not seen as being contrary to the GEA if there are valid 
reasons behind a decision. Special considerations regarding women related to pregnancy 
and childbirth are not to be regarded as discrimination. 

The  arrangement  of  the  Icelandic  occupational  pension  fund  system  may  give  rise  to 
indirect  discrimination,  primarily  because  of  its  close  linkage  with  external  employment 
outside the home, even in the absence of overt discriminatory elements. 

Despite  long  standing  labour  force  participation  of  both  men  and  women163  and  low 
unemployment  rates,  there  are  elderly  women  who  still  grapple  with  the  enduring 
consequences of persistent gender discrimination from previous decades. Housework and 
the care of the elderly have consistently been unpaid work resulting in women not enjoying 
pensions that reflect their contributions in these areas. 

  Personal scope 

The personal scope specified in Directive 2006/54 is covered by the Act on working terms 
and  pension  rights  insurance,  No. 55/1980,  as  amended  by  Acts  No. 58/1985, 
No. 33/1987, No. 21/1991, No. 69/1993, No. 129/1997, No. 145/2004 and No. 76/2010.  

Chapter  I of  the  Pension  Act  No. 129/1997  provides  for  compulsory  pension  fund 
membership for all employed people. The mandatory insurance of pension rights means 
that everyone active in the labour market is obliged to belong to a pension fund and pay 
contributions  to  a  pension  fund  and,  as  appropriate,  to  other  parties  pursuant  to  an 
agreement  on  supplementary  insurance  benefits.  All  employees  and  employers  or  self-
employed  people  are  obliged  to  insure  their  pension  rights  through  membership  of  a 
pension fund between the ages of 16 and 70. Membership of a pension fund, the payment 
of pension contributions and the division of the contributions between the employee and 
employer respectively is set out in the collective bargaining agreement that determines 
the minimum terms of employment in the occupation concerned, or in a specific legal act, 
as appropriate.  

161  See: https://www.lifeyrismal.is/static/files/old/Bindi_1.pdf.  
162  See: https://web.archive.org/web/20220131121219/http://styrmir.is/entry.html?entry_id=2236805. 
163  See: https://hagstofa.is/utgafur/frettasafn/vinnumarkadur/vinnumarkadurinn-arid-2022/.  

62 

 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

Chapter II of the Act stipulates that all employed people aged 16 to 70 years may establish 
individual retirement contracts with banks or other financial institutions for supplementary 
pensions. The premiums may accumulate in a blocked account or be used to purchase an 
annuity life insurance. 

  Material scope 

Every employee has access to a pension fund and is obliged to contribute to it. Through 
contributions to acquire pension  rights in mutual pension funds, pension fund members 
obtain the right to an old-age pension, disability pension (following Article 7 of the Recast 
Directive) and spouse’s and children’s pensions, for themselves, their spouse and children, 
as appropriate, which may not be less extensive than provided for in Chapter III of the 
Pension Act.  

The recipients of unemployment benefits must pay 4 % of their benefits to an occupational 
pension fund and the unemployment fund pays the 11.5 % contribution of the employer. 

The  rules  on  pension  rights  are  defined  in  Chapter  III  of  the  Pension  Act,  where  all 
mandatory pensions go into a common pool in each pension fund, and the right to an old-
age  pension  may  start  at  the  age  of  60  and  will  be  lifelong.  The  minimum  rights  to 
disability,  spouse’s  and  children’s  benefits  are  also  defined.  Chapter  IV of  the  Act  deals 
with qualifications for pension funds. They must reach a critical minimum size, based on 
the number of pension fund members and their ability to provide a financial base for their 
commitments.  The  Act  incorporates  12  chapters  on  the  following  matters:  Chapter  I  – 
Compulsory  insurance,  contribution  and  insurance  protection;  Chapter  II  –  Pension 
savings; Chapter III – Pension rights in pension funds; Chapter IV – General conditions 
for  the  operation  of  a  pension  fund;  Chapter  V  –  Operating  licences  for  pension  funds; 
Chapter  VI  –  Function  and  internal  surveillance;  and  Chapter  VII  –  Pension  fund 
investment policy. 

The  minimum  pension  premium  is  15,5 %  of  wages,  with  the  wage  earner  always 
contributing  4 %  and  the  employer  11,5 %.  Membership  of  a  pension  fund  may  be 
determined  in  a  collective  bargaining  agreement,  by  special  legislation  or  through  an 
employment contract. Along with compulsory membership, a minimum benefit right is also 
defined.  Individuals  are  accorded  the  right  to  establish  individual  retirement  accounts, 
either with the pension fund where they pay the compulsory minimum premium or with 
any other qualified financial institution. 

  Exclusions 

The exclusions in the Recast Directives Article 8 are not relevant in the case of Iceland. 

  Laws  and  case  law  falling  under  the  examples  of  sex  discrimination 

mentioned in Article 9 of Directive 2006/54 

Case law in the last two decades concerning the division of pension funds when terminating 
the  settlement  of  assets  and  liabilities  in  legal  separation  is  inconsistent.  The  gender 
inequality is reflected in the fact that in all these cases the women are claiming a share in 
their husband’s pension rights. 

The  question  whether  the  pension  fund  of  a  spouse  should  be  considered  matrimonial 
property in accordance with Article 54 of the Marriage Act No. 31/1993164 was contested 
in case No. 170/2002.165 In this case the woman claiming a share of her husband’s pension 

164  See: https://www.government.is/library/04-

Legislation/Law%20in%20Respect%20of%20Marriage%20No%2031%201993_English%20translation.pdf.  

165  Supreme Court judgment 26 April 2002. 

63 

 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

had been a homeworker, taking care of their children during their 15 years of marriage 
(18  years  of  living  together)  and  hence  had  no  income  or  pension  rights  herself.  Her 
husband  was  in  a  highly  paid  job  with  considerable  pension  rights.  According  to 
Article 102(2) of the Marriage Act, the rights acquired in public or private pension funds, 
and  claims  for  pension  or  life  insurance  benefits  according  to  policies  which  have  no 
surrender  value  upon  the  request  of  one  or  both  spouses,  may  be  exempted  from  the 
settlement procedure.  

The Supreme Court held in this case that it was unfair to exempt the husband’s pension 
rights  from  their  settlement  and  that  she  deserved  her  share  of  these  rights.  In  its 
judgment  when  deciding  on  the  amount  to  be  paid  to  the  woman  the  Court  took  into 
account the fact that she got a tax-free lump sum and that her relatively young age of 44 
years would enable her to obtain her own pension rights. 

In 2012, in a similar case, the Supreme Court166 rejected the woman’s claim pointing out 
that the provision in Article 102(2) exempts pension funds from settlements in divorce and 
the only exception to this rule is when circumstances on the whole require deviating from 
the rule. In this case the woman had been active in the labour market and had obtained 
her own pension rights. The Court emphasised that the woman had many years to acquire 
enhanced pension rights and hence it had not been proven on her behalf that sticking to 
the principle in Article 102(2) was unfair. 

In the most recent case before the Court of Appeal on 15 September 2020,167 the court 
rejected the woman’s claim, stating that an exception to the rule in Article 102(2) of the 
Marriage  Act  could  not  be  justified  on  the  whole  as  she  had  opportunities  to  work  and 
enhance  her  own  pension  rights.  However,  the  Court  of  Appeal  accepted  a  part  of  her 
claim  concerning  the  man’s  supplementary  pension  rights  and  hence  has  created  legal 
uncertainty in this sphere. 

  Actuarial factors 

After  retirement  age  (67)  is  reached,  payments  are  in  proportion  to  the  employee’s 
contribution to the fund throughout the years. It takes on average 13.3 years to get back 
from the fund the amount of the total contribution of the employee. 

The employee pays 4 % of their wages to the relevant fund while the employer, according 
to the latest collective agreements, must pay 11,5 %.168 Exceptions are seamen, where 
the  trawler  industry  pays  8 %.  Self-employed  individuals,  according  to  the  law,  pay 
11,5 % as employers.169 

  Difficulties 

The Supreme Court held in a case before it in 2012 that the pension rights of a man in a 
divorce case did not fall into the category of ‘matrimonial property’ under the Marriage Act 
No. 31/1993.170  The  claimant  in  this  case  referred  to  Article 102(2)  of  the  Marriage  Act 
which states that pension rights should not be excluded from divorce settlements if this 
appears to be unreasonable. The couple in this case had been married for 35 years. His 
income  had  been  considerably  higher  than  hers  and  subsequently  he  was  expecting  a 
higher old-age pension, although there was no concrete calculation presented with regard 
to their expected pension.  

166  Supreme Court case No. 568/2012, judgment 17 September 2012. 
167  Court of Appeal, case No. 368/2020. 
168  As of 1 January 2023, this is 11.5 %. 
169  See: https://www.lifeyrismal.is/is/spurt-og-svarad/sjalfstaett-starfandi. There were 18 000 self-employed 

sole workers according to statistics from the Icelandic Revenue and Customs from 2016. 

170  Supreme Court case No. 568/2012. 

64 

 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

  Evaluation of implementation 

Despite the highest participation of women in the labour force among all OECD countries 
(75.1 %), women constitute the majority receiving social security benefits. There remains 
legal  uncertainty  regarding  the  Icelandic  courts’  case  law  on  a  woman’s  share  of  their 
husband’s occupational pension rights in divorce settlements. 

 Remaining issues 

There  are  no  remaining  issues  regarding  occupational  social  security  that  have  not 
discussed so far. 

65 

 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

7 

Statutory schemes of social security (Directive 79/7) 

The  statutory  social  security  system  in  Iceland  is  a  public  pension  system  of  which  all 
Icelanders are members, with the primary objective of providing mutual insurance, income 
equalisation  and  a  safety  net  for  pension  recipients.  Social  security  includes  pensions, 
health insurance and disability insurance, social assistance and unemployment. 

The State Social Security Institute handles basic disability and retirement pensions under 
the Social  Security  Act,  No. 100/2007.  It  is  also  responsible  for  social  assistance  and 
related entitlements provided for in the Social Assistance Act, No. 99/2007. 

Icelandic  Health  Insurance is  responsible  for  the  implementation  of  the Act  on  Health 
Insurance,  No. 112/2008,  the  Act  on  Social  Security  Occupational  Injury  Insurance, 
No. 45/2015, and the Act on Patient Insurance, No. 111/2000. 

The  national  acts  that  contain  provisions  on  statutory  social  security  schemes  are  the 
Social Security Act No. 100/2007; the Health Insurance Act, No. 112/2008,171 the Act on 
social security occupational injury insurance, No. 45/2015, and the Patient Insurance Act, 
No. 111/2000. 

The State Social Insurance Administration (TR) 172 handles basic disability and retirement 
pensions  under  the Social  Security  Act,  No. 100/2007.  It  is  also  responsible  for  social 
assistance  and  related  entitlements,  such  as  single  parent’s  allowance,  child  pension  in 
connection with school studies or vocational training of young people aged 18‒20, home-
care  allowance,  spouse’s  benefit,  home-care  allowance,  death  grant,  rehabilitation 
pension,  household  supplement,  additional  supplements  etc.  provided  for  in  the Social 
Assistance Act, No. 99/2007. 

The  public  minimum  pension  system  is  based  on  a  tax-financed  public  pension  (social 
security benefits). The social security system applies to those with low or no second pillar 
pension. It is organised by the authorities. Each year of residence is equal to one fortieth 
of  the  full  basic  amount  (income-tested  and  inflation-protected)  after  40  years.  Three 
years of residence is the basic requirement for access to social security.  

The old-age pension was raised by 4.6 % from 1 January 2022 and disability pension was 
raised by 5.6 % from the same date. The basic amount of old-age pension per person per 
month  (2022)  is  ISK 278 271173  (EUR 1 858).  All  other  income  reduces  social  security 
pensions by 45 % (although the first EUR 203/ISK 25 000 is exempt).174 

Persons  between  the  ages  of  18  and  67  years  can  apply  to  the  Social  Insurance 
Administration  (TR)  for  disability  assessment  where  capability  is  assessed  after  illness, 
accident, or disability. It is a condition that rehabilitation has been  exhausted  or that a 
doctor  confirms  that  rehabilitation  does  not  apply.  Individuals’  entitlement  is  based  on 
their residence in Iceland from 16-67 years of age. The person must have lived in Iceland 
for at least the three years preceding their application. The same applies to residence in 
another  Nordic  country  under  the  Nordic  countries’  agreement  on  social  insurance.  The 
person must have been resident in Iceland for at least one year after age 16. Full payment 
is based on 40 years of residence in Iceland. 

A rehabilitation pension is provided for persons who are unable to work due to illness or 
injury and are undergoing rehabilitation with the aim of returning to the labour market. 

171  See: https://www.government.is/media/velferdarraduneyti-media/media/acrobat-enskar_sidur/Act-on-

Health-Insurance-No-112-2008-16.pdf.  

172  The State Social Security Institute (Tryggingastofnun TR): https://www.tr.is/en/. 
173  See: https://www.leb.is/fjarhaedir-lifeyrisgreidslna-og-breytingar-1-januar-2022/. 
174  See: https://www.leb.is/fjarhaedir-lifeyrisgreidslna-og-breytingar-1-januar-2022/; 

https://island.is/en/o/social-insurance-administration/retirement-pension-amounts#income-limit. 

66 

 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

The  Social  Insurance  Administration  provides  various  assistance  regarding  children. 
Entitlements  can  be,  for  example,  for  chronically  ill  or  disabled  children,  child  support, 
parental payments, home-care allowance and child pensions. 

Iceland Health 175 covers part or all of the cost of those insured for healthcare. The objective 
of the Health Insurance Act is to ensure assistance to protect health and equal access to 
health services irrespective of economic situation. 

Unemployment  benefits  are  paid  by  the  Directorate  of  Labour  for  the  whole  of  Iceland. 
The  recipient  of  unemployment  benefits  pays a minimum  of  4 %  of  the  unemployment 
benefits into a pension fund. The unemployment insurance fund pays an 8 % contribution 
in 2022. 

  General (legal) context 

7.1.1  Overview of national acts 

injury 

insurance  and  social  security  occupational 

The  Social  Security  Act  No. 100/2007, 176  with  later  amendments,  covers  social  security 
pension 
insurance.  Under 
Act No. 100/2007  any  person  who  is  resident  in  Iceland  is  regarded  as  being  insured 
providing that  other conditions of the Act are  met, unless  other provisions are made in 
international agreements. Residence, for the purpose of the first paragraph,  refers to a 
legal  domicile  in  the  sense  of  the  Legal  Domicile  Act.177  In  order  to  enjoy  full  benefits, 
individuals must have lived in the country for at least 40 years between the ages of 16 
and 67 (i.e. a minimum of 40 out of 52 years). The right to partial benefits is gained after 
residency  for  at  least  3  calendar  years  and  is  calculated  pro  rata  from  3  to  40  years. 
Pension  insurance  includes  old-age  pensions,  disability  pensions,  age-related  disability 
supplements, pension supplements, disability allowances and child pensions, as provided 
by Article 16 of the Social Security Act.  

