The Iceland Chamber of Commerce reviewed the draft regulation on primary healthcare and supports its objective of levelling the playing field between publicly and privately operated primary care. The Chamber emphasises that the regulation should form part of broader reforms to the operating environment of primary care centres — covering funding, diagnostic services, and oversight — so that competition can contribute to better access and higher quality.

The Iceland Chamber of Commerce has reviewed the draft regulation on primary healthcare. The regulation emphasises clarifying the core services of primary care centres and thereby improving public access to primary healthcare. A stated objective of the regulation is also to level the playing field between publicly and privately operated primary care through harmonised rules governing their services and operations irrespective of ownership model.
The Chamber wholeheartedly supports the regulation's objective of levelling the playing field between publicly and privately operated primary care in order to improve public access to primary healthcare, including by unifying the rules on services and operations irrespective of ownership model. The Iceland Chamber of Commerce has previously pointed out that unequal operating conditions between public and private primary care have reduced competition, innovation, and output in the system. The Chamber's March 2026 review found that privately operated primary care centres serve a large share of patients in the capital region, are on average measured as more cost-efficient, and enjoy higher user satisfaction.[1]
The Iceland Chamber of Commerce considers it positive that the draft regulation includes changes that promote a clearer separation of central functions from the operation of individual primary care centres — among other things by placing the professional council under the Directorate of Health and abolishing the development unit that previously came under the Primary Health Care of the Capital Area. Such changes are in line with the views the Chamber has previously emphasised on separating regulation from operations, ensuring equal treatment between operators, and reducing structural conflicts of interest that can arise when the same body is responsible both for operations and for central administrative or developmental roles. They can thus help primary care centres operate on comparable terms and create a more solid basis for effective competition on more equal operating conditions, which is conducive to better patient care.
It is likewise positive that central services are specifically defined in the draft regulation and that the minister determines their arrangement separately, since such a separation promotes greater transparency and equal treatment between operators. For these objectives to be met, however, it is important that the powers of the Directorate of Health are clearly delimited and that this delimitation is unambiguously reflected in the regulation, so that the Directorate can carry out its supervisory and professional role objectively towards all operators without overlap arising between central administration and operations. It is further important to continue ensuring effective and equal participation by primary care centres, irrespective of ownership model, in the work of the professional council.
Notwithstanding the above, the Iceland Chamber of Commerce considers it important that the regulation form part of broader reforms to the operating environment of primary care centres. To achieve the government's objectives of shorter waiting times and better access in primary care, work is also needed on reforms to the funding system, the organisation of services, digital development, and the strengthening of specialist training in family medicine.
The Icelandic Competition Authority has repeatedly pointed out that the operating conditions of privately and publicly operated primary care centres are not comparable and has called for measures to level the playing field. The Authority's recommendations have concerned, among other things, equalising terms for diagnostic services; separating payments for central services provided from the operations of the Primary Health Care of the Capital Area in order to prevent distorted incentives; harmonising oversight of service providers irrespective of ownership model; ensuring equal access to specialist trainee doctors; taking account of privately operated centres' costs arising from patient insurance in the funding model; and harmonising VAT refunds between ownership models. The Competition Authority first raised these points in 2017 and reiterated them in 2021 and 2022, the authorities having failed to respond adequately.[2]
In light of the above, the Iceland Chamber of Commerce considers it important that work continue on levelling the operating conditions of primary care centres irrespective of ownership model — including as regards funding, diagnostic services, patient insurance, VAT, access to specialist trainee doctors, and oversight. Conditions must also be created for greater competition and more diverse ownership models, so that more parties can take part in developing primary care on an equal footing. It is further important to develop the funding system so that it reflects to a greater degree the services actually provided, along with access, quality, and outcomes. In the Chamber's assessment, such reforms are a prerequisite for competition to contribute to better access, higher quality, and more efficient use of public funds.
[1] See the Iceland Chamber of Commerce review (March 2026) “Kerfislægur kvilli”. URL: https://vi.is/skodanir/kerfislaegur-kvilli
[2] Icelandic Competition Authority (2025). Primary care centres – case closure letter and recommendations reiterated, with a request for further dialogue. URL: https://www.samkeppni.is/wp-content/uploads/2025/12/Heilsugaeslustodvar-malslokabref-og-tilmaeli-arettud-12112025.pdf
This article was automatically translated from the Icelandic original.