Freedom on the Net 2022 - Iceland

/ 100
Obstacles to Access 25 / 25
Limits on Content 34 / 35
Violations of User Rights 36 / 40
96 / 100 Free
Scores are based on a scale of 0 (least free) to 100 (most free). See the research methodology and report acknowledgements.


Iceland remained the world’s best protector of internet freedom during the coverage period. Users in this island country enjoy near-universal connectivity, minimal restrictions on online content, and strong protections for their rights online.

Iceland is a parliamentary democracy with a long history of upholding political rights and civil liberties. Current challenges include potentially inappropriate links between business interests and politicians, media consolidation, and conditions for immigrants.

Key Developments, June 1, 2021 - May 31, 2022

  • In May 2022, Iceland’s three major mobile providers signed a cooperation agreement with the government and the national 112 crisis line to expand fourth-generation (4G) or fifth-generation (5G) coverage in areas with lower levels of mobile connectivity (see A2).
  • People continued to use social media platforms for social and political activism, as users organized protests on Facebook against the Russian invasion of Ukraine in February 2022 (see B8).
  • Two media sites were briefly disrupted by distributed denial-of-service (DDoS) attacks in April 2022, marking the first cyberattack against media sites in several years (see C8).

A Obstacles to Access

A1 0-6 pts
Do infrastructural limitations restrict access to the internet or the speed and quality of internet connections? 6 / 6

With near-ubiquitous access, Icelanders are frequent internet users. According to 2021 data from Eurostat, 100 percent of the population uses the internet (99 percent within the last three months of the year), and 98 percent of households have internet connections.1 Iceland’s fixed broadband penetration rate was 41.6 percent in 2020, the most recent year for which data are available, according to the International Telecommunication Union (ITU);2 its mobile broadband penetration rate was 122.9 percent.3

Iceland continues to enhance its ICT infrastructure. In the first half of 2020, the majority of the population using the internet was connected via fiber-optic cable (68.6 percent) while a shrinking number remained connected via digital subscriber line, or DSL, technology (30.6 percent).4 The government’s Iceland Optical Connected initiative, which aims to provide citizens with fixed-lined connections of at least 100 megabits per second (Mbps) by 2020, has driven the development of fiber-optic cables.5 In May 2020, the government announced that it had allocated ISK 400 million ($3.1 million) toward realizing this goal.6 In March 2021, the government announced the final phase of the Iceland Optical Connected initiative, where a further ISK 180 million ($1.4 million) will be available as grants to local municipalities.7

Both third-generation (3G) and 4G mobile coverage is extensive. Many mobile operators are working to develop 5G networks.8 At least three mobile service providers have received permission from the Post- og Fjarskiptastofa (Post and Telecom Administration, or PTA) to develop 5G networks, which the PTA says must serve at least 25 percent of the population by 2021.9 In May 2020, Nova became the first mobile operator in Iceland to offer 5G to its customers.10 The PTA anticipates that 5G will become broadly available by 2022 or 2023.11

Public Wi-Fi hotspots are widely available throughout the country.12

In 2021, the average fixed broadband download speed in Iceland was 191.83 Mbps, according to the analytics company Cable.13 The PTA’s 2021 data show that 97.9 percent of fixed broadband internet subscribers enjoy advertised download speeds of 30 Mbps or more.14

Winter storms sometimes lead to power outages in more remote parts of the country that may temporarily disrupt connectivity for people living in these areas. An unusually powerful storm in December 2019 temporarily disrupted telecommunications in parts of the Eastern, Northeastern, Northwestern, and Westfjords regions.15

A2 0-3 pts
Is access to the internet prohibitively expensive or beyond the reach of certain segments of the population for geographical, social, or other reasons? 3 / 3

There are no major digital divides in Iceland. Internet connections are relatively affordable. According to Cable, the average monthly cost of a fixed broadband subscription was $68.68 in 2021, while 1 gigabyte (GB) of mobile data cost $1.23 on average.16 These averages are slightly lower relative to 2019 price data collected by Cable. According to 2020 ITU data, a monthly high-speed fixed broadband subscription cost 1.2 percent of gross national income (GNI) per capita, while a monthly mobile subscription offering 1.5 GB of data cost 0.4 percent of GNI per capita.17

Historically, there are no significant differences in penetration rates and access in terms of geography, gender, or education levels.18