The  Unemployment  Insurance  Act  No. 54/2006  provides  for  unemployment  insurance 
covering  wage  earners  and  self-employed  individuals  on  the  domestic  labour  market  in 
the  event  of  their  becoming  unemployed.  Unemployment  benefits  are  paid  from  the 
unemployment  insurance  fund,  which  is  financed  by  the  employment  insurance  tax  (cf. 
the Social Security Tax Act) and interest on the balance held in the fund (per Article 5 of 
Act No. 54/2006, which also stipulates that the accounts of the unemployment insurance 
fund  shall  according  to  Article 5  be  audited  by  the  Auditor-General  and  that  the  fund’s 
operating expenses shall be met from its income. 

The Directorate of Labour manages the assets of the unemployment insurance fund and 
is in charge of the application of the Act on the basis of a service agreement made with 
the board of the unemployment insurance fund.  

Social security in relation to health is covered by the Health Insurance Act, No. 112/2008 
(HIA).  The  aim  of  the  Health  Insurance  Act  is  to  ensure  assistance  to  health  insured 
persons for the protection of their health and equal access to health service, irrespective 
of  financial  position,  as  further  provided  in  the  Act  and  in  accordance  with  the  Health 
Service Act, the Patients’ Rights Act and  other legislation (HIA, Article 1). Furthermore, 

175  Iceland Health (Sjúkratryggingar Íslands SÍ): https://island.is/en/o/icelandic-health-insurance. 
176  The Social Security Act, No. 100/2007, as amended by Act No. 105/2007, No. 160/2007, No. 17/2008, 
No. 57/2008, No. 112/2008, No. 155/2008, No. 173/2008, No. 55/2009, No. 70/2009, No. 97/2009, 
No. 120/2009, No. 136/2009, No. 65/2010, No. 162/2010, No. 164/2010, No. 51/2011, No. 106/2011, 
No. 126/2011, No. 178/2011, No. 28/2012, No. 134/2012, No. 86/2013, No. 107/2013, No. 140/2013, 
No. 8/2014, No. 137/2014, No. 88/2015, No. 125/2015, No. 130/2015, No. 107/2016, No. 116/2016, 
No. 126/2016, No. 9/2017 and No. 96/2017, available at: https://www.government.is/library/04-
Legislation/Social%20Security%20Act%20100%202007%20with%20subsequent%20amendments%20May
%202018.pdf.  

177  Legal Domicile Act (Lög um lögheimili og aðsetur) No. 80/2018. 

67 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

the objective of the Act is to promote the efficiency and economic viability of the health 
service and maximise its quality to the extent possible at any time. The Act is also intended 
to strengthen the role of the state as a buyer of health services and to analyse the cost of 
the health service.  

7.1.2  Political and societal debate and pending legislative proposals 

The  on-going  general  debate  concerns  the  criticism  directed  at  the  social  security 
payments  after  retirement  –  the  fact  that  they  are  linked  and  reduced  with  regard  to 
payments from the occupational pension fund. Furthermore, there is criticism of the fact 
that these social security payments are  cut if individuals continue with small tasks with 
some  extra  pay.  The  opposing  view  is  that  the  social  security  scheme  is  meant  to 
guarantee  payments  to  those  in  need,  as  this  is  public  money,  instead  of  being  an 
additional bonus in old age. 

  Implementation of the principle of equal treatment for men and women in 

matters of social security 

There are no derived benefits. The determination of the pensionable age is the same for 
both sexes: 67 years. 

Article 2(10) of the GEA No. 150/2020 defines terms such as pay, pension rights, holiday 
rights and entitlement to pay in the event of illness and all other terms of employment or 
entitlements  that  can  be  evaluated  in  monetary  terms.  Article 6  of  the  GEA  prohibits 
discrimination regarding such terms on grounds of gender. 

  Personal scope 

The  personal  scope  of  the  national  law  relating  to  statutory  social  security  schemes  is 
broader  than  specified  in  Article 2  of  Directive 79/7  as  it  applies  not  only  to  the  whole 
working population but to all those who are resident in Iceland and thus regarded as being 
insured (although under Article 29, persons who are not covered by health insurance in 
Iceland pursuant to the Act must pay a fee corresponding to the cost of the health services 
provided in accordance with regulations), giving equal access to social security and health 
service irrespective of financial position. Residence refers to a legal domicile in the sense 
of the Legal Domicile Act. Any person who stays in Iceland for a period of six months or 
more is required to be domiciled here. A citizen of an EEA country may stay and work in 
Iceland without a permit for up to three months from their arrival in the country, or stay 
for up to six months if they are seeking employment.  

  Material scope 

The material scope of national law relating to statutory social security schemes covers all 
the  areas  listed  in  Article 3(1)  and  (2)  of  Directive 79/7:  sickness,  invalidity,  old  age, 
accidents at work and occupational diseases, unemployment and social assistance. 

  Exclusions 

There are no derived benefits. The determination of the pensionable age is the same for 
both sexes. 

  Actuarial factors 

Sex is not an actuarial factor in statutory social security schemes.  

68 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

  Difficulties 

No specific difficulties. 

  Evaluation of implementation 

The national law that implements the EU law is satisfactory. As the focus here is on gender 
equality there are no more issues to report.  

  Remaining issues 

The social security system compensates for low pension income; however, first-generation 
immigrants will probably lack contribution years in the private pension fund system, which 
will curtail their rights in comparison with others. In order to enjoy full benefits, individuals 
must have lived in the country for at least 40 years between the ages of 16 and 67 (i.e. a 
minimum of 40  out of  52 years). The minimum age  for  receiving  old age pension is 67 
years. The right to partial benefits is gained after residency for at least 3 calendar years 
and is calculated pro rata from 3 to 40 years. 

A study illustrates a marked difference in pension income by gender, with men receiving 
24 %  higher  income,  on  average,  than  women.  The  difference  is  more  or  less  constant 
across all age groups. 178  

In 2022 there were 43 000 pensioners in Iceland. Women constitute a majority of those 
receiving old age pension, disability and rehabilitation payments from the Social Insurance 
Administration. Out of 81 000 beneficiaries, 49 000 are women. 179 

Recent surveys show that despite the fact that, on average, women live longer than men, 
their general health is worse; they are more frequent visitors to healthcare centres and 
take  more  medication  than  men.  The  poorer  health  of  women  is  also  evident  from 
increased  disability  among  women:  60 %  of  those  who  measure  as  75 %  disabled  are 
women.  Women  are 
linked  to  the 
musculoskeletal system and the growing number of invalidity pensioners amongst women 
who are 50 or older indicates that the causes are external and social. 180 

increasingly  disabled  because  of  diseases 

178  Financial Supervisory Authority (2014) Retirement savings adequacy. Measurement in Iceland, available at: 

https://en.fme.is/media/news/Retirement-Savings-Adequacy---Iceland.pdf. 

179  Social Insurance Administration (2023) Annual Report 2022, available at: 

https://assets.ctfassets.net/8k0h54kbe6bj/6tFGinbRPXzjBXlEus9sum/89b83fa580bfcf6484b41e69d61171b9
/arsskyrslatr2022.pdf. 

180  Directorate for Gender Equality (2021) Kortlagning kynjasjónarmiða Stöðuskýrsla 2021 (Mapping gender 

perspectives 2021). 

69 

 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

8 

Self-employed  workers  (Directive 2010/41/EU  and  some 
provisions of the Recast Directive) 

relevant 

Self-employed  workers  are  legally  mandated  to  make  a  pension  fund  contribution  of 
15.5 %,  which  is  composed  of  a  4 %  contribution  as  an  employee  and  an  11.5 % 
contribution equivalent to that of an employer.181 

A self-employed individual must declare as employment income an amount comparable to 
the  remuneration  they  would  receive  if  similarly  employed  by  an  unrelated  person 
(presumptive  employment  income).182  The  same  applies  if  an  individual  works  for  a 
partnership  in  which  they  participate  directly  or  indirectly  as  an  owner.  If  a  spouse  or 
children of a self-employed person are employed in the business, their remuneration must 
be calculated.183  

An amount equal to the individual’s own presumptive employment income, or to that of 
their spouse or children, is deductible as operating expenses from the income of the private 
or partnership business. If the self-employed worker declares an income much lower than 
their presumptive employment income, i.e. the income they would be earning if employed 
by an unrelated person, their pension savings are accordingly reduced. Each January, the 
Ministry of Finance publishes rules about ‘reference incomes’ for self-employed individuals 
and independent activities. 184  

Anyone (both employees and the self-employed) who is aged 16 or older during the income 
year is entitled to a personal tax credit of EUR 411.42 (ISK 53 916) per month (2022) 185 
to reduce the tax deducted from their wages. The same applies to other income, such as 
pension, benefits, etc. where unused credit may be transferred to an individual’s spouse.  
Self-employed  individuals  are  required  to  contribute  a  minimum  of  4 %  of  their  total 
income to a certified pension fund. Since self-employed individuals are both the employer 
and employee, they are responsible for the employer’s share of the contribution, which is 
11.5 %  of  their  total  income.  So,  the  total  contribution  for  self-employed  individuals  in 
Iceland  is  15.5 %  of  their  income.  Taxable  income  includes  all  income  from  past  and 
present employment, businesses and professions, and capital. All income received by the 
taxpayer  in  money  or  in  kind  is  subject  to  tax,  unless  it  is  exempt.  The  collection  of 
individual income taxes (state and municipal) on employment income takes place at source 
each month during the income year.186 

  Implementation of Directive 2010/41/EU 

Directive 2010/41/EU  on  equal  treatment  between  men  and  women  engaged  in  a  self-
employed capacity has been fully implemented with the following legislation: 

- 

Act No. 150/2020 on equal status and equal rights of women and men; 187 

181  Self-employed workers are legally mandated to make a pension fund contribution of 15,5 %, which is 
composed of a 4 % contribution as an employee and an 11,5 % contribution equivalent to that of an 
employer. 

182  Published on the homepage of the Directorate for Internal Revenue: 

https://www.rsk.is/atvinnurekstur/stadgreidsla-og-reiknad-endurgjald/reiknad-endurgjald/2019/#tab2. 

183  See: https://island.is/en/self-employed. 
184  Directorate of Internal Revenue (2022) Reiknað endurgjald 2022 (Presumptive income 2022), available in 

Icelandic at: https://www.skatturinn.is/atvinnurekstur/stadgreidsla-og-reiknad-endurgjald/reiknad-
endurgjald/2022/#. 

185  See: https://www.skatturinn.is/einstaklingar/stadgreidsla/personuafslattur/#tab2.  
186  See: https://www.rsk.is/english/individuals/taxable-income/. 
187  The Gender Equality Act No. 10/2008 already gave effect to Directive 2006/54/EC of the European 

Parliament and of the Council of 5 July 2006 on the implementation of the principle of equal opportunities 
and equal treatment of men and women in matters of employment and occupation, to which reference is 
made in Annex XVIII of the Agreement on the European Economic Area as amended by the Decision of the 
EEA Joint Committee No. 33/2008. In addition, this Act gives effect to Directive 2010/41/EU of the 
European Parliament and of the Council of 7 July 2010 on the application of the principle of equal treatment 

70 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

- 
- 

Social Security Act No. 100/2007; and 
MPLPL Act No. 144/2020 on maternity/paternity leave and parental leave. 

  Personal scope 

8.2.1  Scope 

While employees are covered by labour law and the protection it affords, the self-employed 
are, in principle, covered (only) by the provisions of general civil law, as there is no actual 
employment  relationship  based  on  a  contract.  However,  self-employed  workers  enjoy 
protection as parents just like other parents, as evident from Article 1 covering the scope 
of the MPLPL, which applies to parents who are employed by others or are self-employed. 

8.2.2  Definitions 

The  Unemployment  Insurance  Act,  No. 54/2006,188  Article 3(b)  defines  a  self-employed 
individual as any person who works in their own business or independent activity to the 
extent that they are obliged to pay tax deductions at source in respect of calculated wages 
and social insurance tax in respect of their work, either every month or in another regular 
manner  according  to  rules  set  by  the  Director  of  Internal  Revenue  on  calculated 
remuneration. 

8.2.3  Categorisation and coverage  

Not all self-employed workers are considered to be part of the same category with regard 
to unemployment. There is a special unemployment fund for benefit payments to farmers, 
small fishing-vessel owners and lorry drivers.189 Other self-employed individuals, just like 
wage earners, are entitled to apply to the Directorate of Labour for unemployed benefit if 
they  become  unemployed.  Self-employed  persons  who  run  their  operation  through  a 
private limited company and have paid the social insurance tax (6.35 % in 2022) on their 
employee’s wages and their own wages, can apply for unemployment benefits. 

8.2.4  Recognition of life partners 

Under the Unemployment Insurance Act No. 54/2006, cohabiting partners, 190 if registered, 
are covered like spouses. Under the Social Security Act No. 100/2007 (see Article 49), two 
unmarried individuals have the same rights to benefits as couples if registered in Registers 
Iceland, providing that they have a child together or are expecting a child together or have 
been cohabitating together consecutively for more than one year. The same applies to the 
benefit  entitlements  of  an  individual  who  survives  their  spouse.  This  provision  was 
amended  subsequent  to  amendments  to  the  Marriage  Act,  No. 31/1993  with  law 
No. 65/2010 where the term ‘two individuals’ replaced ‘a man and a woman’. 

With regard to tax rules, cohabiting same-sex partners may request to be taxed together, 
in the same way as married couples and cohabiting couples of the opposite sex, who have 
registered their cohabitation, who have lived together for at least one year or have or are 
expecting a child together (Act No. 90/2003 on income tax). Furthermore, a rule providing 
for a tax-free personal allowance that is transferable between spouses has been extended 
so  that  it  is  also  transferable  between  cohabiting  partners  (Act  No. 45/1987  on  the 
settlement of taxes). 

between men and women engaged in an activity in a self-employed capacity and repealing Council 
Directive 86/613/EEC, to which reference is made in Annex XVIII of the Agreement on the European 
Economic Area as amended by the Decision of the EEA Joint Committee No. 84/2011. 

188  Unemployment Insurance Act (Lög um atvinnuleysistryggingarsjóð nr. 54/2006).  
189  Unemployment Insurance Act No. 54/2006, Article 7. 
190  People who live together, have the same legal domicile (address), are not married and have informed 
Registers Iceland about their marital status, can register their cohabitation in the population registry. 

71 

 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

  Material scope 

8.3.1  Implementation of Article 4 of Directive 2010/41/EU 

Article 1 of the Gender Equality Act No. 150/2020 provides:  

‘All  individuals  shall  have  equal  opportunities  to  benefit  from  their  own  enterprise 
and to develop their skills irrespective of their sex. With sex the law refers to women, 
men and people registered as gender neutral in the national register’.  

The act states that this aim will be reached, amongst other means as stated in 1(c), by 
specifically improving the position of women and increasing their opportunities in society.  

