Icelandic DPA
Act on Data Protection and the Processing of Personal Data No. 90/2018
Key Facts
Effective Date
July 15, 2018
Enacted
June 27, 2018
Enforcing Authority
Persónuvernd (Icelandic Data Protection Authority)
Consent Model
Opt-in
Applies To
Any entity storing or accessing information on terminal equipment of users in Iceland
Overview
Iceland implements the GDPR through Act 90/2018 as part of its EEA obligations. While Iceland follows EU data protection standards, its penalty structure differs — capped at 2% of turnover rather than the EU's 4%. Persónuvernd can impose both one-time fines and daily penalty fines for ongoing non-compliance.
What This Means for Your Website
- Informed consent is required before placing non-essential cookies on Icelandic visitors
- Visitors must be informed about cookie usage and provided an option to refuse
- Daily fines of up to ISK 200,000 can accumulate for ongoing non-compliance
- Administrative fines range from ISK 100,000 to ISK 1.2 million, or up to 2% of worldwide turnover
Key Requirements
Persónuvernd enforces Act 90/2018 with both one-time administrative fines and daily penalty fines. The penalty cap of 2% of turnover is lower than the EU's 4%, reflecting Iceland's EEA (rather than EU) membership. Persónuvernd has particularly focused enforcement on protecting children's data.
How ConsentStack Handles This
ConsentStack detects Icelandic visitors and presents a GDPR-compliant opt-in consent banner with clear information and refusal options, meeting Act 90/2018 requirements.
Penalties
Daily fines up to ISK 200,000. Administrative fines ISK 100,000 to ISK 1.2 million, or up to 2% of total worldwide annual turnover.
Maximum Fine
ISK1,200,000 aggregate
Revenue-based
2% of annual revenue
Key Requirements
- Informed consent before placing non-essential cookies
- Users must be informed about cookie use
- Option to refuse cookies must be provided
- Strictly necessary exemption for essential cookies
- Consent must align with GDPR standards
Notable Provisions
- Lower maximum penalty cap (2% turnover vs EU 4%)
- Daily fines up to ISK 200,000 for ongoing non-compliance
- EEA member but not EU member state
- Persónuvernd focused on protecting children's data
Other ePrivacy Directive Related Regulations
Loi Informatique et LibertésFrance
France has the most actively enforced cookie regime in Europe. CNIL issued 259 corrective decisions in 2025, with cookie-specific fines totaling EUR 486.8 million including EUR 325M against Google. A Refuse all button or Continue without accepting must appear on the first layer.SI 336/2011Ireland
Ireland implements the ePrivacy Directive through SI 336/2011. The DPC is the lead supervisory authority for major tech companies headquartered in Ireland including Meta, Google, Apple, and Microsoft. Uniquely, cookie consent is limited to 6 months and must then be refreshed.TDDDGGermany
Germany implements the ePrivacy Directive through Section 25 of TDDDG (renamed from TTDSG in May 2024). A Consent Management Ordinance (EinwV) became effective April 2025, establishing a voluntary framework for recognized consent management services. Cookie banners must not obscure website content.Dutch Telecom ActNetherlands
The Netherlands implements the ePrivacy Directive through Article 11.7a of the Telecommunications Act. The AP launched a major enforcement sweep in April 2025, warning 50 organizations for misleading cookie banners or placing tracking cookies without consent. Cookie walls are not permitted.Italian Privacy CodeItaly
Italy implements the ePrivacy Directive through Article 122 of the Privacy Code with detailed Garante cookie guidelines effective January 2022. Only technically necessary cookies may load by default. Scrolling is not valid consent, and closing a banner with "X" closes it without granting consent.LSSISpain
Spain implements the ePrivacy Directive through Article 22 of the LSSI. Cookie violations are classified as slight offenses with EUR 30,000 fines per URL, but multiple URLs multiply penalties. AEPD allows consent-exempt analytics under privacy-friendly configurations, similar to CNIL.Danish Cookie OrderDenmark