In May 2022, the country’s three major mobile providers (Nova, Vodafone, and Síminn) signed a cooperation agreement with Iceland’s crisis line, 112, and the government to increase mobile service in areas with low levels of mobile connectivity. The government will pay for the installation of at least 12 cell phone towers, which will provide either 4G or 5G coverage, though 30 others were being considered at the time of the announcement.19

A3 0-6 pts
Does the government exercise technical or legal control over internet infrastructure for the purposes of restricting connectivity? 6 / 6

There are no government-imposed restrictions on connectivity in Iceland, and the government does not exercise technical or legal control over the ICT infrastructure. According to Article 72 of the Electronic Communications Act, the government can “close” or “restrict” the internet “in times of hostilities” or during emergencies.20

Iceland has multiple channels connecting the country to the international internet, including connections to the international backbone through four submarine cables. Two cables connect Iceland with Greenland and Canada: Greenland Connect (2009) and the 25-year-old CANTAT-3 from Canada. Two other cables connect Iceland to Europe: FARICE-1 (2003) and DANICE (2009). In May 2022, work began on IRIS, a high-speed submarine cable connecting Iceland and Ireland. IRIS is expected to be fully operational by the end of 2022.21

The Reykjavik Internet Exchange Point (IXP), which exchanges internet traffic among internet service providers (ISPs) located in Iceland, is operated independently of the government by the country’s top-level domain registry ISNIC.

A4 0-6 pts
Are there legal, regulatory, or economic obstacles that restrict the diversity of service providers? 6 / 6

There are no obstacles for service providers to operate in Iceland, and the ICT market is competitive and relatively diverse. Service providers need to register with the PTA prior to commencing their operations, but registration is a formality.22

Of all the ISPs in the first half of 2021, Síminn held the largest market share (44.8 percent), followed by Vodafone (27.4 percent), Nova (15.6 percent), and Hringdu (9.3 percent), according to PTA data.23 Among mobile operators, Síminn led the market in terms of total subscriptions (36.4 percent), followed by Nova (33.0 percent) and Vodafone (26.4 percent).24

A5 0-4 pts
Do national regulatory bodies that oversee service providers and digital technology fail to operate in a free, fair, and independent manner? 4 / 4

The PTA, an independent entity under the Ministry of Transport and Local Government, is the main regulatory body governing telecommunications. It supervises development, logistics, and fair competition in the telecommunications field. PTA decisions may be appealed to the Rulings Committee for Electronic Communications and Postal Affairs, which consists of three people appointed by the Minister of Transport and Local Government. They, along with the third member of the Rulings Committee, are appointed to four-year terms.25 The Rulings Committee’s decisions may be appealed in court.

The Icelandic Competition Authority (ICA) is an independent administrative body that oversees mergers, acquisitions, and other moves in the ICT market.26 It is composed of three board members appointed by the Minister for Industries and Innovation; the board members then select a director.

B Limits on Content

B1 0-6 pts
Does the state block or filter, or compel service providers to block or filter, internet content, particularly material that is protected by international human rights standards? 5 / 6

Political, social, and religious websites are not blocked in Iceland. Social media platforms such as YouTube, Twitter, Facebook, and international blog hosting services are freely available and used by a large part of the population. However, some websites are blocked for hosting copyrighted content.

In October 2018, the Supreme Court of Iceland upheld a 2014 Reykjavík District Court decision that ordered ISPs Hringdu and Vodafone to block the file-sharing website the Pirate Bay and the largest Icelandic torrent website Deildu.27 The court order came after the music rights group Composers Rights Society of Iceland (STEF) and Iceland’s motion picture association SMAIS reported the websites to police in 2013 for copyright infringement and pirated material. 28 An agreement was later reached between rights holders and ISPs that gave ISPs the authority to block any new links related to the Pirate Bay and Deildu without additional court orders.29 It is not known how many links were blocked under this agreement.

Pornography in general is illegal in Iceland,30 although the ban is not strongly enforced, and online pornography is neither blocked nor specifically banned.31

ISPs in Iceland filter websites containing child sexual abuse imagery. Icelandic ISPs collaborate with Barnaheill—Save the Children Iceland, a local nongovernmental organization (NGO) focused on curbing child abuse, and participate in the International Association of Internet Hotlines (INHOPE) project, which solicits reports of illegal content.32

B2 0-4 pts
Do state or nonstate actors employ legal, administrative, or other means to force publishers, content hosts, or digital platforms to delete content, particularly material that is protected by international human rights standards? 4 / 4

In general, online content is not subject to deletion, and government requests to remove online content are rare.