8.3.2  Material scope 

The material scope  covers the same issues as in Article 4 of Directive 2010/41/EU. The 
self-employed are not excluded from protection as regards equal treatment, although their 
workplace conditions are different from those who are employed by others. 

  Positive action 

Politicians tend to talk about creating job opportunities for people. Such voices grew louder 
during  the  lockdown  in  2020,  which  was  particularly  difficult  for  tourism,  a  growing 
industry in Iceland. Part of this industry is renting out parts of one’s home, like the Airbnb 
system, which has undoubtedly created opportunities for individuals, not least women, to 
earn an income as self-employed (although there are no official statistics to support that 
yet).  A  law  was  passed  in  2016191  setting  specific  limits  for  renting  out  property  (for 
example, through Airbnb), with stiff penalties for breaking them. The new law has made 
it very difficult for small entrepreneurs to rent  out their property (the  proportion  of the 
population living in their own housing in Iceland is around 70 %)192 through agencies like 
Airbnb.193 Self-employed hosts who were previously able to rent out part of their housing 
or their property on a short-term basis are now faced with limits of renting out for no more 
than 90 days per year and never for more than EUR 13 600 (ISK 2 million) per year. This 
measure  is  questionable  considering  the  constitutional  right  to  peaceful  enjoyment  of 
property, right to work and right to privacy of home and family. 194 

  Social protection 

The  whole  population  in  Iceland  is  covered  by  the  national  social  security  scheme.  The 
whole working population is covered by the Pension Fund Act No. 129/1997.  

Each self-employed individual (including those who do not have any other employees apart 
from themselves) must pay a social security contribution (in 2022, 6.35 % of their own 
total wages and that of their employees).195 

191  Act No. 67/2016 amending Act No. 85/2007 (lög um veitingastaði, gististaði og skemmtanahald, nr. 

85/2007 sbr. breytingu á þeim lögum með lögum nr. 67/2016); Regulation 1277/2016. 

192  See: https://hms-web.cdn.prismic.io/hms-web/e5d878d5-d63e-4aa3-8af5-cb0a072594c0_stadan-a-

leigumarkadi-2020.pdf.  

193  Mody, M. and Gomez, M. (2018) ‘Airbnb and the Hotel Industry: The past, present, and future of sales, 

marketing, branding, and revenue management’, Boston Hospitality Review, Autumn 2018, 
https://www.bu.edu/bhr/2018/10/31/airbnb-and-the-hotel-industry-the-past-present-and-future-of-sales-
marketing-branding-and-revenue-management/. 

194  For further information: https://grapevine.is/news/2018/06/11/icelands-parliament-to-begin-cracking-

down-on-airbnb/. 

195  Iceland Revenue and Customs (2022) Insurance fee, https://www.skatturinn.is/atvinnurekstur/skattar-og-

gjold/tryggingagjald/. 

72 

 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

Under  the  Social  Security  Act  No. 100/2007,  any  person  who  is  resident  in  Iceland  is 
regarded as being insured, provided that other conditions of the Act are met. Residence 
refers  to  legal  domicile  in  the  Legal  Domicile  Act.  Pension  insurance  includes  old-age 
pensions,  disability  pensions,  age-related  disability  supplements,  pension  supplements, 
disability allowances and child pensions.196 

Two unmarried individuals have the same rights to benefits as couples if their cohabitation 
is registered in Registers Iceland, a special institution which is part of the Ministry of the 
Interior,197 providing that they have a child together or are expecting a child together or 
have been cohabitating together consecutively for more than one year. The same applies 
to  the  benefit  entitlements  of  an  individual  who  survives  their  spouse.  Confirmed 
cohabitation (same-sex couples) has the same legal effect as a marriage with regard to 
social security, social care and insurance, housing and healthcare. 

  Maternity benefits 

The MPLPL Act No. 144/2020 applies to self-employed parents as well as those employed 
by others. The Act defines a ‘self-employed’ parent as referring to a parent who works at 
least 25 % of every month for themselves, irrespective of the type of company, of which 
they own at least 25 %, to the effect that it is mandatory for them to pay an insurance 
levy every month, or in another manner decided by the tax authorities (Article 4(3)).198  

The maternity/paternity leave fund is financed through the collection of an insurance levy 
in addition to interest on the fund’s deposits. 199 

The  maternity/paternity  leave  fund  (the  fund)  makes  payments  to  parents  who  have 
entitlements to payments during maternity/paternity leave. Each parent, including a self-
employed parent, is entitled to leave for up to six months due to a birth, primary adoption 
or reception of a child into permanent foster care. Like any other parent, the self-employed 
parent  may  assign  six  weeks  of  their  independent  entitlement  to  the  other  parent.  In 
addition,  parents  have  a  joint  entitlement  to  an  additional  three  months,  which  either 
parent may use in its entirety or may be divided between them. Parents acquire the right 
to payments from the fund after they have been active in the domestic labour market for 
six consecutive months prior to the birth of a child or the date on which a child enters the 
home in the case of adoption or permanent foster care. The work contribution of a self-
employed  parent  is  based  on  the  payment  of  the  insurance  levy  on  calculated 
remuneration  for  the  same  period.  The  monthly  payment  amounts  to  80 %  of  the  self-
employed  worker’s  average  total  wages  during  the  reference  period.  The  maximum 
payment per month in 2020 was EUR 4 085 (ISK 600 000). 

Maternity allowance is granted on a mandatory basis to parents working in the domestic 
labour market, employed by others or self-employed. The maternity/paternity leave fund 
makes the payments to parents who are entitled to it. The fund is financed through the 
collection  of  an  insurance  levy  and  the  Minister  of  Welfare  ensures  that  the  fund  has 
sufficient funds at all times to meet its obligations.  

There are various recruitment agencies from which anyone can seek assistance, but always 
on their own initiative, or they can seek assistance from the municipalities. The Directorate 
of  Labour  has  eight  service  centres  in  various  parts  of  the  country  to  provide 
information and advise on payments from the maternity/paternity leave fund, etc.200 

196  Act No. 100/2007, Article 16. 
197  Þjóðskrá Íslands, Registers Iceland: https://www.skra.is/english/.  
198  See Act No. 45/1987 on the withholding of public levies at source. 
199  Insurance Levy Act No. 113/1990.  
200  See: https://vinnumalastofnun.is/um-okkur/thjonustuskrifstofur and 
https://www.vinnumalastofnun.is/en/maternitypaternity-leave-fund.  

73 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

  Occupational social security 

The Act on Mandatory Occupational Pension Funds No. 129/1997 (Pension Act) applies. 

8.7.1  Implementation of provisions regarding occupational social security 

The Act on Mandatory Occupational Pension Funds No. 129/1997 (Pension Act) requires 
that all employees and  self-employed workers  between the ages  of 16 and 70 must be 
members  of  an  approved  pension  fund.  The  mandatory  contribution  is  currently  a 
minimum  of  12 %  of  total  earnings  (all  types  of  taxable  wages).  If  the  self-employed 
person is using their own identification number, they pay the whole 12 % and the same 
applies  if  they  are  working  as  a  contractor.  If  the  self-employed  person  has  a  private 
limited company then they pay 4 % as an employee and the company pays 8 %. If there 
is  a  supplement  payment  then  the  self-employed  employee’s  share  is  2-4 %  and  the 
private limited company’s share is 2 %. In addition, it is mandatory to pay 0.10 % to a 
vocational rehabilitation fund. 

A  business  operator  or  self-employed  person,  as  well  as  others  who  make  payments 
subject to contributions, must, upon the conclusion of the revenue year, specify on their 
wage payment slips, or by other means prescribed by the Directorate of Internal Revenue, 
the amount upon which each person’s contributions were based, together with the total 
amount of contributions paid to a pension fund. 

The contribution can be split into two parts. The first part ensures a minimum benefit for 
the member. This minimum provides the individual who has paid for 40 years a lifelong 
old-age pension every month amounting to at least 56 % of the monthly wages from which 
the  contribution  was  paid.  Furthermore,  it  ensures  a  minimum  disability  and  survivor’s 
pension, which are defined in the Act. The second part can go  either  towards acquiring 
additional pension rights in a pension fund or into individual pension plans (accounts). The 
funds define the minimum benefit. For example, one fund might define it so that all of the 
12 % contribution goes to cover minimum benefits, while another might only need 10 % 
for  the  minimum  and  then  the  extra  2 %  can  be  saved  elsewhere.  Banks,  insurance 
companies,  securities  undertakings  and  pension  funds  can  receive  contributions  for 
supplementary insurance benefits. 

According  to  Act  No. 113/1990,  all  employers  are  required  to  pay  a  social  security 
contribution based on the total wages/salaries they pay to their employees or, in the case 
of  the  self-employed,  based  on  their  own  presumptive  employment  income.  This 
contribution is a wage-related tax. The contribution for 2022 is 6.35 % of wages paid. 201 
This social security contribution must be paid every month. 

8.7.2  Application  of  exceptions  for  self-employed  persons  regarding  matters  of 

occupational social security (Article 11 of Recast Directive 2006/54) 

None. 

  Prohibition of discrimination 

Prohibition of discrimination is firmly entrenched in the GEA No. 150/2020. Article 1 of the 
GEA  explicitly  states  that  ‘all  individuals  shall  have  equal  opportunities  to  benefit  from 
their own enterprise and to develop their skills irrespective of gender’. Article 1(c) states 
that the aim of the GEA is specifically to ‘improve the position of women and increase their 
opportunities  in  society’.  Article 24  of  the  GEA  is  a  general  prohibition  of  all  forms  of 
discrimination on grounds of gender. 

201  See: https://www.skatturinn.is/atvinnurekstur/skattar-og-gjold/tryggingagjald/.  

74 

 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

  Evaluation of implementation 

The  national  law  that  implements  the  EU  law  topics  discussed  in  this  chapter  appear 
satisfactory. 

 Remaining issues 

Being self-employed can be difficult when the going gets tough. However, no research has 
been conducted on the situation of self-employed women in Iceland, whether the gender 
pay  gap  is  larger  in  their  case  on  average  or  how  much  less  they  earn  than  their  male 
counterparts. It must be emphasised that many self-employed women run their operations 
through private limited companies and hence it is difficult to assess whether they are run 
by a man or woman. 

75 

 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

9 

Goods and services (Directive 2004/113) 202 

  General (legal) context 

Law  No. 79/2015203  amended  the  Gender  Equality  Act  No. 10/2008,204  with  a  new 
provision in Article 24(a). Article 17 of the new Gender Equality Act No. 150/2020, which 
entered into force on 6 January 2021, contains the same principle in an unamended text 205 
The Act gave effect to Directive 2004/113/EC of the Council, on implementing the principle 
of equal treatment between women and men regarding access to and supply of goods and 
services referred to in Annex XVIII to the EEA Agreement as amended by decisions of the 
EEA  Joint  Committee  No. 147/2009.  New  EU  legislation  with  possible  EEA  relevance  is 
scrutinised by the EEA EFTA States. For relevant acts, draft decisions incorporating them 
into the EEA Agreement are submitted by the EEA EFTA side to the EU for consideration. 
Formal  decisions  incorporating  the  acts  are  taken  by  the  EEA  Joint  Committee.  As  the 
decisions do not have direct effect in the EEA EFTA States, the acts must subsequently be 
implemented in national law. Currently, the EU and the EEA EFTA States share more than 
5 000 acts in force in the EEA. 

Article 17 of the Gender Equality Act No. 150/2020 provides: 

‘All forms of discrimination on grounds of sex, regarding access to or supply of goods 
as well as access to or granting services, is prohibited. This provision does not apply 
to access to or supply of goods on one hand or to access to or granting services on 
the other hand in the area of private and family life. Furthermore, this provision does 
not apply to matters concerning work on the labour market.  

All  forms  of  discrimination  on  grounds  of  sex,  when  deciding  premiums  or  when 
deciding amount of benefits due to insurance contract or under other related financial 
service, is prohibited. Costs related to pregnancy and maternity shall not result in 
differences in individuals’ premiums and benefits.  

If  a  likelihood  is  adduced  that  a  discrimination  under  this  provision  has  occurred, 
direct or indirect, the person believed to be the discriminator shall demonstrate that 
the  grounds  for  the  treatment  are  not  sex-based  unless  it  can  be  justified  by  a 
legitimate  aim  and  the  means  of  achieving  that  aim  are  appropriate  and 
necessary.’206 

9.1.1  Specific  problems  of  discrimination 

in 

the  online  environment/digital 

market/collaborative economy 

No surveys have been undertaken about potential difficulties linked to access and supply 
of services. There are no examples concerning specific problems of discrimination in the 
online environment or collaborative economy where there are many self-employed women 
(Airbnb hosts, for example). 

202  See e.g. Caracciolo di Torella, E. (2021) Directive 2004/113EC on Gender equality in goods and services – 

In search of the potential of a forgotten Directive, European network of legal experts in gender equality and 
non-discrimination, available at: https://www.equalitylaw.eu/downloads/5614-directive-2004-113-ec-on-
gender-equality-in-goods-and-services-in-search-of-the-potential-of-a-forgotten-directive-1-38-mb. 

203  Lög um breytingu á lögum um jafnan rétt og jafna stöðu kvenna og karla nr. 10/2008, með síðari 

breytingum (vörukaup, þjónusta), https://www.althingi.is/altext/stjt/2015.079.html. 

204  See: https://www.government.is/lisalib/getfile.aspx?itemid=90bec9b4-0275-11e8-9425-005056bc530c. 
205  The new Gender Equality Act No. 150/2020 entered into force on 6 January 2021 is available here: 

https://www.althingi.is/lagas/151a/2020150.html. The new Act has not yet been translated into English. 

206  Act No. 79/2015, Article 1. 

76 

 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

9.1.2  Political and societal debate 

The Directive has been subject to political discussions as evident from the writing of the 
former Government Minister of Health around the time of its transposition. It was pointed 
out  at  the  time  (2009)  that  the  Goods  and  Services  Directive had  been  a  controversial 
issue from the time of its adoption in 2004, in particular as regards labour law and even 
more so as regards public service, including the health sector where there was (and still 
is)  much  political  opposition  to  bringing  it  under  the  domain  of  the  market  forces.  The 
Norwegians had introduced  explicit terms regarding the above and Icelandic authorities 
intended to follow the same route.207 

As  recently  as  April  2020,  the  Prime  Minister’s  Office  issued  a  notice  that  any  legal 
amendments, in the field of natural resources, required by the transposition of the Goods 
and Services Directive would be postponed until it completely  clarified exactly what the 
legal obligations of Icelandic authorities are under the EEA Treaty.208 

  Prohibition of direct and indirect discrimination 

Article 17 of the GEA No. 150/2020 prohibits all forms of discrimination, hence both direct 
and indirect, regarding access to or supply of goods as well as access to or provision of 
services. If it is shown to be likely that discrimination under this provision has occurred, 
direct or indirect, the alleged discriminating party must demonstrate that the grounds for 
the treatment are not sex-based, unless it can be justified by a legitimate aim and the 
means of achieving that aim are appropriate and necessary (Article 17, paragraph 3 of the 
GEA). 