Denmark implements the ePrivacy Directive through the Cookie Order (Cookiebekendtgørelsen), administered by the Danish Business Authority. Cookie consent is a declared 2026 enforcement priority for Datatilsynet, which will examine whether Danish websites give users a genuine choice.Portuguese ePrivacy LawPortugal
Portugal implements the ePrivacy Directive through Law 41/2004, with a distinctive tiered penalty structure distinguishing between large companies, SMEs, and natural persons. The CNPD issued 90 fines totaling EUR 559,950 in 2023, demonstrating active enforcement.Polish Telecommunications LawPoland
Poland implements the ePrivacy Directive through Articles 173-174 of the Telecommunications Law. While Article 173(2) technically permits consent via browser settings, PUODO recommends active consent. Since 2019, Article 174 requires cookie consent to meet full GDPR standards.Norwegian E-Com ActNorway
Norway's January 2025 amendment to Ekomloven marked a major shift from tolerating passive consent to strict opt-in. Pre-ticked boxes and browser settings are now explicitly invalid. Accept and reject options must have equal prominence. Datatilsynet sanctioned 6 websites for tracking pixel violations.Belgian E-Communications ActBelgium
Belgium enforces strict cookie consent with one of the EU's most active DPAs. Cookie walls are prohibited, and a Reject all button must appear on the first layer with equal prominence to Accept all. Dark patterns in cookie banners are actively enforced against.LEKSweden
Sweden implements the ePrivacy Directive through Chapter 9 Section 28 of LEK. In April 2025, IMY issued a landmark reprimand against Aller Media for dark patterns in cookie banners. Less than 25% of Swedish users accept cookies, reflecting strong privacy awareness.Other Europe Regulations
GDPREuropean Union + EEA
The GDPR sets the global standard for data protection, requiring explicit opt-in consent before processing personal data of EU/EEA residents. For websites, non-essential cookies must be blocked until visitors actively consent. Pre-ticked boxes and implied consent are invalid.PECRUnited Kingdom
PECR is the UK's cookie-specific law, requiring consent before storing or accessing cookies. The DUAA 2025 significantly increased penalties from GBP 500,000 to GBP 17.5 million and introduced analytics exceptions on an opt-out basis. Only strictly necessary cookies are exempt.ePrivacy DirectiveEuropean Union + EEA
Article 5(3) of the ePrivacy Directive is the primary EU legal basis requiring cookie consent. It mandates prior informed consent before storing or accessing any information on a user's device, with narrow exceptions only for transmission necessity and explicitly requested services.Loi Informatique et LibertésFrance
France has the most actively enforced cookie regime in Europe. CNIL issued 259 corrective decisions in 2025, with cookie-specific fines totaling EUR 486.8 million including EUR 325M against Google. A Refuse all button or Continue without accepting must appear on the first layer.UK GDPRUnited Kingdom
The UK GDPR is the retained EU GDPR post-Brexit, with consent standards identical to the EU version. The UK adequacy decision was renewed December 2025, valid until December 2031. Combined with PECR, it forms the legal framework for cookie consent in the UK.TDDDGGermany
Germany implements the ePrivacy Directive through Section 25 of TDDDG (renamed from TTDSG in May 2024). A Consent Management Ordinance (EinwV) became effective April 2025, establishing a voluntary framework for recognized consent management services. Cookie banners must not obscure website content.Frequently Asked Questions
Does Iceland follow GDPR cookie rules?
Yes. Iceland implements the GDPR through Act 90/2018 as an EEA member. Cookie consent requirements align with EU standards, though the penalty cap is 2% of turnover versus the EU's 4%.
What are the cookie penalties in Iceland?
Administrative fines of ISK 100,000 to ISK 1.2 million or up to 2% of worldwide turnover, plus daily fines of up to ISK 200,000 for ongoing non-compliance.
Who enforces cookie laws in Iceland?
Persónuvernd (Icelandic Data Protection Authority) enforces Act 90/2018 with both one-time and daily penalty fines.
Stay compliant with Icelandic DPA
ConsentStack helps you implement Opt-in consent for Iceland automatically.