Between July and December 2021, however, Facebook reported restricting access to 91 items in Iceland for violating local law. Google reported receiving one government request to remove content during a similar period, for privacy and security reasons, but did not comply.33 There were no public reports of the government ordering the removal of content during the previous coverage period. 34

Content is sometimes removed under the right to be forgotten. During the coverage period, Google de-indexed 220 URLs in Iceland,35 while in the second half of 2021, Microsoft reported no de-indexed URLs.36

ISNIC, Iceland’s main domain registrar, rarely closes domains based on a site’s content. However, ISNIC acted after the neo-Nazi website The Daily Stormer appeared with an .is domain name in 2017.37 The website reportedly lost its Icelandic web address based on a technicality, as its publisher failed to provide accurate registration information such as proof of identity and address.38

B3 0-4 pts
Do restrictions on the internet and digital content lack transparency, proportionality to the stated aims, or an independent appeals process? 4 / 4

In general, legal restrictions on the internet and digital content are transparent, proportionate, and subject to judicial oversight. There are no specific laws mandating the blocking of websites or the removal of content.39 When websites have been blocked or content has been removed, it has usually been done by court order pursuant to civil or criminal law.

Chapter V of Icelandic Law No. 30/2002 establishes a system of takedown notices for online content that violates the law, in accordance with Directive 2000/31/EC (the E-Commerce Directive) of the European Parliament.40 The Ministry of Transport and Local Government is responsible for handling matters related to online content, and there is judicial oversight over the appeals process for disputing content removal.41

Under Iceland’s Data Protection Act, the country’s Data Protection Authority may administratively order the deletion of content that, for example, violates the right to privacy.42

ISPs and content hosts are not held legally liable for the content that they host or transmit. However, according to Icelandic law, domain registrants are responsible for ensuring that the use of their domains is within the limits of the law.43 Claims regarding intellectual property rights are handled by the Icelandic Patent Office, which is dependent on international cooperation; Iceland is party to a number of international agreements in this field.

In May 2021, the parliament adopted a bill that empowers the courts to order the closure of .is domains involved in criminal activities or in disseminating illegal material.44

B4 0-4 pts
Do online journalists, commentators, and ordinary users practice self-censorship? 4 / 4

Self-censorship is not a widespread problem online, though some degree of self-censorship in the news media has been reported in the past.45

B5 0-4 pts
Are online sources of information controlled or manipulated by the government or other powerful actors to advance a particular political interest? 4 / 4

Government or partisan manipulation of online content is not a major issue.

In April 2020, the government set up a working group “to map the manifestations and extent of information chaos in connection with COVID-19 in Iceland and to make proposals for measures to combat it.”46 A subsequent memo suggested that the working group would be involved in evaluating information about COVID-19 in the mass media and on social media platforms.47 The move drew criticism from politicians and pundits, who questioned its necessity and argued that it could lead to censorship.48 The working group did not appear to seek to manipulate online information during the coverage period, as indicated by the report it released in October 2020 on information sources about COVID-19 (see B7).49

In March 2019, the Supreme Court upheld an October 2018 appellate decision to lift an injunction that prevented specific reporting by the newspaper and online site Stundin.50 In October 2017, two weeks before parliamentary elections, Glitnir Bank, which failed during the 2008 financial crisis, secured a legal injunction preventing Stundin from reporting on the bank’s links with then Prime Minister Bjarni Benediktsson. Stundin then fought the injunction in court, but it remained in effect through the elections.