  Material scope 

Article 17 of the GEA on the prohibition against discrimination in relation to trade in goods 
and services states: 

‘All forms of discrimination on grounds of gender, regarding access to or supply of 
goods as well as access to or granting services, is prohibited. However, this provision 
does not apply to access to or supply of goods on one hand or to access to or granting 
services on the other hand in the area of private and family life. Furthermore, this 
provision does not apply to matters concerning work in the labour market.  

All  forms  of  discrimination  on  grounds  of  gender  when  determining  insurance 
premiums  or  when  deciding  the  amount  of  compensation  due  to  an  insurance 
contract or in relation to other related financial service, are prohibited. Costs related 
to  pregnancy  and  childbirth  shall  not  result  in  differences  in  individuals’  insurance 
premiums and compensations.  

If  a  likelihood  is  adduced  that  a  discrimination  under  this  provision  has  occurred, 
whether  direct  or  indirect,  the  person  believed  to  be  the  discriminator  shall 
demonstrate that the grounds for the treatment are not gender-based unless it can 
be justified in an objective manner with a legitimate aim in mind, and the means of 
achieving that aim are appropriate and necessary.’  

The  above  provision  also  applies  to  persons  registered  as  neutral  in  Registers  Iceland. 
Paragraph 1 of Article 17 is in accordance with Article 3(1) of Directive 2004/113 as it does 
not  apply  to  trade  within  the  family  or  private  sphere.  An  example  would  be  renting  a 
room  in  a  home  where  the  renter  lives.  Neither  does  the  provision  apply  to  insurance 

207  See: https://www.stjornarradid.is/efst-a-baugi/frettir/stok-frett/2009/05/26/Thjonustutilskipun-ESB-

Samthykkt-med-skyrum-fyrirvara/.  

208  See: https://viljinn.is/frettaveita/rokstuddar-efasemdir-um-ad-thjonustutilskipun-esb-eigi-vid-um-

raforkuframleidslu/.  

77 

 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

related to occupation on the labour market. An example would be the work responsibility 
insurance of various professions. 

Regarding Article 3, paragraph 3 of Directive 2004/113, the explanatory report to the GEA 
No. 150/2020  explains  that  the  prohibition  against  discrimination  within  educational 
institutions  as  well  as  advertising  within  the  media  or  in  the  public  sector  is  covered  in 
Articles 15, 21 and 22 of the GEA No. 150/2020. 

  Exceptions 

Article 37  of  the  Media  Act  No. 38/2011  prohibits  subliminal  techniques  in  audio-visual 
commercial communications that include or promote any discrimination based on gender, 
racial or ethnic origin, nationality, religion, belief, disability, age or sexual orientation. 

Article 22 of the new GEA No. 150/2020 provides that:  

‘advertisers and those who design or publish advertisements shall ensure that the 
advertisements are not belittling or disrespectful towards either sex and that they 
do  not  run  contrary  to  the  equal  status  and  equal  rights  of  the  genders.  Such 
advertisements may not be published in the media or any other public venue.’  

  Justification of differences in treatment  

An example mentioned in the explanatory report to Article 17 of the GEA No. 150/2020 
regarding a legitimate objective of providing a service to one sex and not the other are 
shelters for victims of gender-based violence. 

  Actuarial factors 

Article 17 of GEA No. 150/2020 states in paragraph 2 that any discrimination on the basis 
of sex regarding the calculation of premiums and benefits for the purposes of insurance 
and related financial services is prohibited. 

  Interpretation of exception contained in Article 5(2) of Directive 2004/113 

This exception is not relevant. 

  Positive action measures (Article 6 of Directive 2004/113) 

There are none in particular. 

  Specific problems related to pregnancy, maternity or parenthood 

No. 

 Evaluation of implementation 

There has been no evaluation of the implementation so far. 

 Remaining issues 

There are no remaining issues at present. 

78 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

10  Violence  against  women  and domestic violence  in  relation to  the Istanbul 
Convention  and  the  Violence  Against  Women  Directive  (Directive  (EU) 
2024/1385)209 

Iceland ratified the Council of Europe Convention on Preventing and Combating Violence 
against  Women  and  Domestic  Violence  (hereafter  the  Istanbul  Convention)  on  26  April 
2018 and the Convention entered into force on 1 of August of the same year. 

 General (legal) context with regard to the obligation set out by the Istanbul 
Convention 

10.1.1 Surveys and reports on issues of violence against women and domestic violence 

During  the  lockdown,  domestic  violence  increased  by  10 %  according  to  the  National 
Commissioner’s  Office.  Reports  to  the  child  protection  authorities  also  increased  during 
this  time  with  more  children  contacting  the  authorities  with  complaints  about  their 
detrimental situation.210 Two women died in their homes during the lockdown.211 A man 
who later was convicted for killing his wife was initially not a suspect until a post-mortem 
dissection revealed that the woman had died from strangulation.212 

The  National  Commissioner’s  Office  has  embarked  on  publishing  quarterly  reports  on 
sexual  violence  in  the  whole  country,  covering  both  sexual  and  domestic  violence, 
including  manslaughter  and  attempts  to  kill.  In  2023  there  were  1 131  incidents  of 
domestic violence reported to the police.213 There were 184 rape notifications to the police 
in 2023, of which 121 had occurred that year. This represents a 13 % decrease in rape 
notifications in 2023 compared to the previous three years.214 In 2024, 25 % of domestic 
violence cases occurred in the countryside and 75 % in the capital area where 64 % of the 
population  lives;  64  %  of  these  cases  occurred  between  current  or  former  spouses  or 
partners. This was a 2 % increase from previous years.215 

According  to  the  director  of  the  Women’s  Shelter,  Linda  Dröfn  Gunnarsdóttir,  domestic 
violence  does  not  appear  to  be  taken  as  seriously  as  it  should  be  given  the  risk  of  its 
escalation to the point where violent behaviour can be lethal. Victims of domestic violence 
are  rarely active professionally or on the labour market. It is often the victims  who are 
stigmatised  rather  than  the  perpetrators.  The  problem  is  ingrained  in  the  imbalanced 
power-structure  of  society.216  According  to  Dröfn  Gunnarsdóttir,  while  64  %  of  women 

209  See for more information: Nousiainen, K. and Chinkin, C. (2015), Legal implications of EU accession to the 

Istanbul Convention, European network of legal experts in gender equality and non-discrimination, 
available at https://www.equalitylaw.eu/downloads/3794-legal-implications-of-eu-accession-to-the-
istanbul-convention; and De Vido, S., Sosa, L. (2021) Criminalisation of gender-based violence against 
women in European States, including ICT-facilitated violence, European Commission, available at: 
https://www.equalitylaw.eu/downloads/5535-criminalisation-of-gender-based-violence-against-women-in-
european-states-including-ict-facilitated-violence-1-97-mb. 

210  See: https://www.ruv.is/kveikur/heimilisofbeldi-i-skugga-koronuveirufaraldurs/.  
211  A man was convicted by the district court of Reykjanes and got a 14-year prison sentence on 13 January 

2021. 

212  See: https://www.visir.is/g/20212060343d.  
213  See: https://www.logreglan.is/althjodlegur-barattudagur-kvenna/ and https://www.logreglan.is/wp-

content/uploads/2023/11/Kynferdisbrot-Aukaadild-og-sakb.-fyrir-ytri-vef-jan-sept-2023.pdf.  
214  See: https://www.visir.is/g/20242537446d/tilkynningar-um-kynferdisbrot-ekki-faerri-sidan-2017.  
215  https://www.logreglan.is/tilkynningum-um-heimilisofbeldi-faekkar-a-milli-ara/; 

https://www.logreglan.is/wp-content/uploads/2025/01/Heimilisofbeldi-BI-skyrsla-fyrir-ytri-vef-jan-des-
1.pdf. 

216  RÚV News (2024) ‘Verdict sends a message that domestic violence is not as serious as other forms of 

violence’, 14 December 2024, https://nyr.ruv.is/frettir/innlent/2024-12-14-sendir-skilabod-ad-
heimilisofbeldi-se-ekki-jafn-alvarlegt-og-annad-ofbeldi-430979. 

79 

 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

would  return  to  their  abusers  20  years  ago,  today,  only  11 %  of  the  women  who  have 
recently stayed in the shelter go back to their abusers.217 

There are fewer requests for restraining orders in 2024 than in previous years; there were 
79 requests in 2024, which is a decrease of 26 %. 

Surveys show that only 10-20 % of sexual violence cases are reported to the police. In 
the  years  of  2016–2021  the  police  stopped  investigating  or  did  not  prosecute  in  50  to 
60 %  of  sexual  violence  cases.  On  average  16  %  of  incidents  of  sexual  violence  were 
subject to criminal prosecution.218 

The action plan of the Minister of Justice is the basis for improving the handling of sexual 
violence cases.219 The training of policemen is now at university level and the training of 
those investigating sexual violence cases is under revision. Victims are now offered follow-
up interviews with the crisis team at the psychiatric department at the National Hospital 
after questioning by the police.  

The Saga cohort is a research study at the University of Iceland and the largest of its kind 
worldwide.  This  study  is  unique  globally,  shedding  light  on  the  frequency  of  various 
traumas  and  how  they  are  associated  with  women’s  health  in  Iceland.  Around  30 %  of 
Icelandic women between 18 and 69 took part in the first phase of the study from March 
2018–June  2019.  The  women  answered  a  comprehensive  questionnaire  on  various 
traumas  in  various  stages  during  their  lives,  mental  health  symptoms,  and  health  in 
adulthood. The main findings of the first phase of the study show that 4 out of 10 women 
have  experienced  sexual  or  physical  violence  and  half  of  them  have  been  subject  to 
harassment. The findings also reveal that residence does not have any considerable impact 
on  the  number  of  incidents.220  The  authors  of  the  report221  suggest  that  systematic 
preventive measures are necessary as well as  improving the access  of these  women to 
support and treatment in the healthcare system.222 Findings from the first phase of the 
research  have  been  introduced  in  various  scientific  articles  published  in  international 
academic journals. The results have confirmed the high percentage  of various traumas, 
including violence, among Icelandic women and a strong correlation between trauma and 
psychological and mental health issues. 223 In 2024, Icelandic women were again invited 
to  participate  in  the  collection  of  follow-up  data  by  answering  a  new  questionnaire  on 
trauma history, lifestyle and health. 

217  BBC News (2024) ‘100 Women: 2024’, 3 December 2024, https://www.bbc.com/news/resources/idt-

4f79d09b-655a-42f8-82b4-9b2ecebab611. 

218  Director of Public Prosecutions (2022) Report on time frame of sexual violence cases (Skýrsla um 

málsmeðferðartíma kynferðisbrota), https://island.is/s/rikissaksoknari/frett/skyrsla-um-
malsmedferdartima-kynferdisbrota. 

219  Stjórnarráð Íslands (2023.) Aðgerðaáætlun um meðferð kynferðisbrota. Sótt af 

https://www.stjornarradid.is/library/04-Raduneytin/Domsmalaraduneytid/ymsar-
skrar/Adgerdaa%c3%a6tlun_um_medferd_kynferdisbrota_2023_2025.pdf. 

220  The first follow-up data collection started in January 2024. The Saga cohort is a unique nationwide study on 
the impact of trauma on women’s health. The target population are all women, 18 years or older, residing 
in Iceland during the first wave of data collection. From March 2018 till June 2019 participants answered an 
extensive web-based questionnaire on trauma history and health. They will then be prospectively followed 
for diagnoses of major physical diseases and mental disorders. https://afallasaga.is/english/.  

221  See: https://afallasaga.is/rannsoknarteymid/.  
222  See: https://afallasaga.is/um-rannsoknina/; https://www.logreglan.is/althjodlegur-barattudagur-kvenna/.  
223  University of Iceland (2024) ‘New phase in the Saga cohort study’, 22 January 2024, 

https://english.hi.is/research/new-phase-saga-cohort-study. 

80 

 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

10.1.2 Overview of national acts on violence against women, domestic violence and issues 

related to the Istanbul Convention 

The  authorities  submitted  the  first  report  to  GREVIO  on  the  implementation  of  the 
Convention  in  September  2021.224  GREVIO  in  its  baseline  report  in  2022  provided  a 
comprehensive  analysis  of  the  implementation  of  the  provisions  of  the  Istanbul 
Convention.225 It acknowledged the steps taken by the country to comply with the treaty 
but identified areas where progress is still needed. The report assessed the wide variety 
of measures taken by the Icelandic authorities in the area of preventing and combating 
violence  against  women  and  domestic  violence.  Measures  include  aligning  the  Icelandic 
laws and regulations more closely with the requirements of the Istanbul Convention, such 
as the introduction of a consent-based definition of rape and sexual violence, the creation 
of  a  separate  criminal  offence  of  violence  in  a  close  relationship  and  the  Act  on  the 
protection of sexual privacy, which includes provisions to counter digital sexual violence.  

Moreover,  GREVIO  has  observed  numerous  promising  practices  such  as  innovative  and 
targeted awareness-raising campaigns designed to counter violence against women or a 
yearly status report on gender budgeting describing the situation of women in each public 
policy area. 

GREVIO noted in its baseline report, however, that more efforts are needed in particular 
to  offer  more  services  and  policies  for  women  victims  of  stalking,  forced  sterilisation, 
violence related to so-called honour, forced marriage and female genital mutilation, and 
to include the perspective of women subjected to or at risk of intersectional discrimination 
in service provision. The report also showed a lack of harmonised data collection and co-
ordination between relevant services, in particular the police, prosecuting authorities, the 
justice sector and the healthcare sector. 

GREVIO also noted that emergency accommodation for the homeless  is not suitable for 
women  victims  of  violence,  and  even  less  so  when  they  have  children,  as  homeless 
shelters, even if they are only for women, often lack specific approaches and protocols for 
the  prevention  of  violence  and  for  the  provision  of  protection  and  support  to  victims  of 
domestic violence. 

Prior to the signing of the Istanbul Convention, the Icelandic authorities had undertaken a 
revision of national law (the relevant chapter of the General Penal Code No. 19/1940 with 
subsequent amendments is Chapter XXII – Sexual Offences and Chapter XXIII – Homicide 
and Bodily Harm). 226  

In 2010, ‘the purchasing of sexual services’ was made punishable by law, through changes 
in the General Penal Code (Article No. 206). It is illegal to advertise and to benefit from 
prostitution, e.g. through pimping and other means.  

In June 2011, the Parliament approved a law (No. 85/2011) that improves the powers that 
authorities have to protect victims of domestic violence. This law authorises the removal 
of the party accused of domestic violence from the household and puts in place restraining 
orders  in  cases  of  suspected  domestic  violence.  Victims  can  also  request  temporary 

224  Government of Iceland (2021) ‘First report for Iceland on the Council of Europe Convention on preventing 
and combating violence against women and domestic violence’, https://rm.coe.int/grevio-inf-2021-9-state-
report-iceland/1680a3b9e2. 

