Download

Main Developments in Competition Law and Policy 2025 – Iceland

January 9, 2026

The year of 2025 was an eventful year for the development of Icelandic competition law. The Supreme Court of Iceland addressed critical issues, including the interpretation of settlements, and upheld a significant fine against the country’s largest retailer of telecom services for anti-competitive bundling practices. Also, the Competition Appeals Committee partly overturned the Icelandic Competition Authority’s (“ICA”) decision in a major cartel case, while the ICA imposed a substantial fine on the national power company for abusing its dominant position.

Following is a brief overview of the most important developments in Iceland in 2025. It is worth noting that Iceland is a member of the EEA Agreement (“EEA”) and Icelandic competition law therefore mainly mirrors EU competition law.

Cartels (sections 10 and 12 of the Icelandic Competition Act / Article 53 EEA)

Competition Appeals Committee – Samskip

In August 2023, the ICA found that Samskip, a company active on the transportation market, had unlawfully colluded with its main competitor, Eimskip, thereby violating both Article 10 of the Icelandic Competition Act and Article 53(1) of the EEA Agreement1. The ICA imposed a record breaking fine of 4.2 billion ISK on Samskip as well as structural measures. Samskip appealed the decision to the Competition Appeals Committee.

In March 2025, the Committee handed down its decision and reduced the fine to 2.4 billion ISK. While the ICA had characterized a broad range of commercial interactions between Samskip and Eimskip as collusive, such as container transportation between Iceland and Europe and Iceland and North America, land transportation and port services, the Committee rejected these claims. It also found no evidence that the alleged coordination regarding the changes to Samskip’s transport system and dealings with Alcoa amounted to illegal collusion. Similarly, allegations of coordinated surcharges were dismissed.

However, the Committee confirmed that Samskip and Eimskip exchanged sensitive information on certain occasions and agreed not to compete for each other’s largest clients. The Committee relied on indirect evidence such as minimal client movement between the companies and internal documents suggesting reluctance to poach each other’s customers.

Both the ICA and Samskip have filed lawsuits with the District Court of Reykjavík.

Supreme Court - Samskip

In May, the Supreme Court of Iceland confirmed the Court of Appeals annulment of a ruling by the District Court of Reykjavik which had previously found that Samskip had a legitimate interest to bring an appeal before the Competition Appeals Committee regarding the annulment of a certain provision in a settlement made between its main competitor, Eimskip, and the ICA2. Eimskip had admitted an unlawful collusion with Samskip and agreed to pay an administrative fine of 1.5 billion ISK. Eimskip had also accepted specific measures to promote competition. This included, among other things, to cease all business cooperation with Samskip as well as any other undertaking in any kind of transport service if Samskip also cooperated with the relevant undertaking.

The Supreme Court held that Samskip did not have a legitimate interest in receiving a substantive ruling by the Competition Appeals Committee about the legitimacy of this specific measure in the settlement. The Court emphasized that the ICA must be able to rely on the fact that a settlement concerning collusion represents the final resolution of the case with respect to the company settling and that the company will take the actions it has committed to. The Court also noted that obligations undertaken by a company to prevent further violations and promote effective competition should generally not be separated from other provisions of the settlement. The judgment also referred to the possibility that Samskip may file a complaint with the ICA if it believed that Eimskip’s refusal of certain transactions constituted abuse of its alleged dominant market position.

Daily fines imposed on the Association of Companies in the Restaurant Market (SVEIT)

In June, the ICA imposed daily fines of 1 million ISK on SVEIT for violating its legal obligation to provide documents to the Authority3. The ICA received a complaint regarding illegal price collusion among companies in the restaurant market and illegal price collusion within SVEIT and decided to initiate an investigation. It requested documents from SVEIT which it did not provide.