B6 0-3 pts
Are there economic or regulatory constraints that negatively affect users’ ability to publish content online? 3 / 3

There are no undue economic or regulatory limitations on publishing content online. European Union (EU) regulations on net neutrality and equal access to the internet were implemented as an amendment to Article 41 of the Electronic Communications Act in 2018.51

B7 0-4 pts
Does the online information landscape lack diversity and reliability? 4 / 4

Iceland has a vibrant digital sphere, and almost all traditional media, including print, radio, and television, offer versions of their content online. In 2019, the use of social media platforms was higher in Iceland than in any other country in the European Economic Area (EEA).52

The working group on COVID-19 misinformation (see B6) found that Icelanders overwhelmingly trusted national media, health professionals, and the government’s website over social media for information about the pandemic. More than three-quarters of the over 800 people surveyed as a part of the report indicated that they had encountered misinformation about COVID-19 on social media.53

B8 0-6 pts
Do conditions impede users’ ability to mobilize, form communities, and campaign, particularly on political and social issues? 6 / 6

Digital tools, including social media platforms, are widely used for social, political, and civic activism. Demonstrations and events are frequently organized on Facebook in particular. For example, people used the platform to organize protests against the Russian invasion of Ukraine in February 2022.54

An online platform created in February 2018 has allowed individuals to easily provide their input on draft laws.55 Since the platform’s launch, hundreds of draft laws, regulations, and policy papers have been published for consultation, generating thousands of open responses from stakeholders and members of the general public.56

In the wake of the Icelandic financial crisis in 2008, social media served as a vital platform for citizens to demand an extensive review of the country’s constitution.57 A 25-member council consisting of ordinary residents helped draft a new constitution and worked through 16 versions in 4 months based on 16,000 comments from users across platforms such as Facebook, Twitter, and YouTube.58 The draft constitution has been stalled in Parliament since 2012,59 though support remains high; as of July 2021, 53 percent of people polled by Gallup supported the draft produced by the council.60

C Violations of User Rights

C1 0-6 pts
Do the constitution or other laws fail to protect rights such as freedom of expression, access to information, and press freedom, including on the internet, and are they enforced by a judiciary that lacks independence? 6 / 6

Freedom of expression is protected under Article 73 of the constitution and by the country’s independent judiciary.61 The Icelandic Media Law, which came into effect in 2011, established several legal protections for journalists that extend to the online sphere, including protection of anonymous sources and editorial independence from owners of media service providers.62

In recent years, the government has pursued several initiatives to enhance internet freedom. In 2010, the parliament approved a resolution—the Icelandic Modern Media Initiative—that articulated the country’s intention to become a global “safe haven” offering legal protection, including from “libel tourism,”63 to journalists, publishers, and whistleblowers.64 To implement this resolution, the nonprofit International Modern Media Institute (IMMI) was founded.65 The IMMI’s work, however, has been stalled in recent years. In May 2020, Parliament finally approved a law protecting whistleblowers from retaliation.66 However, other elements of the Icelandic Modern Media Initiative remain unimplemented.

C2 0-4 pts
Are there laws that assign criminal penalties or civil liability for online activities, particularly those that are protected under international human rights standards? 3 / 4

Despite having strong protections for free speech, Iceland criminalizes certain online activities under its penal code. Both defamation and insult are criminal offenses subject to fines or prison sentences of up to one year.67 Article 233(A) of the penal code also prescribes two years of imprisonment for publicly denigrating a person or group on the basis of “nationality, color, race, religion, sexual orientation or gender identity.”68

In a positive change, blasphemy was repealed as a criminal offense under Article 125 of the penal code in 2015. It had carried penalties of fines or imprisonment for up to three months.69

According to Article 51 of the Media Law, journalists cannot be held responsible for potentially libelous quotes from sources, but they can be held responsible for libel in their own content.70

In March 2018, in an effort to restart the Icelandic Modern Media Initiative, the prime minister appointed an expert committee tasked with improving legislation concerning freedom of expression, media, and information.71 The committee reviewed earlier bills and drafted new ones in line with its mandate. The committee delivered five bills to the government in 2018 (aimed at reducing compensation for defamation claims, narrowing the definition of criminal hate speech, narrowing the intermediary liability of ISPs, protecting civil servants’ freedom of expression, and removing data retention requirements) and four additional bills in 2019 (concerning freedom of information, whistleblower protections, injunctions on publication, and amending the Media Law regarding the responsibility of journalists). All were presented for consultation online.72 Aside from the whistleblower protection bill (see C1), none of these measures were enacted during the coverage period.

C3 0-6 pts
Are individuals penalized for online activities, particularly those that are protected under international human rights standards? 6 / 6

Internet users are periodically prosecuted but rarely penalized for their online activities. The coverage period saw no notable civil or criminal cases for online expression.

C4 0-4 pts
Does the government place restrictions on anonymous communication or encryption? 4 / 4

The government does not place restrictions on anonymous communication. No registration is required when purchasing a SIM card.73 Users can freely use encrypted tools, and there are no laws requiring decryption or the disclosure of encryption keys.

C5 0-6 pts
Does state surveillance of internet activities infringe on users’ right to privacy? 6 / 6

Users are generally free from state surveillance, which is regulated under the Telecommunications Law74 and a set of rules issued in 2006.75 According to data disclosed by the public prosecutor’s office, police requested phone usage data or other related surveillance techniques a total of 388 times in 2020, with phone usage data specifically requested 92 times.76

The government launched a voluntary contact tracing app called Rakning C-19 in April 2020 as part of its response to COVID-19.77 The app tracks users’ movements, storing this geolocation data on their mobile devices. State authorities can then request that users share the data. The app’s code was inspected by a member of Parliament from the Pirate Party, who confirmed that “the necessary measures have been taken so that authorities can only access information with the permission of each individual.”78 By May 2020, 38 percent of the population had downloaded Rakning C-19.79

In May 2021, Rakning C-19 was updated to allows users to enable Bluetooth contact tracing rather than geolocation tracking. Alma Möller, the director of Iceland’s healthcare agency, stated that the changes allow authorities to trace potential exposures without compromising privacy.80

According to the 2013 revelations that the United States and allied intelligence agencies had been collecting and storing massive amounts of user data from global online communications, Iceland has cooperated with the activities of the Five Eyes—the intelligence alliance between the United States, the United Kingdom, Australia, Canada, and New Zealand.81 It is not clear whether that cooperation extended into the coverage period.

C6 0-6 pts
Does monitoring and collection of user data by service providers and other technology companies infringe on users’ right to privacy? 4 / 6

Internet users are protected by a strong data protection law, although the government has set data retention requirements. In July 2018, Iceland’s Act on Data Protection and the Processing of Personal Data entered into force; among other things, it implements the EU’s General Data Protection Regulation (GDPR).82

A 2005 amendment83 to the Electronic Communications Act of 2003 implements data retention requirements.84 The law applies to telecommunications providers and mandates the retention of user data, including browsing history, for six months.85 It also states that companies may deliver user data only in criminal cases or on matters of public safety and that such information may be given only to the police or the public prosecutor.86

C7 0-5 pts
Are individuals subject to extralegal intimidation or physical violence by state authorities or any other actor in relation to their online activities? 5 / 5

Users were not subjected to extralegal intimidation or physical violence by state authorities or other actors in relation to their online activities during the coverage period.

C8 0-3 pts
Are websites, governmental and private entities, service providers, or individual users subject to widespread hacking and other forms of cyberattack? 2 / 3

Score Change: The score declined from 3 to 2 because media sites were disrupted by cyberattacks during the coverage period, after several years of reprieve.

Government entities and media sites are rarely subjected to cyberattacks as of recent years, though private companies and ordinary users are occasionally targeted.

Though rare, cyberattacks against media sites do sometimes occur. In April 2022, the websites of the Icelandic National Broadcasting Service (RÚV) and Icelandic newspaper DV experienced temporary disruptions after being targeted with distributed denial-of-service (DDoS) attacks. The attacks rendered the DV website fully inaccessible multiple times, while the disruptions to the RÚV were minimal.87

In October 2021, Reykjavík University reported that its mail servers for employee emails had been hacked. A letter demanding a ransom of $10,000, under threat of publishing university employees’ emails, had been left on the server.88

In September 2021, Iceland’s financial sector was hit by a substantial DDoS attack. Although companies that were subject to the attack claimed that no user data was stolen, most payment services were disrupted for about one hour.89

In December 2021, Strætó, the public transportation company, was the subject of a cyberattack by foreign hackers. The hackers involved threatened to leak user data if Strætó did not pay a requested fee. Compromised data included contact and personal information belonging to current and former Strætó employees.90

The National Computer Security Incident Response Team (CERT-ÍS), operating within the PTA, is the national point of contact for critical cybersecurity incidents.91 In 2015, the Ministry of the Interior published an ICT security policy that aimed to increase resilience for, raise awareness about, and expand collaboration with international organizations on cybersecurity issues.92 The PTA also operates a website with cybersecurity advisories for the public.93