225  Grevio (2022) Baseline evaluation report: Iceland, https://rm.coe.int/grevio-inf-2022-26-eng-final-report-

on-iceland/1680a8efae. 

226  See: https://www.government.is/library/Files/General_Penal_Code_sept.-2015.pdf, see also here: 

https://evaw-global-database.unwomen.org/en/countries/europe/iceland/1940/general-penal-code-no-19-
1940.  

81 

 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

restraining orders. Act No. 94/2000 amended the Code of Criminal Procedure227 outlining 
restraining orders. A violation of a restraining order is subject to fines or imprisonment for 
up to one year. 

Act  No. 23/2016228  amended  the  General  Penal  Code  No. 19/1940  in  line  with  the 
requirements of the Council of Europe Convention on preventing and combating violence 
against women and domestic violence (Istanbul, 11.V.2011).229 Article 6 of the Penal Code 
stipulates  that  punishment  will  be  imposed  according  to  the  Icelandic  Penal  Code  for 
offences in the Council of Europe Convention on preventing and combating violence against 
women  and  domestic  violence.  The  amendment  includes  adding  a  new  provision 
Article 218(b) (right after Article 218(a)) on domestic violence, which provides: 

- 

- 

Any  person  who,  repeatedly  or  seriously,  poses  a  threat  to  the  life,  health  or 
wellbeing of his or her present or former spouse or cohabiting partner, to his or her 
descendant or the descendant of his or her present or former spouse or cohabiting 
partner, to an older person in his or her direct blood-line, or to other persons who 
live  with  him  or  her  in  the  home  or  are  in  his  or  her  care,  by  means  of  violence, 
threats, deprivation of freedom, coercion or in another manner, shall be imprisoned 
for up to 6 years. 

A  gross  violation  may  be  punishable  by  up  to  16  years’  imprisonment.  When  the 
seriousness  of  the  violation  is  assessed,  particular  consideration  shall  be  given  to 
whether  the  injured  party  suffered  major  physical  injury  or  damage  to  his  or  her 
health or whether the violation was fatal. Furthermore, consideration shall be given 
to whether the violation was committed in a particularly painful or injurious manner, 
whether it lasted a long time or whether the perpetrator grossly abused his or her 
superior position vis-à-vis the injured party. 

Aggravating factors include serious physical injury, damage to health or resulting in death. 
It will also be considered an aggravating factor if the assault was particularly painful or 
the offence is perpetrated in such a way to cause particular pain or injury (Article 195(c) 
of the Penal Code No. 19/1940), or if the assaults are repeated over a long period or if the 
perpetrator has blatantly abused his domineering position in relation to the victim.230  

The  Gender  Equality  Act  No. 150/2020,  adopted  by  Parliament  on  17  December  2020, 
took effect on 6 January 2021. The definition of gender-based violence was inserted into 
the GEA No. 10/2008 and is the same in the new GEA No. 150/2020, Article 2(6): ‘Gender-
based  violence:  Violence  based  on  gender  which  results  in,  or  could  result  in,  physical, 
sexual or psychological injury or suffering on the part of the victim; also the threat of such 
and  coercion  or  arbitrary  deprivation  of  freedom,  both  in  private  life  and  in  a  public 
venue.’231 
Article 218(b) of the Penal Code No. 19/1949232 covers domestic violence. 233 In 
the provisions of both laws, the term ‘gender-based violence’ is gender neutral. 

227  Iceland, Code of Criminal Procedure, https://www.government.is/lisalib/getfile.aspx?itemid=bc7cb7af-

0572-11ea-9450-005056bc4d74. 

228  See: https://www.althingi.is/altext/stjt/2016.023.html.  
229  See: https://rm.coe.int/168008482e.  
230  Article 218 b last sentence as amended by Law No. 23/2016, Article 4 last sentence in Icelandic: Enn 

fremur ber að líta til þess hvort brot hafi verið framið á sérstaklega sársaukafullan eða meiðandi hátt, hafi 
staðið yfir í langan tíma eða hvort gerandi hafi misnotað freklega yfirburðastöðu sína gagnvart þolanda. 
231  Act No. 62/2014, Article 1. Lög um breytingu á lögum nr. 10/2008. An act amending the previous GEA. 

https://www.althingi.is/altext/stjt/2014.062.html.  

232  The translation of the Penal Code No. 19/1949 from Icelandic into English only covers amendments, etc. 
until 2014. After that period there is no English translation – hence amendments from 2014 onwards are 
translated by the author of this report. 

233  As amended by Act No. 23/2016 in accordance with the Istanbul Convention, Council of Europe Convention 

on preventing and combating violence against women and domestic violence. 

82 

 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

A new provision was added to the General Penal Code in 2020 to protect sexual privacy 
due to the impact of digital technologies. The new provision, Article 199(a) comes right 
after Article 199 in Chapter XXII on sexual offences, on sexual privacy. Articles 228 and 
229 were subsequently amended as well the Code of Criminal Procedure No. 88/2008). 234 

Article 227, paragraph 1 of the General Penal Code No. 19/1940 on human trafficking was 
amended by Law No. 79/2021 and adopted on 21 June 2021 (there is no recent translation 
in English of the General Penal Code).235 The words ‘sexually using a person or for forced 
labour’ is replaced with ‘another person in prostitution or in another sexual manner, forced 
marriage,  slavery  or  servitude,  forced  labour  or  forced  service,  including  begging,  to 
commit  a  punishable  act’  [author’s  translation].  Furthermore,  the  wording  in  the  first 
section is: ‘procuring, transporting, handing over, housing or accepting someone by using 
or having used violence, force, coercion, deprivation of liberty, abduction, threats, unlawful 
deceit  by  awakening,  strengthening  or  utilising  the  lack  of  understanding  concerning 
circumstances or by exploiting the position of vulnerability of the person concerned’.236 
Article  34  of  the  Istanbul  Convention  covers  stalking  and  the  signatories’  obligation  to 
criminalise stalking. On 15 February 2021 the legislature passed amendment No. 5/2021 
on stalking, adding a new provision, Article 232, to the General Penal Code and thereby 
making it punishable. Stalking is defined as conduct that entails repeatedly threatening, 
following, contacting, surveilling or by other comparable conduct harassing another person 
in such a way as to cause fear or anxiety. Stalking was not punishable until Article 232 
came into effect. Before this amendment, restraining orders were used to protect victims 
from  repeated  violations  of  privacy  or  harassment.  A  restraining  order  is  a  provision 
intended to improve the legal standing of victims and limit the leeway of the harassers but 
is  not  subject  to  punishment.  Requesting  a  restraining  order  is  subject  to  various 
requirements  (see  Act  No.  85/2011  on  restraining  order  and  removal  from  household). 
Stalking another person as described in Article 232 of the General Penal Code constitutes 
grounds for a restraining order.  

With Act No. 23/2016 a new paragraph was added to Article 225 of the General Penal Code 
prohibiting forced marriage. 

10.1.3 Political and societal debate 

Currently, violence against women probably ranks the highest of all issues in relation to 
gender equality in Iceland.  

The  provisions  on  restraining  orders,  removal  from  household  and  stalking  have  been 
criticised  for  their  infrequent  use.237  Courts  can  issue  restraining  orders  but  there  is  an 
overall  complaint  (shared  by  the  police)  that  these  are  not  always  obeyed  in  practice. 
Some  reports  also  suggest  that  courts  set  the  bar  too  high,  diminishing  the  power  of 
restraining orders and limiting them to extreme circumstances only. The Icelandic judiciary 
is  independent.  It  is  up  to  the  individual  judge  to  decide  whether  to  keep  a  suspect  in 
custody  during  a  criminal  investigation  or  to  grant  release  pending  trial.  There  is  no 
bail system. 

The law prohibits domestic violence primarily through the provisions of the Criminal Code. 
However,  violence  against  women  continues  to  be  a  problem.  The  penalties  can  range 
from a fine to 16 years in prison, depending on the type of violence committed. In addition, 
the law permits judges to increase the sentences of persons who commit violence against 
persons with whom they have had a domestic relationship or other close bond. However, 

234  See: https://www.althingi.is/thingstorf/thingmalalistar-eftir-thingum/ferill/?ltg=151&mnr=267 and 

https://www.althingi.is/altext/151/s/0296.html. 

235  See: https://www.althingi.is/altext/stjt/2021.079.html. 
236  See: https://www.althingi.is/altext/stjt/2021.079.html. 
237  RUV (2023) ‘Surprised she hasn’t been charged more often’, 9 June 2023, 

https://www.ruv.is/frettir/innlent/2023-06-09-undrast-ad-ekki-hafi-verid-akaert-oftar-fyrir-umsaturseinelti. 

83 

 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

there  were  no  domestic  violence  cases  in  which  judges  actually  handed  down  heavier 
sentences and there has been criticism that sentences are often too lenient. 

In  December  2024  a  district  court  handed  down  a  judgment  where  a  man  accused  of 
serious domestic violence killed his wife whom he had been assaulting since 1999. He got 
12 years in prison as there was no proof of premeditation.238 

Recent political debates concern sentences in rape cases where defendants, such as in one 
recent  case, 239  got  a  probationary  prison  sentence.  The  reasons  given  by  the  Court  of 
Appeal was that it took the police eight months to investigate the case after the woman 
pressed  charges  and  it  was  not  sent  to  the  district  prosecutor  until  one  year  later.  The 
legal proceedings in such cases are criticised for taking a long time, which may have an 
impact  on  the  ruling.  The  victims  on  the  other  hand  are  viewed  as  suffering  from  the 
prolonged process and waiting for a decision. Additionally, the victims themselves must 
collect their damages from their assailant with the ensuing legal cost. The minimal penalty 
for rape is one year and the maximum 16 years (Article 194 of the General Penal Code 
No. 19/1940). In a recent TV programme covering shortcomings in the handling of sexual 
crimes by the legal system, a victim recounted that it took six years for her rape case to 
go through the court system, from lower court to appellate court where the defendant was 
found guilty and given a probationary prison sentence. The long court proceedings were 
considered by the courts as mitigating factors for the defendant. 

 General context with regard to the obligation set out by the Violence Against 
Women Directive 

10.2.1 Preparatory transposition work  
There have been no discussions yet regarding Directive EU 2024/1385. 

10.2.2 National provisions on cyber violence  

Cyber  harassment  and  cyber  bullying  are  generally  not  punishable  in  Iceland  as  the 
legislation has not developed hand in hand with technology. Raised awareness has led to 
political forces putting the fight against digital violence at the forefront. There is still a long 
way to go and implementing comprehensive legislation takes time.240 

The Penal Code No. 19/1940 with later amendments prohibits hate speech in the media; 
incitement  to  criminal  conduct  (Article 27);  the  use  of  social  media  and  the  internet  to 
make  contact  with  children  under  the  age  of  15,  etc.  (Article 202).  Article 233(a) 
criminalises  the  conduct  of  mocking,  defaming,  threatening  an  individual  or  group  of 
individuals  with  verbal  or  any  other  kind  of  expression,  due  to  ethnicity,  race,  colour, 
religion, sexual orientation or gender identity.241 

238  The District Court of Northeast Iceland, judgment 9 December 2024, case No. S-295/2024, RUV (2024) 
‘Man who killed his wife had been abusing her for decades’, https://nyr.ruv.is/frettir/innlent/2024-12-11-
madur-sem-drap-konu-sina-hafdi-beitt-hana-ofbeldi-aratugum-saman-430744. 

239  Court of Appeal judgment, case No. 528/2021, 24 June 2022. 

(https://www.landsrettur.is/?PageId=347c3bb1-8926-11e5-80c6-005056bc6a40&Id=e6dc9665-c3fa-4038-
b2f3-ea4e9f6e0ad5&verdictid=48191d01-ceff-43e6-9046-feca8a66eda6). See also: 
https://www.ruv.is/frettir/innlent/2020-11-27-domur-fyrir-tvaer-naudganir-skilordsbundinn-vegna-tafa. 

240  Skarpass, E. (2024) Cyber harassment and bullying on social media, LLM thesis on digital violence, 

https://skemman.is/handle/1946/47392. 

241  Skarphéðinsdóttir, I. (2013) Kynferðisleg áreitni skv. 199. gr. almennra hegningarlaga (Sexual harassment 
in view of Article 199 of the General Penal Code No. 19/1940), an LLM thesis at the University of Iceland (in 
Icelandic only), available at: 
https://skemman.is/bitstream/1946/14709/1/Inga%20Skarphe%CC%81%C3%B0insdo%CC%81ttir-
ritger%C3%B0.pdf. 

84 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

Act  No. 22/2021  amended  the  General  Penal  Code, 242  by  adding  Article 199a  to 
Chapter XXII on sexual offences, after the provision on sexual harassment in Article 199. 
The new provision concerns sexual privacy due to the impact of digital technologies (no 
translation yet)243 where anyone who prepares, imparts or accesses illustrative material, 
text or comparable content, including falsified material of another person’s nudity or sexual 
conduct  without  consent  will  be  subject  to  fines  or  imprisonment  up  to  four  years.  The 
same punishment applies to anyone who threatens such conduct. Culpable negligence is 
subject to fines or imprisonment up to one year. 

 Ratification of the Istanbul Convention 

Iceland ratified the Istanbul Convention on 26 April 2018.244 

242  Act No. 22/2021, https://www.government.is/lisalib/getfile.aspx?itemid=dd8240cc-c8d5-11e9-9449-

005056bc530c. 

243  See: Icelandic Penal Code: https://www.government.is/lisalib/getfile.aspx?itemid=dd8240cc-c8d5-11e9-

9449-005056bc530c.  

244  See: https://www.ruv.is/frett/radherra-fullgildir-istanbulsamninginn; https://www.jafnretti.is/is/samfelag-

og-vinnumarkadur/kynbundid-ofbeldi/istanbulsamningurinn. 

85 

 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

11  Compliance  and  enforcement  aspects  (horizontal  provisions  of  all 

directives)  

 General (legal) context 

The Act on the administration of matters concerning equality No. 151/2020 applies, among 
other things, to the activities of the Directorate of Equality and the Equality Complaints 
Committee.245 

Article 8 of Act No. 151/2020 provides that:  

‘The Equality Complaints Committee handles complaints submitted to it in keeping 
with the equality acts referred to in Article 1 [i.e. the Act on Equal Status and Equal 
Rights Irrespective  of  Gender, the Act on Equal Treatment Irrespective of Race  or 
Ethnic Origin, and the Act on Equal Treatment on the Labour Market.], and gives a 
written  ruling  regarding  whether  or  not  the  provisions  of  those  acts  have  been 
violated.  If  the  Equality  Complaints  Committee  concludes  that  there  has  been 
violation  of  the  provisions  of  the  acts,  it  may,  in  its  ruling,  instruct  the  entity  in 
question to make specific improvements.  