SVEIT appealed the decision to the Competition Appeals Committee and argued that the ICA lacked the power to investigate the alleged collusion and that its request was excessively broad. The Committee upheld the ICA’s decision in September as it considered that the investigation was still at an early stage making it impossible to conclude whether it related to matters outside the scope of the Competition Act.4

Abuse of dominance (section 11 of the Icelandic Competition Act / Article 54 EEA)

The Supreme Court holds that Síminn violated a settlement

In February, the majority of the Supreme Court held that Síminn, the largest retailer of telecom services in Iceland, had violated the conditions of a settlement between Síminn and the ICA from 20155, and ordered it to pay a fine in the amount of 400 million ISK. Síminn was found to have unlawfully bundled together electronic communications services and linear television services, namely the broadcasting of English Premier League football, in one package.

The majority of the Court held that Síminn’s pricing of the television service in question, as part of the package, had been anti-competitive and not in accordance with the settlement as it, inter alia, limited its competitors’ abilities to attract consumers. It held that subscribers to the package did not have the option to refuse access to the television channel while retaining other services except by canceling the subscription entirely. In the majority’s opinion purchasing individual services from Síminn would inevitably have resulted in a significant price increase.

The Court rejected Síminn’s argument that the wording of the settlement was unclear or that there was any ambiguity in its interpretation. In this regard, it was considered relevant that Síminn had requested the removal of the settlement’s conditions and given the detailed reasoning in the ICA’s decision to deny that request, the company should have been fully aware that the terms in question conflicted with the settlement’s conditions.

However, the Court found that the ICA had not adequately concluded whether Síminn’s conduct constituted a breach of another settlement concluded with the ICA in 2015. Consistent with the ruling of the Competition Appeals Committee, that part of the case was remitted to the ICA for further examination.

ICA imposes a fine on Landsvirkjun for abuse of dominance

In August, the ICA imposed a fine of 1.4 billion ISK on Landsvirkjun, the national power company of Iceland6. The ICA concluded that Landsvirkjun had abused its dominant position through its pricing of electricity in Landsnet’s tenders between 2017 and 2021. Landsnet is the transmission system operator of the Icelandic high-voltage power grid.

In its decision, the ICA held that Landsvirkjun had abused its dominant position in the market for electricity generation and wholesale through a margin squeeze in the market for electricity purchases related to transmission losses. In the ICA’s opinion, Landsvirkjun’s pricing in Landsnet’s tenders meant that its customers, who purchased electricity from Landsvirkjun and participated in Landsnet’s tenders in competition with Landsvirkjun, could only resell the electricity at a loss. Landsvirkjun’s conduct was found to have hindered new and smaller competitors from gaining a foothold in the electricity market, thereby preventing increased competition that would benefit businesses and consumers.

Landsvirkjun has appealed the decision to the Competition Appeals Committee, and a decision is expected later this year.

Merger control

The ICA continued to exercise its merger control powers actively. While one notable transaction was approved subject to behavioral commitments, most notified mergers in 2025 were cleared without an in-depth investigation.

Landsbankinn / TM

In November, the ICA approved Landsbankinn’s acquisition of TM7. Landsbankinn is the country’s largest commercial bank while TM is its third largest insurance company. The ICA’s investigation revealed that TM’s market share had been declining for several years, and the new ownership structure was expected to create scope and incentives for increased competition in the market. Consequently, the merger was approved subject to a settlement under which Landsbankinn committed to ensuring that special terms on TM insurance would not be conditional upon the customer’s salary being paid into an account with the bank. The ICA considered such practices likely to restrict smaller competitors’ opportunities for growth and survival and potentially exclude them from competing for a significant share of customers in the general banking services market.

Outlook for 2026

The year of 2026 promises to be an exciting year for competition law in Iceland. Several high-profile cases are pending before the Competition Appeals Committee and Icelandic courts which will no doubt have important implications for future investigations and competition law developments. At the same time, the ICA is expected to maintain its robust approach to merger control, with rigorous scrutiny of pending transactions across multiple markets.

Disclaimer: Note that both Jonsson & Hall Law Firm and the contributor have acted as legal advisors and litigated in cases herein detailed. Any opinions or conclusions provided in this blog entry shall not be ascribed to Jonsson & Hall Law Firm or any clients of the firm.