The Complaints Committee operates as an independent and autonomous entity and 
its rulings cannot be appealed to a higher authority. 

The  Complaints  Committee’s  rulings  are  binding  for  the  parties  to  the  case.  The 
parties to the case may refer the Committee’s rulings to the courts of law. If a party 
to a case refers the ruling of the Equality Complaints Committee to the courts within 
eight  weeks  of  the  publication  of  the  ruling,  the  judicial  effects  of  the  ruling  are 
suspended. A party to a case may petition for an accelerated procedure before the 
courts. If a petition for an accelerated procedure is denied, the court action shall be 
initiated as soon as possible after the petition is submitted, and in any case no later 
than within thirty days from the denial. The delay of the judicial effects of the ruling 
shall  cease  to  apply  if  the  if  court  proceedings  are  not  initiated  within  thirty  days 
from the judge’s denial of an accelerated procedure. Should a case be brought before 
the courts due to the Committee’s ruling, it may defer the handling of comparable 
cases it has accepted for processing until a judgement is passed in the case.  

The  Equality  Complaints  Committee  can  decide,  if  it  rules  in  favour  of  the 
complainant, that the entity to which the complaint refers shall pay the complainant’s 
cost of proceedings before the Equality Complaints Committee.  

If the Equality Complaints Committee’s ruling is in favour of the complainant but the 
opposing party is not willing to accept the ruling and refers the case to the courts for 
annulment,  the  Equality  Complaints  Committee  and  the  complainant  shall  be  the 
defendants.  The  complainant’s  costs  of  proceedings  before  the  district  court,  the 
Landsréttur  (Appeal  Court)  and  the  Supreme  Court  shall  be  paid  from  the  state 
Treasury. 

If  the  Equality  Complaints  Committee  finds  that  a  complaint  is  clearly  unfounded, 
the Committee can rule that the complainant shall pay the opposing party’s costs of 
the proceedings. A levy of execution may be carried out without a prior judgement 
of enforcement of the claim for the cost of the proceedings.  

245  Act on the administration of matters concerning equality No. 151/2020, 

https://www.government.is/library/04-
Legislation/Act%20on%20the%20Administration%20of%20Matters%20Concerning%20Equality.pdf. 

86 

 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

The expenses of the Equality Complaints Committee’s activities are paid by the state 
Treasury.’ 

The Equality Complaints Committee issued 18 rulings in 2024: 

1. 
2. 

3. 

4. 

5. 

6. 

(13  September  2024):  Employment.  Public  administration. 

No. 4/2023 (23 September 2024): Discrimination. Disability. No violation. 
No.  2/2023 
Discrimination. Gender. No violation. 
No.  10/2024  (6  September  2024):  Dismissal.  Lack  of  legal  standing.  (A  decision 
which  does  not  conclude  the  determination  of  a  case  cannot  be  the  subject  of  a 
complaint  until  the  case  has  been  concluded,  cf.  Art.  26(2)  of  the  Administrative 
Procedures Act No. 37/1993). 
No.  1/2023  (20  August  2024):  Dismissal.  Pregnant  spouse.  Ethnic  origin.  No 
violation. 
No.  10/2023  (19  August  2023):  Appointment.  Public  Service.  Discrimination. 
Gender. No violation. 
No.  9/2024  (14  August  2024):  Dismissal.  Period  during  which  complaints  may  be 
lodged. 
No. 12/2024 (14 August 2024): Dismissal. Material scope of national law. 
No. 14/2024 (14 August 2024): Employment. Discrimination. Gender. No violation. 
No. 7/2024 (8 August 2024): Dismissal. Insufficient evidence. 

7. 
8. 
9. 
10.  No. 12/2023 (8 August 2024): Dismissal. Circumstances related to pregnancy and 

childbirth.  

11.  No. 6/2023 (8 August 2024): Duty of notification. Discrimination. Race. Ethnic origin. 

Outside labour market. No violation. 

12.  No.  8/2023  (5  July  2024):  Employment.  Public  Administration.  Discrimination. 

Gender. Age. Multiple discrimination. Violation. 

13.  No.3/2024 (17 May 2024): Disability. Outside labour market. Review of a case. Claim 

rejected. 

14.  No.  16/2023  (10  May  2024):  Appointment  in  committee.  Participation.  Legal 

standing. Dismissal.  

15.  No. 13/2023 (10 May 2024): Treatment at work. Dismissal. 
16.  No.  6/2024  (19  April  2024):  Dismissal.  Demanding  redress.  Pay  discrimination. 
Gender.  Race.  Ethnic  origin.  Multiple  discrimination.  No  violation  regarding  pay. 
Violation regarding dismissal. 

17.  No. 5/2023 (10 January 2024): Rejection of renewal of employment. Discrimination. 

Religion. No violation. 

18.  No. 16/2022 (10 January 2024): Employment. Discrimination. Gender. Violation. 

11.1.1 Issues related to the pursuit of a discrimination claim 

The main obstacles in relation to pursuing a discrimination claim are expensive lawyers’ 
fees and the uncertainty of outcome as the burden of proof is a cumbersome process. In 
cases  concerning  employment  the  complainant  may,  by  all  general  standards,  be  more 
qualified as regards education and experience (case No. 16/2022, academic post) while 
the  Complaints  Committee  only  seeks  to  assess  whether  the  hiring  process  was  non-
discriminatory. Hence, the institution may set lower standards than would be considered 
normal. A complainant who has been rejected will not be hired despite winning the case 
and  their  next  step  is  to  try  to  reach  a  bargain  for  some  compensation.  In  2024,  the 
Equality Complaints Committee dealt with 18 cases and ruled in favour of the complainant 
in  3  of  them.  Such  statistics  may  prove  discouraging  for  complainants.  Fear  of  risking 
future chances of finding a job and being labelled a troublemaker or loser also plays a role, 
especially with professionals who have an image to protect with regard to their next job 
application.  

87 

 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

11.1.2 Political and societal debate and pending legislative proposals 

There are no pending legislative proposals that are being debated in the public forum. 

11.1.3 Gender mainstreaming 

Gender mainstreaming has been part and parcel of the gender equality legislation since 
Act No. 96/2000 and subsequently Act No. 10/2008. The new GEA No. 150/2020 includes 
the same definition in Article 2(7), albeit with a slight change of wording where the new 
Act speaks  of the incorporation of gender and equality perspectives,  while the previous 
Act  No. 10/2008  included  the  words  ‘gender  equality  perspective’.  The  reason  for  the 
different wording is to emphasise the objective of working against multiple discrimination. 

Gender  and  equality  mainstreaming  have  been  an  ongoing  project  within  the  Icelandic 
administration, as explained on the Government’s website, in previous action plans and 
gender budgeting.246 

Employers must take measures in accordance with Article 5, paragraph 1 of the GEA, on 
mainstreaming gender equality plans into personnel policies. It is furthermore necessary 
to introduce these policies in a coherent manner to employees, as stated in the explanatory 
report to the GEA No. 150/2020. 

 Victimisation 

Article 20  of  the  new  GEA  No. 150/2020  on  the  prohibition  against  dismissal,  etc.,  in 
connection with a complaint or a demand for redress replaces Article 27 of the previous 
GEA No. 10/2008 but is substantially the same. Article 20 provides that:  

‘Employers may not dismiss an individual for demanding redress on the basis of this 
Act.  Furthermore,  employers  shall  ensure  that  employees  are  not  subjected  to 
injustice  in  their  work,  e.g.  as  regards  job  security,  terms  of  employment  or 
performance  assessment,  on  the  grounds  of  having  submitted  a  complaint  or 
provided information regarding gender-based or sexual harassment or gender-based 
discrimination. If a likelihood is adduced that this provision has been violated, the 
employer shall demonstrate that the dismissal or alleged injustice is not based on 
the employee’s demand for redress, complaint or provision of information regarding 
gender-based or sexual harassment or gender-based discrimination. This shall not 
apply if the dismissal takes place more than one year after the employee made the 
demand for redress under this Act.’ 

Article 23 replaces Article 30 of the previous GEA (prohibition of a waiver). 

The above Article 20 complies with Article 24 (victimisation) of the Recast Directive. 

 Access to courts 

Most discrimination cases initially go before the Equality Complaints Committee. Following 
a ruling by the Committee, the complainant, if they have been successful, can commence 
an action for damages before a court of law. It may be assumed that the most common 
violations of the Gender Equality Act are regarding wage equality as the gender-based pay 
gap persists. In 2024, the Equality Complaints Committee ruled in 18 cases and found a 
violation  in  3  of  them:  discrimination  on  grounds  of  gender  in  case  in  case  16/2022; 
multiple  discrimination  on  grounds  of  gender  and  age  in  case  8/2023  and  violation 
regarding dismissal in case 6/2024. Nine cases were dismissed.  

246  See: https://www.stjornarradid.is/verkefni/mannrettindi-og-jafnretti/jafnretti/framkvaemdaaaetlun-i-

jafnrettismalum-/stok-adgerd/?itemid=6c8bc85b-fe8b-11ea-8123-005056bc8c60.e. 

88 

 
 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

The  complainants  must  pay  their  legal  fees  themselves  (most  lawyers  charge  EUR 150 
(ISK 25 000) or more per hour). The Complaints Committee can decide, if it rules in favour 
of  the  complainant,  that  the  entity  to  which  the  complaint  refers  must  pay  the 
complainant’s  cost  of  proceedings  before  the  Committee  (Article  8  of  the  Act  on  the 
administration  of  matters  concerning  equality,  No.  151/2020).  Should  the  Complaints 
Committee  rule  in  their  favour  they  can  take  their  case  to  a  court  of  law  and  seek 
compensation. The parties may refer the Committee’s rulings to the courts.  

11.3.1 Difficulties and barriers related to access to courts 

Legal fees are high, burden of proof often difficult and outcomes are uncertain. 

According to Article 41 of the Law on Criminal Procedure No. 88/2008, claimants in cases 
of  sexual  violence  and  other  serious  offences  have  the  right  to  an  independent  legal 
counsel  who  is  a  lawyer  paid  for  by  the  state.  According  to  Article  45,  the  role  of  the 
independent legal counsel is to guard the interests of their client and to support them in 
the case, which includes filing civil claims. These claims are then usually filed in conjunction 
with the criminal proceedings. If the accused is found guilty, the victim is usually awarded 
compensation  from  the  offender.  According  to  Article  176,  however,  the  judge  will  not 
consider the civil claim if the accused is not found guilty.  

There is recognised need to strengthen the situation of victims of sexual violence. Under 
the  current  system,  the  victim  is  not  part  of  the  prosecutor’s  case  against  the  alleged 
offender.  The  police  have  a  duty  to  inform  the  victim  about  their  rights  and  whether 
investigation  in  the  case  has  been  ended  or  cancelled,  as  well  as  providing  substantive 
reasoning for such decisions so that the victim can contest the decision before the state 
prosecutor. However, the police are not under any obligation to inform the victim about 
the process of the case. The victim may be called to give a report twice while having no 
further insight into the process of the case until the police cease the investigation, dismiss 
the case, or the prosecutor cancels it or initiates prosecution. As the victim is not part of 
the case and has little or no insight into its process, they may not know which information 
that they have might be of use for those conducting the investigation. If the victims were 
part of the case they might be able to provide useful information to the investigation. It 
also seems important that the victim can contest the testimony of the alleged offender or 
aid  in  providing  more  evidence.  Under  the  current  system,  the  victim  is  not  allowed  to 
overhear  the  testimony  of  the  alleged  offender,  to  avoid  influencing  witnesses.  As  it  is 
now, the trials in sexual offence cases are closed; the victim has the status of a witness 
and cannot sit in the courtroom and follow the case.247 

A partial involvement of the victim in the prosecutor’s case has been instituted in Sweden 
and Norway, granting victims the same rights as the accused, such as access to documents 
and a right to pose questions in court. 

11.3.2 Availability of legal aid 

Legal aid is provided for all individuals involved in judicial proceedings in Iceland who fulfil 
the  strict  requirements  to  receive  it.  Foreign  nationals  who  are  involved  in  judicial 
proceedings  in  Iceland  may  therefore  be  eligible  for  legal  aid,  as  legal  aid  is  granted 
regardless of nationality. Article 126 of the Act on Civil Procedure No. 91/1991 states that 
any person involved in judicial proceedings in Iceland may be entitled to legal aid. 

Legal aid is granted by the Ministry of the Justice. However, the minister is bound by the 
opinion  of  an  independent  committee,  the  Legal  Aid  Committee,  which  recommends  or 
denies legal aid depending on the circumstances in each case. The committee is composed 

247  See: https://kjarninn.is/frettir/2019-06-20-baeta-aetti-rettarstodu-brotathola-i-kynferdisbrotamalum/.  

89 

 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

of three lawyers. The chair is appointed by the minister, one member is nominated by the 
Icelandic Bar Association and one member by the Judge’s Association. 

An individual sends a detailed application for legal aid (most often with the assistance of 
a  lawyer),  with  information  about  the  case,  the  individual’s  finances  and  other  relevant 
information,  to  the  ministry  before  the  case  goes  to  court.  The  Legal  Aid  Committee 
assesses  applications  for  legal  aid  on  the  merits  of  the  case  and  the  income  of  the 
applicant. The income threshold for eligibility for legal aid is EUR 12 000 (ISK 2 million) 
per individual per year before taxes. For a married or cohabiting couple, it is EUR 18 000 
(ISK 3 million). An additional EUR 1 500 (ISK 250 000) is allowed for each child supported 
by the applicant. These criteria are not definitive. The committee may look at factors other 
than  just  income  when  deciding  on  the  eligibility  of  the  applicant.  These  factors  are 
outlined  in  the  Regulation  on  Legal  Aid  No. 45/2008.  Legal  aid  may  be  granted  to  an 
individual who has income above the threshold under particular circumstances,  such as 
when the cost of living is especially high for some reason. The committee may deny legal 
aid to someone who fulfils the criteria in particular circumstances, for example, due to the 
value of the property owned by the individual. 

If an individual has been granted legal aid, they are exempt from all legal fees payable to 
the  state  treasury.  Other  legal  costs,  including  the  lawyer’s  remuneration,  according  to 
the  judge’s  decision,  are  paid  by  the  ministry.  Legal  aid  can  be  restricted  to  a  certain 
amount of money in cases that should be settled out of court and it is sometimes restricted 
to legal fees and the evaluation of one court-appointed specialist. The restriction is decided 
by the Legal Aid Committee on the basis of the application from the individual. 

Victims of sexual violence do not initiate private legal proceedings. Although it would be 
perceivable, it could be financially risky. It has thus been suggested that legal aid should 
be enhanced is such situations.248 

 Horizontal effect of the applicable law 

11.4.1 Horizontal effect of relevant gender equality law 

The horizontal direct effect of the gender equality legislation (GEA, No. 150/2020) is that 
it  can  be  relied  on  by  individuals  before  domestic  courts  and  the  Equality  Complaints 
Committee, not only against public institutions but also against private employers. 

11.4.2 Impact of horizontal direct effects of the charter after Bauer  

Established case law of the EFTA Court confirms that fundamental rights form part of the 
general principles of EEA law; the provisions of the European Convention on Human Rights 
and the case law of the European Court of Human Rights have an important role.249 The 
EU Charter of Fundamental Rights is not applicable as such within the EFTA pillar of the 
EEA.  

Iceland, like Norway, has a dualistic approach to international law. In order to be applicable 
in domestic law, EEA legislation has to be transposed into Icelandic legislation. EEA law 
that  has  not  been  transposed  is  not  applicable  as  such  in  Icelandic  courts.  EEA  law,  as 
opposed  to  EU  law,  does  not  call  for  the  direct  effect  or  for  the  supremacy  of  EEA  law 
within  the  domestic  legal  system  of  the  EFTA  States  (Article 7,  EEA  Agreement  and 

248  Antonsdóttir, H.F. (2019) ‘Réttlát málsmeðferð með tilliti til þolenda kynferðisbrota’ greinargerð um leiðir til 

að styrkja réttarstöðu þolenda, available at: 
https://www.stjornarradid.is/lisalib/getfile.aspx?itemid=c9ee2c0c-927f-11e9-9442-005056bc530c.  

249  The entry into force of the Charter of Fundamental Rights as a binding legal act in 2009 did not deprive the 
ECHR of its role in the EU legal system as a source of fundamental rights in the form of general principles: 
http://www.europarl.europa.eu/thinktank/en/document.html?reference=EPRS_BRI%282017%29607298. 

90 

 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

Protocol 35  to  the  Agreement).250  All  the  same,  Iceland  is  obliged  to  transpose  the  EU 
directives into domestic law on the basis of the EEA Agreement as well as interpreting the 
provisions of the EEA Agreement in accordance with the judgments of the EU courts, i.e. 
those from before the signature of the Agreement.251  

The successful operation of the EEA depends on uniform implementation and application 
of the common rules in all EEA States. To this end, a two-pillar system of supervision has 
been devised: the EU Member States are monitored by the EU Commission and the EFTA 
States party to the EEA Agreement by the EFTA Surveillance Authority. The latter has been 
given powers corresponding to those of the Commission in the exercise of its surveillance 
role.  A  two-pillar  structure  has  also  been  established  in  respect  of  judicial  control;  the 
EFTA Court operates in parallel to the Court of Justice of the European Union. 

Because of the above, the evolution of Icelandic legislation in the sphere of gender equality 
is heavily influenced by EU law. Rulings of the CJEU have limited relevance in Icelandic 
case law unless indirectly if referred to in judgments of the EFTA Court. The EU Charter of 
Fundamental Rights is not recognised in Icelandic case law. 

 Burden of proof 

The  GEA  No. 150/2020  provides  for  a  shift  in  the  burden  of  proof.  An  alleged  victim  of 
discrimination  has  to  establish,  before  a  court  or  other  competent  authority,  facts  from 
which it may be presumed that there has been direct or indirect discrimination. The burden 
of  proof  is  twofold.  The  claimant  must  provide  all  the  relevant  facts,  documents  and 
information  which  would  lead  to  the  claim  that  the  claimant  was  directly  or  indirectly 
discriminated against on the basis of sex. If the claimant succeeds with this objective the 
burden  of  proof  shifts  to  the  employer  to  demonstrate  that  factors  other  than  sex 
determined  his/her  decision.  In  assessing  whether  the  claimant  has  provided  all  the 
relevant  material  conducing  to  his/her  case  of  discrimination  on  engagement  in 
employment and the employer likewise has proven that he/she had not discriminated on 
the basis of sex, paragraph 5 of Article 19 contains guidance for the Equality Complaints 
Committee’s assessment. 252 

It  is,  however,  for  the  person  believed  to  be  the  discriminator  to  demonstrate  that  the 
grounds for the treatment are not gender based unless it can be justified in an objective 
manner with a legitimate aim in mind, and the means of achieving that aim are appropriate 
and necessary (Articles 17(3) on prohibition against discrimination in relation to access to 
goods  and  services,  18(2)  on  prohibition  against  discrimination  regarding  terms  of 
employment, 19(4) on prohibition against discrimination at work and on engagement in 
employment, and 20(3) on prohibition against dismissal). 

In sexual offence cases a high burden of proof is required, which is often difficult due to 
the  lack  of  concrete  evidence.  The  prosecutor  gathers  evidence  but  the  defendant  may 
also gather evidence if they consider a reason to do so. If the judge considers it necessary 
to solve a matter or clarify it, he or she may instruct the prosecutor to gather evidence 
regarding particular aspects of it. If the judge considers it evident that points that a party 
wishes to demonstrate are of no importance or that an item of evidence is of no evidential 

250  For further reading on this topic: Bårdsen, A. (2015) ‘Fundamental Rights in EEA Law – The Perspective of a 
National Supreme Court Justice’, EFTA Court spring seminar, Luxembourg 12th of June 2015, available at: 
https://www.domstol.no/globalassets/upload/hret/artikler-og-foredrag/fundamental-rights-in-eea-law---
bardsen-03062015.pdf. 

251  Article 6 of the EEA: ‘Without prejudice to future developments of case law, the provisions of this 

Agreement, in so far as they are identical in substance to corresponding rules of the Treaty establishing the 
European Economic Community and the Treaty establishing the European Coal and Steel Community and to 
acts adopted in application of these two Treaties, shall, in their implementation and application, be 
interpreted in conformity with the relevant rulings of the Court of Justice of the European Communities 
given prior to the date of signature of this Agreement.’  

252  See Act on administration on matters concerning equality No. 151/2020. 

91 

 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

value, he or she may prevent a party from presenting proof concerning it (Article 110 of 
the Code of Criminal Procedure). Frequently, it boils down to a case of one person’s word 
against another’s.  

Condemnation  on  social  media,  urging  a  rush  to  judgment  and  the  so-called  ‘cancel-
culture’ often results in harsher or more damaging outcomes than the actual judgments. 
The presumption of innocence principle is protected under Article 70, paragraph 2 of the 
Constitution,  which  is  that  everyone  charged  with  criminal  conduct  shall  be  presumed 
innocent until proven guilty (Article 6(2) of the European Convention of Human Rights). 

A tragic incident occurred in 2024 when a 28-year-old pilot with Icelandair took his own 
life. This came in the wake of workplace bullying by two women co-workers harassing him 
with unclear or vague accusations – slandering about him in the workplace. His complaint 
to  the  human  resources  department  was  delayed  and  finally  dismissed.  There  was  no 
official complaint to the police concerning his alleged conduct. 253  

 Remedies and sanctions  

Section  VI  of  the  Gender  Equality  Act  No. 150/2020  deals  with  sanctions.  Article 31 
concerns compensation for financial loss and personal injury and Article 32 covers fines 
for violations of Articles 16-23 in Chapter III of the GEA prohibiting discrimination on the 
grounds of sex.  

11.6.1 Types of remedies and sanctions 

Compensation may be awarded for non-financial loss as well as financial loss. Violations 
are punishable by fines unless heavier penalties are prescribed by other statutes. 

The new Act on the administration of gender equality matters No. 151/2020 provides that 
the Directorate of Gender Equality can impose per diem fines on the basis of violations of 
the GEA, to ensure better compliance with the law. 

Effectiveness, proportionality and dissuasiveness 

Surveys show that only 10-20 % of sexual violence cases are reported to the police. In 
the  years  of  2016–2021  the  police  stopped  investigating  or  did  not  prosecute  in  50  to 
60 %  of  sexual  violence  cases.  On  average  16  %  of  incidents  of  sexual  violence  were 
subject to criminal prosecution.254 Procedure in the justice system often takes a long time 
resulting in a lenient judgment. Women who press charges fear the consequences of being 
accused of false claims - see Article 148 of the Penal Code, where the punishment can be 
10 years. 

In  one  case,  the  Ministry  of  Justice  acknowledged  that  a  mistake  occurred  during  the 
investigation after police dropped charges on the grounds that a conviction was unlikely. 
However, it concluded that the error did not rise to the level of a breach of the European 
Convention  on  Human  Rights,  to  which  the  woman  had  complained.255  Her  complaint 

253  Nútíminn (2024) ‘Young Iceldandair pilot: “I am taking my own life because I don’t trust myself to live”’, 20 
September 2024, https://www.nutiminn.is/frettir/ungi-flugmadurinn-hja-icelandair-eg-er-ad-taka-mitt-
eigid-lif-thvi-eg-treysti-mer-ekki-til-ad-lifa-lengur/. 

254  Director of Public Prosecutions (2022) Report on time frame of sexual violence cases (Skýrsla um 

málsmeðferðartíma kynferðisbrota), https://island.is/s/rikissaksoknari/frett/skyrsla-um-
malsmedferdartima-kynferdisbrota. 

255  Application No. 59813/19 lodged on 8 November 2019 by M.A. The applicant pressed charges in December 

2017 against her ex-cohabiting partner for two separate assaults committed in February and July 2016. A 
statement was taken from the applicant in December 2017 and the accused in August 2018. The police 
notified the applicant in April 2019 that the case had been closed on the grounds that it was not likely to 
lead to a conviction. The State Prosecutor upheld the decision in August 2019 on the grounds that the two-
year statute of limitation for the charges had lapsed when the formal investigation started with the 

92 

 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

alleged that delays in taking statements from the accused caused the statute of limitations 
to expire unjustly, violating the state’s obligation to conduct an effective investigation and 
prosecution of sexual assault and domestic violence. 

Penalties  for  sexual  offences  are  generally  lenient,  with  suspended  sentences  being 
common. Offenders must cover legal costs, which can be high, and pay damages to the 
victim, varying by crime severity. 

Around  one  hundred  individuals  sought  help  from  Bjarkarhlíð,256  a  centre  for  victims  of 
violence due to stalking in 2024, as well as 160 because of cyber-harassment/violence. 
The rapid development of digital technologies has paved the way for abusers.  

The Equality Complaints Committee found a violation in 3 of the 18 rulings delivered in 
2024. 

The dissuasive factors against seeking justice are probably fewer now than before given 
that  public  employers  as  well  as  private  ones  are  more  aware  of  the  negative  public 
relations impact  of  facing claims of discrimination. It can, however, be difficult to claim 
discrimination  when  applying  for  a  job,  as  employers  have  been  granted  wide  scope  in 
choosing between applicants from subjective paradigms. 

Article 8  of  the  Act  No. 151/2020  on  the  administration  of  matters  concerning  equality 
provides that the Equality Complaints Committee can decide, if it rules in favour  of the 
complainant, that the entity to which the complaint refers will pay the complainant’s cost 
of  proceedings  before  the  Equality  Complaints  Committee.  In  case  No. 6/2021257  the 
Complaints Committee concluded that there had been violation on the basis of Article 8 of 
Act on equal treatment on the labour market No. 86/2018258 (prohibition on discrimination 
at work and in this case on the basis of age). It did not consider it necessary, however, as 
it may do according to Article 8, paragraph 1 of Act No. 151/2020 in its ruling instruct the 
entity in question to make specific improvements. On the other hand it accepted the claim 
of  the  complainant  that  the  defendant  should  pay  the  cost  of  proceedings  before  the 
Complaints Committee, according to Article 8, paragraph 4 of Act No. 151/2020. 

 Equality body  

In Iceland the Directorate for Gender Equality (Jafnréttisstofa; website: www.jafnretti.is) 
fulfils the role of an equality body. The staff consists of eight people: six women and two 
men.  Its  tasks  are  listed  in  Chapter  II  of  the  new  Act  on  the  administration  of  gender 
equality matters No. 151/2020 where monitoring the application of the GEA is listed first, 
hence  its  concerns  are  all  the  grounds  which  form  the  basis  of  the  prohibition  of 
discrimination. Its role includes, amongst other things, advising authorities, institutions, 
NGOs and individuals on gender equality issues; providing assistance to gender equality 
committees, gender equality advisers and representatives of local authorities, institutions 
and  companies;  mediating  in  cases  of  disputes  referred  to  the  Directorate  for  Gender 
Equality on the basis of the GEA; and investigating whether there is a reason to request 
the Gender Equality Complaints Committee to examine a matter when there is a suspicion 
of a breach of the GEA by an institution or enterprise. It also has competence to request 
information from organisations, institutions, etc. regarding matters in a case of an alleged 

statement of the accused. The applicant was granted anonymity by this Court on 16 February 2021. 
Reykjavik Grapevine (2021) ‘Women’s case in the ECtHR makes international headlines’, 20 December 21, 
https://grapevine.is/news/2021/12/20/womens-cases-against-iceland-in-human-rights-court-make-
international-headlines/. 

256  Bjarkarhlíð website: https://bjarkarhlid.is/; Visir (2025) ‘News round-up’, 

https://www.visir.is/g/20252703436d/umsaturseinelti-attavilltur-ferdamadur-og-rektorskjor. 

257  Equality Complaints Committee ruling of 31 January 2022. 
258  Act on equal treatment on the labour market, No. 86/2018. See: 

https://www.jafnretti.is/static/files/English_gogn_a_ensku_sidu/act-on-equal-treatment-on-the-labour-
market-no-86-2018-m-br-final-sent-230519.pdf. 

93 

 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

breach. Such parties are obliged to provide the Directorate with the requested information 
and the Directorate may fine them if they do not obey (which, to date, has never been 
done). 

The Directorate for Gender Equality has competence to impose per diem fines to ensure 
compliance with its requests for information or documents in accordance with Article 5 of 
the Act on administration of gender equality matters, No. 151/2020, or in accordance with 
Article 10  of  the  GEA  No. 150/2020  regarding  the  equal  pay  certification. 259  The 
Directorate  for  Gender  Equality  has  not  resorted  to  this  measure  of  imposing  per  diem 
fines as it may do in accordance with Article 7 of Act No. 151/2020. 

 Social partners  

The  social  partners  include  the  Icelandic  Confederation  of  Labour  (ASÍ),  SA  – 
Confederation of Icelandic Employers, the Federation of State and Municipal Employees, 
the  Association  of  Academics,  various  civil  society  organisations/NGOs  involved  in 
women’s  rights,  campaigning  against  sexual  abuse  and  violence  and  human  trafficking, 
and other civil society organisations working on gender equality.260 

 Other relevant bodies 

Article 24  of  the  new  GEA  No. 150/2020  provides  for  a  Gender  Equality  Council  –  a 
consultation platform and gender equality awards. The Gender Equality Council will meet 
at least once a year and will include representatives of the social partners, the academic 
community and gender equality organisations working within the provisions of the GEA. 
The role of the consultation platform is to advise the minister’s policy making on issues 
relating to gender equality; the minister will meet the GEC once a year. Article 25 of the 
new GEA No. 150/2020 provides for a gender  equality meeting to be  financed from the 
Treasury to be called every two years by the Prime Minister who decides the agenda. 

The state Treasury bears all the costs. 

 Evaluation of implementation 

The Gender Equality Complaints Committee issued 18 rulings in 2024 and found a violation 
in 3 cases. Nine cases were dismissed. 

 Remaining issues 

None. 

259  Act on equal status and equal rights irrespective of gender (GEA) No. 150/2021 (English translation): 

https://www.government.is/library/04-
Legislation/Act%20on%20Equal%20Status%20and%20Equal%20Rights%20Irrespective%20of%20Gender.
pdf; Act on the administration of matters concerning equality No. 151/2020 (English translation): 
https://www.government.is/library/04-
Legislation/Act%20on%20the%20Administration%20of%20Matters%20Concerning%20Equality.pdf. 

260  See: https://www.jafnretti.is/static/files/Gender_Equality_in_Iceland_2017.pdf. 

94 

 
 
 
 
 
 
 
 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

12  Overall assessment  

There are no particular transposition problems regarding Iceland’s compliance with EU law. 
The  overall  legislative  transposition  of  the  directives  is  satisfactory  while  the 
implementation may be subject to hindrances due to other factors such as barriers related 
to access to courts, legal costs and cumbersome processes as well as the social, political 
and economic environment. 

In  order  to  be  applicable  in  the  EEA,  EU  acts  have  to  be  incorporated  into  the  EEA 
Agreement, more specifically into one of its annexes or protocols. The amendments to the 
EEA Agreement are done by means of Joint Committee Decisions (JCDs). These decisions 
constitute  international  agreements  and  are  adopted  according  to  the  simplified 
procedures set out in the EEA Agreement.  

On 14 March 2024, the EEA Joint Committee decided to amend Annex XVIII (Health and 
safety  at  work,  labour  law,  and  equal  treatment  for  men  and  women)  to  the  EEA 
Agreement  (2024/1956).261  Directive  EU  2019/1158  of  the  European  Parliament  and  of 
the  Council  of  20  June  2019  on  work-life  balance  for  parents  and  careers  is  to  be 
incorporated  into  the  EEA  Agreement,  subsequently  repealing  Council  Directive 
2010/18/EU under the EEA Agreement, although this has not yet happened.262 It has been 
reviewed within the Ministry  of Social Affairs and Labour and passed  with constitutional 
reservation to the Ministry of Foreign Affairs as it is anticipated that it will call for legal 
amendments. Consultation with stakeholders on the labour market on how to transpose 
the Directive are ongoing and the results are expected in the spring of 2025.263  

Currently, violence against women ranks as the highest of all issues in relation to gender 
equality in Iceland. The law prohibits domestic violence primarily through the provisions 
of the Criminal Code that has been amended in line with the Istanbul Convention. In 2024, 
25 % of domestic violence cases occurred in the countryside and 75 % in the capital area 
where  64  %  of  the  population  lives;  64  %  of  these  cases  occurred  between  current  or 
former spouses or partners. This was a 2 % increase from previous years.264 

The law prohibits domestic violence primarily through the provisions of the Criminal Code. 
However,  violence  against  women  continues  to  be  a  problem.  The  penalties  can  range 
from a fine to 16 years in prison, depending on the type of violence committed. In addition, 
the law permits judges to increase the sentences of persons who commit violence against 
persons with whom they had a domestic relationship or other close bond. However, there 
were no domestic violence cases in which judges actually handed down heavier sentences 
and there is criticism that sentences are often too lenient. 

In December 2024 a district court handed down a judgment in a high-profile case where 
a man accused of serious domestic violence killed his wife whom he had been assaulting 
since 1999. He got 12 years in prison as there was no proof of premeditation.265 

Requests  for  restraining  orders  were  25  %  fewer  in  2024  than  in  previous  years.  The 
provisions on restraining orders, removal from household and stalking have been criticised 
for  their  infrequent  use.266  Ankle  bracelets  are  not  used  and  the  perpetrator  is  not 

261  Decision of the EEA Joint Committee No 74/2024 of 15 March 2024, https://eur-lex.europa.eu/legal-

content/EN/TXT/PDF/?uri=CELEX:22024D1596.  

262  Information obtained from the Ministry of Social Affairs on 18 February 2025. 
263  Information obtained from the Ministry of Social Affairs on 18 February 2025. 
264  https://www.logreglan.is/tilkynningum-um-heimilisofbeldi-faekkar-a-milli-ara/; 

https://www.logreglan.is/wp-content/uploads/2025/01/Heimilisofbeldi-BI-skyrsla-fyrir-ytri-vef-jan-des-
1.pdf. 

265  District Court of Northeast Iceland, judgment 9 December 2024, case No. S-295/2024. 
266  RUV (2023) ‘Surprised she hasn’t been charged more often’, 9 June 2023, 

https://www.ruv.is/frettir/innlent/2023-06-09-undrast-ad-ekki-hafi-verid-akaert-oftar-fyrir-umsaturseinelti. 

95 

 
 
 
 
 
Country report – Gender equality – Iceland – 2025 

necessarily removed from the home. Courts can issue restraining orders but there is an 
overall  complaint  (shared  by  the  police)  that  these  are  not  always  obeyed  in  practice. 
Some  reports  also  suggest  that  courts  set  the  bar  too  high,  diminishing  the  power  of 
restraining  orders  and  limiting  them  to  only  in  extreme  circumstances.  The  Icelandic 
judiciary  is  independent.  It  is  up  to  the  individual  judge  to  decide  whether  to  keep  a 
suspect in custody during a criminal investigation or to grant release pending trial. There 
is no bail system. 

Around  one  hundred  individuals  sought  help  from  Bjarkarhlíð,267  a  centre  for  victims  of 
violence due to stalking in 2024, and 160 because of cyber-harassment/violence. The rapid 
development of digital technologies has paved the way for abusers.  

According to the director of the Women’s Shelter, domestic violence does not appear to 
be taken as seriously as it should be given the risk of its escalation such that the violent 
behaviour becomes lethal. Victims of domestic violence are rarely active professionally or 
on  the  labour  market.  It  is  often  the  victims  who  are  stigmatised  rather  than  the 
perpetrators.  The  problem  is  ingrained  in  the  imbalanced  power  structure  of  society. 268 
However, according to the director of the Women’ Shelter, whereas 20 years ago, 64 % 
of women returned to their abusers after leaving the shelter, now only 11 % of the women 
go back to their abusers, as a result of improved support and services.269 

Homeless  women  are  particularly  vulnerable  and  repeatedly  subject  to  rape,  physical 
assault and other forms of violence. As noted by Grevio,270 emergency accommodation for 
the homeless is not suitable for women victims of violence, and even less so when they 
have children, as homeless shelters, even if they are only for women, often lack specific 
approaches and protocols for the prevention of violence and for the provision of protection 
and support to victims of domestic violence.  

The police maintain that there is growing awareness within the police about the serious 
impact of sexual violence and that they are working on increasing assistance to victims 
and to enhance transparency while cases are under investigation.271 

In  2024  there  has  been  growing  scepticism  and  criticism  of  the  equal  pay  certification 
system.  A  survey  by  the  Confederation  of  Icelandic  Enterprise  (SA)  in  September  2024 
reviewing the experience of managers regarding the effect of the equal pay certification 
shows that the perception is generally negative. There was an overall response rate of 31 
% (598 companies), out of which only 22 % had a positive view  of the procedure.  The 
main reasons stated for the negative perception concerned: the cost of implementing the 
standard; the procedure being cumbersome and time consuming; that certification did not 
serve a purpose given the nature of the firms; that it was not consistent with collective 
agreements;  and  that  the  assessments  were  too  frequent.  Furthermore,  the  procedure 
made it difficult to reward outstanding employees independent of their sex. The view of 
those  who  are  critical  of  the  system  is  that  the  equal  pay  certification  ought  not  to  be 
mandatory  but  optional.272  The  critics  maintain  that  the  benefit  of  the  system  is  highly 
questionable and also entails considerable cost. The implementation process is regarded 

267  Bjarkarhlíð website: https://bjarkarhlid.is/; Visir (2025) ‘News round-up’, 

https://www.visir.is/g/20252703436d/umsaturseinelti-attavilltur-ferdamadur-og-rektorskjor. 

268  RÚV News (2024) ‘Verdict sends a message that domestic violence is not as serious as other forms of 

violence’, 14 December 2024, https://nyr.ruv.is/frettir/innlent/2024-12-14-sendir-skilabod-ad-
heimilisofbeldi-se-ekki-jafn-alvarlegt-og-annad-ofbeldi-430979. 

269  BBC News (2024) ‘100 Women: 2024’, 3 December 2024, https://www.bbc.co.uk/news/resources/idt-

4f79d09b-655a-42f8-82b4-9b2ecebab611 

270  Grevio (2022) Baseline evaluation report: Iceland, https://rm.coe.int/grevio-inf-2022-26-eng-final-report-

on-iceland/1680a8efae. 

271  See: https://www.logreglan.is/fraedsla/ofbeldi/kynferdisofbeldi/. 
272  See: https://www.sa.is/en/frettatengt/frettir/jafnlaunavottun-mikill-kostnadur-litill-avinningur. The equal 
pay certification system was adopted with Act No. 56/2017 amending Article 19 of the GEA on wage 
equality and took effect on 1 January 2018. 

96 

 
Country report – Gender equality – Iceland – 2025 

as particularly cumbersome for smaller companies. At the end of 2023, the Centre Party 
(Miðflokkurinn) in a parliamentary resolution 273 proposed that the equal pay certification 
system should be abolished as the objective of closing the pay gap (with the aim of having 
eliminated it by 2022)274 had failed. In spite of the obligation for equal pay certification, a 
company which employs an average of 25–49 employees can choose to either undergo an 
equal pay certification or to receive an equal pay confirmation following the submission of 
documentation showing that its equal pay system and its implementation comply with the 
requirements of the Directorate of Equality. All the timeframes for the different categories 
of companies were postponed for 12 months. By the end of 2022 out of 1 094 firms and 
institutions only 443 had been accredited  while 651 companies and institutions had not 
yet obtained the accreditation.  

273  See: https://www.althingi.is/altext/154/s/0557.html; https://www.visir.is/g/20232490190d/vilja-leggja-

jafn-launa-vottunina-nidur. 

274  Reykjavik Grapevine (2018) ‘Iceland’s equal pay law sets new world standard’, 7 February 2018, 

https://grapevine.is/news/2018/02/07/9981264/. 

97 

 
 
 
Country report – Gender equality – Iceland – 2025 

Bibliography 

- 

- 

- 

- 

- 

- 

- 

Arnalds, Á.A. Eydal G.B.and Gislason,  I.V. (2022) ‘Paid Parental Leave in Iceland: 
Increasing  Gender  Equality  at  Home  and  on  the  Labour  Market’  in  de  la  Porte,  C. 
Eydal, G.B., Kauko, J., Nohrstedt, D. 't Hart, P., Sofus Tranøy, B. (eds), Successful 
Public Policy in the Nordic Countries, Oxford University Press, pp. 370-387. 

Directorate of Labour (2022) Annual Report regarding the Maternity/Paternity Leave 
https://vinnumalastofnun.is/media/3885/vms-arsskyrsla-
Fund 
faedingarorlofsjods-ens-080622.pdf. 

2021, 

Haraldsdóttir,  R.K.,  Rafnsdóttir,  G.L.,  and  Jónsdóttir,  G.A.  (2022),  ‘Að  sníða 
verkfærið að veruleikanum eða veruleikann að verkfærinu? Um jafnlaunastaðal og 
afnám kynbundinna launa’ (To tailor the tool to match reality or reality to match the 
tool?  On  the  equal  pay  certification  system  and  the  abrogation  of  the  gender  pay 
gap),  Icelandic  Review  of  Politics  and  Administration  (Stjórnmál  &  Stjórnsýsla), 
Vol. 18, No. 2. 

Hafsteinsdóttir, G.B., Kristjánsdóttir, E.S. and Christiansen, Þ. H. (2020) ‘“Þetta er 
allt  mannanna  verk”:  Upplifun  stjórnenda  á  áhrifum 
jafnlaunavottunar  á 
kjaraumhverfi’,  (Behind  every  system  are  people:  Managers’  experiences  of  the 
effect  of  the  Equal  Pay  Certification  on  Wage  Environment),  Icelandic  Review  of 
Politics and Administration, Vol. 16, Issue 2, December 2020.275  

Olafsson, A. and Steingrimsdottir, H. (2020) ‘How Does Daddy at Home Affect Marital 
Stability?’ The Economic Journal (2020) 130, 629. 

Stefansson,  K.  (2021)  ‘Men  in  Care:  Workplace  Support  for  Caring  Masculinities. 
Country  report: Iceland’. Report produced as part  of three-year project co-funded 
by the European Commission. 

Thorgeirsdottir,  H.  K.  (2019)  ‘Protection  from  victimisation  in  the  workplace: 
Comparative EU-Icelandic perspectives’, Equality Law Review 2019/1, pp. 44-59. 

275  Hafsteinsdóttir, G.B., Kristjánsdóttir, E.S. and Christiansen, Þ. H.: ‘“Þetta er allt mannanna verk”: Upplifun 
stjórnenda á áhrifum jafnlaunavottunar á kjaraumhverfi’, in Icelandic Review of Politics and Administration, 
Vol. 16, Issue 2, December 2020. See also: https://www.ruv.is/frett/2020/12/26/jafnlaunavottun-eykur-
skrifraedi-og-er-jafnvel-
talsyn?fbclid=IwAR1g0vx__9gSVtAxMm8ymAnqe0uzxUU2C9Y6c3USgCZEFyl0yn6zy0kmvF0; 
https://www.mbl.is/vidskipti/frettir/2020/12/27/jafnlaunavottun_se_mogulega_talsyn/. 

98 

 
 
 
 
 
 
 
 
GETTING IN TOUCH WITH THE EU 

In person 

All over the European Union there are hundreds of Europe Direct information centres. 
You can find the address of the centre nearest you at:  
https://europa.eu/european-union/contact_en.  

On the phone or by email 

Europe Direct is a service that answers your questions about the European Union.  
You can contact this service: – by freephone: 
00 800 6 7 8 9 10 11 (certain operators may charge for these calls), –  
at the following standard number: +32 22999696, or – by email via: 
https://europa.eu/european-union/contact_en. 

FINDING INFORMATION ABOUT THE EU 

Online 

Information about the European Union in all the official languages of the EU is available 
on the Europa website at: https://europa.eu/european- union/index_en.  

EU publications 

You can download or order free and priced EU publications from: 
https://publications.europa.eu/en/publications. Multiple copies of free publications may 
be obtained by contacting Europe Direct or your local information centre  
(see https://europa. eu/european-union/contact_en). 

EU law and related documents 

For access to legal information from the EU, including all EU law since 1951 in all the 
official language versions, go to EUR-Lex at: https://eur-lex.europa.eu/. 

Open data from the EU 

The EU Open Data Portal (http://data.europa.eu/euodp/en) provides access to datasets 
from the EU. Data can be downloaded and reused for free, for both commercial and non-
commercial purposes. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

PDF  

ISBN:  doi: