Can we record simulated calls in Iceland?

Not silently, on the default rule. The electronic communications act requires a party who wishes to record to notify the other party at the beginning of the call. The only exception is where awareness may unequivocally be assumed, which points at documented standing disclosure rather than at saying nothing.

Can we use an AI voice agent for calls in Iceland?

Take this one to Icelandic counsel first. The numbering rules prohibit connecting a number to an automatic calling machine outside three exceptions, with no marketing scoping, and a scripted synthetic-voice agent fits their definition. A live operator whose voice is transformed involves a human hand on each call.

Does the EU AI Act apply in Iceland?

Not yet. Iceland is in the EEA but not the EU, so an EEA-relevant instrument reaches it only once the EEA Joint Committee incorporates it into the Agreement. EFTA's register lists the AI Act as still under scrutiny with no decision, unlike the financial resilience regulation, which was incorporated in 2025.

Can we present a local Icelandic number?

Only one you legitimately hold, and not from abroad. Using false identifiers or numbers to deceive the recipient is prohibited by name, and calls arriving from outside Iceland presenting an Icelandic fixed-line number in the 4 or 5 ranges must have caller identification disabled before they arrive.

Compliance

Voice phishing simulations in Iceland

Phone numbers in IcelandProvisioned by Callstrike after approval

Iceland is the one country in this region where we would tell you to speak to local counsel before building the campaign rather than after it. A voice phishing simulation is lawful here and Callstrike supplies the Icelandic number, but two Icelandic rules run directly against how this product normally works, and neither has the marketing scoping that defuses the equivalent rule elsewhere in Europe.

Phone numbers

Supplied by Callstrike

Local numbers in Iceland, after a one-time approval.

Running a simulation

Permitted, with two real obstacles

The announcement duty on recording, and the ban on automatic calling machines.

Consent

Evidence, and possibly more than that

Documented standing notice is the only textual route past the recording rule.

Getting a phone number in Iceland

One approval per country, completed in the console.

Provisioned by Callstrike after approval

Numbers here are not released from open inventory. Your workspace is cleared for this country once, and Callstrike then provisions a dedicated number against it for your simulations. Approval is a one-time, per-country step and usually takes 3 to 5 business days. We only ask for what the regulator requires.

Icelandic numbers are not released from open inventory: your workspace is cleared for Iceland once and Callstrike then provisions a dedicated number against it. The carrier's evidence is ordinary and it is all Icelandic, which is the practical point. Both the identification of the business and the address behind it have to come from documents showing an Icelandic address, so a group registration held elsewhere does not carry the filing and a foreign utility bill will not stand in for a local one.

Two numbering rules then shape what you can do with the number, and the second is not a caveat. Iceland prohibits using false identifiers or numbers for the purpose of deceiving the recipient of a call, by name and in terms, and that test turns on the deceptive purpose rather than on whether you hold a right of use, so a pretext built on making the target believe the call comes from somewhere else is on the wrong side of the plain wording. And a call arriving from abroad presenting an Icelandic fixed number in the 4 or 5 ranges must have its caller identification disabled before it reaches the recipient, which closes the obvious workaround at the network rather than in an argument.

01Complete the regulatory clearance formYour administrator, in the Callstrike console. The form asks only for what the regulator requires.
02Approval is granted against your workspaceTypically three to five business days, and once only for as long as you operate here.
03A dedicated number in Iceland is assigned to youCallstrike
04Build and launch the campaignYour team

What you provide	Accepted evidence, any one of
Business name	Excerpt from the commercial register
Address	Excerpt from the commercial register showing icelandic address, Utility bill showing icelandic address, Tax notice showing icelandic address, Rental receipt showing icelandic address, Title deed showing icelandic address

These requirements are set by the carrier and can change. The form in the console is generated from their current rules, so treat it as authoritative and this table as a summary of what to have ready. Checked 2026-09-07.

Is it lawful to run a simulation in Iceland?

The position in short, before your counsel reads the detail below.

Yes in principle, and Iceland is where that answer needs the most qualification in this region. The basis is the Icelandic enactment of the legitimate interests ground, and the supervisory authority is unambiguous that employees generally cannot give valid agreement to workplace monitoring because of the disparity of position. It also states flatly that monitoring conducted in secrecy is prohibited unless it rests on a statutory authorisation or a court order, and it wants staff told what monitoring takes place, its purpose, who can reach what is collected and how long it is kept, in a demonstrable way and if necessary by written rules.

There is one honest limit that runs in your favour rather than against you. The Icelandic monitoring rules are gated on a definition of electronic monitoring that requires it to be continuous or regularly repeated and to take place in a public place or an area a limited group habitually passes through. A single simulated telephone call is not obviously continuous or regularly repeated, and a call is not obviously an area. Whether those rules reach a simulation at all is genuinely unresolved and we are not going to resolve it in either direction, which is why the duties above are written to the data protection act rather than to the rules.

The first real obstacle is recording, and the rule is not in the penal code where everyone looks for it. The electronic communications act requires a party who wishes to record a telephone call to notify the other party of that intention at the beginning of the call. That announcement is precisely what a simulation cannot survive. There is one exception on the text, and it points at documented standing disclosure rather than at silence: specific notice is not needed where it may unequivocally be assumed that the other party is aware of the recording. A workforce told in advance and in an evidenced way that simulated calls occur and are recorded is closer to that description than a workforce told nothing. We are giving you the argument the text supports, not a settled answer, and we could find no Icelandic guidance or decision resolving it. The safe design is a programme that does not need the audio.

The second obstacle is the one to take to counsel. The numbering rules prohibit connecting a telephone number to automatic calling and answering machines at the origination or termination of calls, outside three exceptions, and they define such a machine as equipment that can place or answer a call automatically according to a predetermined script without a human hand involved on each occasion. A scripted synthetic-voice agent sits squarely inside that definition, and unlike the equivalent rule in every neighbouring country the prohibition carries no marketing qualifier at all. The tension is genuine and we will not talk you out of it: the first exception is drafted by reference to the agreement conditions of a marketing article that imposes no agreement condition on a non-marketing call, so it is unclear how a security test satisfies an exception written for a rule that does not reach it. A live operator whose own voice is transformed in real time does not meet the definition, because a human hand is involved on every call, and that is a design answer rather than a clever reading. On disclosing a synthetic voice there is no Icelandic domestic duty: the European transparency rule that would supply one has not been incorporated into the EEA Agreement, so the position today is an absence rather than a permission.

What your company needs to do

7 items, in the order you will need them.

Take the automated-voice question to Icelandic counsel firstIceland-specificThis is the only page in this region carrying that instruction and it is deliberate. The prohibition on connecting a number to an automatic calling machine has no marketing scoping, its definition fits a scripted synthetic-voice agent, and no primary source resolves how a non-marketing call satisfies an exception written for a marketing rule. Get the answer before you build, not after.
Consider running Iceland with a live operatorIceland-specificA human whose own voice is transformed in real time involves a hand on each occasion, so the definition of an automatic calling machine is not met. That is a design choice available to you now, it changes the staffing rather than the scenario, and it is the shape that does not depend on resolving the question above.
Design the programme so it does not need the audioIceland-specificThe default Icelandic rule is that a party wishing to record announces it at the start of the call, which the exercise cannot do. Whether the call was answered, whether a credential was offered and where the person disengaged are all capturable as structured data. That removes the question instead of resting the programme on an unresolved reading of a single exception.
If you do record, build the standing disclosure properlyIceland-specificThe only textual route is that awareness may unequivocally be assumed, which asks for evidenced advance notice rather than a line in a handbook nobody acknowledged. Tell staff that simulated calls occur and are recorded, keep the record of who was told and when, and take advice before relying on it, because no Icelandic decision settles the point.
Give the monitoring notice the regulator asks forWhat monitoring takes place, its purpose, who has or may obtain access to what is collected, and how long it is kept, given in a demonstrable way and if necessary by adopting written rules. The authority also says covert monitoring is prohibited unless it rests on statutory authorisation or a court order, so the standing notice is doing real work rather than being good practice.
Consult, and do not expect anyone to have a vetoAbove fifty employees the information and consultation act requires you to inform representatives about decisions likely to lead to substantial changes in work organisation, and to consult with the aim of reaching agreement. That describes how the consultation runs; it is not a requirement to obtain agreement, and no provision makes the decision void without it.
Check the incorporation position rather than assuming either answerIceland-specificIceland is in the European Economic Area and not the Union, so an instrument marked as relevant to the Area binds only once a Joint Committee decision incorporates it. That status differs per instrument and it moves, so check EFTA's own register when you plan the campaign rather than carrying an answer across from a neighbouring country's page.

The controls that do the work

How Callstrike is configured, and which provision in Iceland each choice answers.

Auto-hangup before disclosure

The bot ends the call at the moment an employee starts to give up a credential or a piece of personal data, so the thing the pretext asked for is never spoken into the system and never stored.

The Icelandic monitoring rules require you to check first whether the aim can be met by other and milder realistic means, which is a statutory test of the design and not of the paperwork. The call ends the instant an employee starts to give up a credential, so the programme learns that somebody would have disclosed without the credential ever entering it, and the milder-means question has already been answered by the way the exercise is built rather than by an argument about why a harsher design was necessary.

In-call debrief and follow-up

A second voice breaks character as soon as the call ends, explains what just happened and why it worked, and a follow-up email repeats it in writing while the moment is still sharp.

The supervisory authority wants employees told what monitoring takes place and why, in a demonstrable way, and it treats covert monitoring as prohibited absent statutory authority. A second voice that breaks character the moment the call ends collapses the covert window to the length of a single call, and vishing training in writing the same day is the demonstrable half. That is a materially different posture from an exercise where the first thing anybody hears is a report weeks later.

Consent Management

Two modes: collect consent now, over email, Slack or Teams with a full audit trail per employee; or record that your organisation already has this covered, by uploading the policy, handbook clause or agreement and confirming the scope it applies to. The document is hashed, the attestation is signed and timestamped, and an audit email is issued. Included on every plan.

Iceland is the country where this does the most work, because the recording rule's only exception turns on whether awareness may unequivocally be assumed, and that is an evidential question rather than a legal one. A dated, per-employee record that the workforce was told simulated calls occur and are recorded is the strongest form that argument can take, and a hashed copy of the policy with a signed scope attestation is the alternative where you already have one. It does not settle the reading, and this page does not pretend it does.

SCORM module

An interactive web presentation on voice-phishing risk, delivered through your own LMS, which then invites the learner to opt into a web call with the bot. A call the person starts themselves in a browser is not a telephone call, so telephony rules do not reach it.

In most countries this is the fallback. In Iceland it is the route that avoids the hardest question on the page, because the prohibition is written about connecting a telephone number to an automatic calling machine and a browser call connects no number at all. Callstrike's vishing simulator can deliver the same deepfake voice through a web call the learner starts themselves after working through the module, and a learner who opens the call has been told in advance by construction, which also puts the recording announcement on a different footing.

Consent Management is included on every plan. See AI voice phishing simulation and human-in-the-loop voice phishing for how each is delivered.

The sourced position

Everything above, with the instruments behind it. Every claim cites the statute or the regulator it comes from, so your counsel can verify it rather than rely on our summary.

Legitimate interests, and a set of monitoring rules that were replaced

The lawful basis is the Icelandic enactment of the European provision on legitimate interests, which sits as the sixth item in the list of permitted grounds in the data protection act. The supervisory authority's own guidance is unambiguous about the alternative: employees generally cannot give valid agreement to workplace monitoring, because the disparity of position between them and the employer is such that it cannot be regarded as freely given, so the monitoring has to rest on another ground.

That same guidance carries the duty that actually shapes an Icelandic programme. The employer must inform staff about the monitoring taking place, its purpose, who has or may obtain access to what is collected, and how long it is kept. It adds that the information must be given in a demonstrable way, if necessary by adopting written rules. And it states flatly that monitoring conducted in secrecy is prohibited unless it rests on a statutory authorisation or a court order.

The instrument that fills in the detail is worth naming carefully, because the commonly cited one has been repealed. The 2006 rules on electronic monitoring were expressly repealed by the closing article of the 2023 rules, which were themselves amended in late 2025 to raise the retention ceiling from thirty days to ninety. The current rules require a clearly specified, lawful and objective purpose such as security, require you to check first whether the aim can be met by other and milder realistic means, and require notice before a person enters the monitored area or the monitoring begins.

Now the honest limit, and it cuts in your favour rather than against you. Electronic monitoring is defined as monitoring that is continuous or regularly repeated and that takes place in a public place or in an area a limited group of people habitually passes through. A single simulated call is not obviously continuous or regularly repeated, and a telephone call is not obviously an area. So whether those rules reach a simulation at all is unresolved, and we are not going to resolve it for you in either direction. The general obligations of the data protection act apply regardless, which is why the paragraphs above are written to the act rather than to the rules.

You must announce the recording at the start of the call

This is the block that decides whether an Icelandic programme records at all, and the rule is not where anyone looks for it. It is not in the penal code, whose privacy articles were rewritten in 2021 into a general privacy offence and a computer-access offence with no surviving provision on recording a conversation. It is in the electronic communications act.

That act provides that a party to a telephone call who wishes to record it shall, at the beginning of the call, notify the other party of that intention. It adds one exception: specific notice is not needed where it may unequivocally be assumed that the other party is aware of the recording. And it makes the handling of such recordings subject to the data protection act, with the arrangements for recording and its notification to the public and to an institution's staff following any conditions the supervisory authority sets.

Say plainly what that means for this product. The default rule is the opposite of what a simulation needs, because the announcement is the thing the exercise cannot survive. The only textual route is the second sentence, and it points at standing, pre-notified disclosure rather than at silence: a workforce told in advance, in a documented way, that simulated calls occur and are recorded is closer to a person of whom awareness may unequivocally be assumed than a workforce told nothing. We are presenting that as the argument available on the text, not as a settled answer, and we could find no Icelandic guidance or decision resolving it.

Layered underneath is the confidentiality rule, which prohibits all processing of communications including storage, listening, recording and interception unless it is done with the user's informed agreement or under statutory authority. Taken together the shape is clear enough to plan against: in Iceland, design the programme so it does not need the audio, or solve the notice question properly before you switch recording on.

The marketing rule lets you through and the numbering rule may not

Two Icelandic provisions point in opposite directions here, and a page that read only the first would tell you something comfortable and incomplete.

The first is the transposition of the European rule on unsolicited communications, and it is scoped by purpose in every paragraph. It permits the use of automated calling systems, fax, electronic mail and electronic messages of any kind for direct marketing only where the end user has given prior informed agreement, prohibits unsolicited communications in the form of direct marketing to those who do not want them, and requires those using telephony as part of marketing to respect the directory marking. Every limb says marketing. An authorised internal security test is not marketing, so on this provision alone the answer would be that it does not reach you. The national opt-out register works the same way, being aimed at controllers engaged in direct marketing.

The second provision is the problem, and it is in the numbering rules rather than the act. It prohibits connecting a telephone number to automatic calling and answering machines at the origination or termination of calls, except in three cases: where the conditions on agreement in the unsolicited-communications article are met, where the use is connected with emergency or rescue activity, or where the answering is toll-free. The same rules define such a machine as technical equipment that can place or answer a call automatically and according to a predetermined script without a human hand being involved on each occasion. A scripted synthetic-voice agent is squarely inside that definition, and the prohibition carries no marketing qualifier at all.

The tension is genuine and we are not going to talk you out of it. The first exception is drafted by reference to the agreement conditions of a marketing article that imposes no agreement condition on a non-marketing call, so it is unclear how a security test satisfies an exception written for a rule that does not apply to it. No primary source resolves that, and Iceland is therefore the one country in this cluster where we would tell you to take the automated-voice question to local counsel before the campaign rather than after it. A live operator whose own voice is transformed does not engage the definition, because a human hand is involved on each occasion, and that is a design answer rather than a legal loophole.

On disclosure of a synthetic voice, Iceland has no domestic duty. The European transparency rule that would supply one has not been incorporated into the EEA Agreement, as the final section sets out.

Deceptive caller identity is prohibited by name

Iceland is one of the few countries in this portal that prohibits deceptive caller identification in terms rather than by implication, and the rule is recent.

The 2025 rules on caller identification arrangements provide that undertakings operating publicly available telephone service shall offer free caller identification, and then state that it is prohibited to use false identifiers or numbers for the purpose of deceiving the recipient of a call or of a short message. Note the shape of that test: it turns on the deceptive purpose rather than on whether you hold a right of use in the number presented. A simulation that presents a number in order to make the target believe the call comes from someone else is on the wrong side of that sentence on its plain wording, and the fact that the employer authorised the exercise does not change what the recipient is being made to believe.

The same rules close off the obvious workaround. Where a call arrives from abroad to an Icelandic number and presents as an Icelandic ordinary fixed-line number beginning with the 4 or 5 ranges, caller identification must be disabled. So a campaign originated outside Iceland presenting a local geographic number does not merely risk an argument; the identification is stripped before the phone rings.

Underneath, numbers are treated as a resource of the Icelandic state, allocated as a temporary and conditional right of use recorded against a name and identity number. Only numbers the regulator has allocated may be used, the undertaking is responsible for their correct use including that they are not used for a purpose other than the one their range was allocated for, and the regulator may order blocking on reasoned suspicion of fraudulent misuse.

What the country matrix holds for Iceland

Number types:: Local
Restricted for automated outbound:: None recorded

Generated from the same country matrix the platform enforces at dispatch, so it cannot drift from what you can actually buy.

Consultation aimed at agreement, which is not the same as agreement

Iceland has no works-council veto of the Austrian or German kind, and saying so with the source is more useful than leaving the reader to assume one exists.

The information and consultation act applies to undertakings normally employing at least fifty people in the domestic labour market. It requires the employer to inform employee representatives about, among other things, decisions likely to lead to substantial changes in the organisation of work or in employees' contracts of employment. Following that information the representatives must be given the opportunity for consultation by meeting the employer and receiving a response to any opinion they put forward, and consultation on that category of decision is to be conducted with the aim of reaching agreement.

Read those last words precisely, because they are the ones that get overstated. With the aim of reaching agreement is a description of how the consultation is to be conducted. It is not a requirement to obtain agreement, and there is no provision making the decision void without it. Alongside that sits the shop steward, appointed at any workplace with five or more workers, whose statutory function is to see that collective agreements are honoured and that workers' social and civil rights are not encroached upon, and to investigate complaints. Nothing in that act gives the steward consent rights over an employer measure.

One thing the text does not settle: whether introducing a simulation programme is a decision likely to lead to a substantial change in the organisation of work, and so whether the consultation duty is engaged at all. No statute, guidance or decision answers it, and we would rather tell you that than assert a duty or dismiss one.

The general written duty that does apply whatever the answer comes from working environment law: the employer is responsible for a written plan on safety and health at the workplace, including a risk assessment, to be prepared in consultation with employee representatives and revised when changes to the working environment change its premises. That is the natural home for the programme description and the notice the data protection guidance requires.

The financial regime arrived first, and the general one has not arrived at all

Iceland is in the European Economic Area and not in the European Union, so a Union instrument marked as relevant to the Area does not become Icelandic law by itself. It reaches Iceland only once a decision of the EEA Joint Committee incorporates it into the Agreement's annexes. The three instruments readers ask about are in three different states, and the ordering is the opposite of what most people expect.

DORA, the financial-sector digital resilience regulation, is fully in. It was incorporated by Joint Committee Decision 40 of 2025, adopted on 20 February 2025, and Iceland gave it the force of law by an act that entered into force on 1 January 2026 and that names that decision in its own opening article. So an Icelandic financial entity is inside the newer European regime, including its threat-led penetration testing requirement.

The EU AI Act is not incorporated. EFTA's own register records it as marked relevant to the Area by the Union and under scrutiny for incorporation by Iceland, Liechtenstein and Norway, with no Joint Committee Decision listed. Its transparency duties, including the duty on a deployer to disclose that audio content is artificially generated, are therefore not Icelandic law today. That is a statement about the incorporation position rather than a view about the merits, and it is the position that will change first.

NIS2, the network and information security directive, is in the same state: under scrutiny, no decision, not incorporated. What Iceland actually operates is the 2019 act on the security of network and information systems of critical infrastructure, implementing the earlier directive. Its risk-management provision requires documented policy and procedures, regular risk assessment, and appropriate testing carried out regularly in accordance with international best practice. It names no technique, and in particular it does not name social engineering or voice, so anyone telling you Icelandic law requires this kind of test is going beyond the text.

There is a tidy corroboration of the NIS position inside the DORA act itself. Because the European regulation cross-refers to national law implementing the newer directive, and Iceland has none, the Icelandic act has to substitute a reference to the 2019 critical-infrastructure act instead. A country that had transposed the newer directive would not need that bridge.

Take this further

Research prompt for your own AI assistant

Paste into Claude, Harvey or your firm's tool to pressure-test the position above.

You are advising on an authorised internal security exercise in ICELAND. Our own employees receive a simulated voice-phishing call, placed by our vendor on our instruction, to measure susceptibility. No credential is captured or stored. The workforce is informed in advance.

Two questions are urgent and come first: may we use a scripted synthetic-voice agent at all, and may we record. Then verify or correct each proposition below against primary Icelandic sources:

1. ⚠ 16. gr. reglna nr. 960/2023 prohibits connecting a telephone number to an 'sjalfvirkur simsvari' at origination or termination outside three exceptions, with NO marketing qualifier, and 3. gr. defines the machine by a predetermined script without a human hand on each occasion. How does a non-marketing call satisfy exception one, which is drafted by reference to the agreement conditions of 94. gr.?
2. ⚠ 91. gr. laga nr. 70/2022 requires a party wishing to record to notify at the BEGINNING of the call, excepted where awareness 'ma otvirætt ætla'. Does documented standing disclosure to a workforce meet that exception? Any decision either way?
3. 94. gr. is scoped to 'markadssetning' in every limb, so an internal test is outside it, and the opt-out register is aimed at direct marketing controllers.
4. ⚠ Reglur nr. 837/2006 were REPEALED by 14. gr. reglna nr. 50/2023, itself amended by reglur nr. 1329/2025 (retention 30 days to 90). And 228./229. gr. almennra hegningarlaga were rewritten by L. 8/2021 with no surviving recording article.
5. 'Rafræn voktun' is defined as continuous or regularly repeated AND in a public place or an area a limited group habitually passes through. Does a telephone call meet either limb? We have left this open.
6. 3. gr. reglna nr. 548/2025 prohibits false identifiers or numbers used to deceive the recipient, turning on PURPOSE rather than right of use, and requires caller identification to be disabled on inbound foreign calls presenting 4 or 5 range numbers.
7. Log nr. 151/2006 apply at 50 employees, and consultation 'med thad ad markmidi ad na samkomulagi' describes the conduct rather than requiring agreement.
8. ⚠ EEA STATUS, PER INSTRUMENT: DORA incorporated by JCD 40/2025 and given effect by log nr. 78/2025 from 01.01.2026, which names that decision in its first article; the AI Act and NIS2 under scrutiny with no decision, not incorporated. Confirm each and give the position rather than an answer either way.

Flag anything that has changed since September 2026, and tell us whether any Icelandic control requiring simulated phishing sits in the annexes we did not read.

Common questions

Can we record simulated calls in Iceland?: Not silently, on the default rule. The electronic communications act requires a party who wishes to record to notify the other party at the beginning of the call. The only exception is where awareness may unequivocally be assumed, which points at documented standing disclosure rather than at saying nothing.
Can we use an AI voice agent for calls in Iceland?: Take this one to Icelandic counsel first. The numbering rules prohibit connecting a number to an automatic calling machine outside three exceptions, with no marketing scoping, and a scripted synthetic-voice agent fits their definition. A live operator whose voice is transformed involves a human hand on each call.
Does the EU AI Act apply in Iceland?: Not yet. Iceland is in the EEA but not the EU, so an EEA-relevant instrument reaches it only once the EEA Joint Committee incorporates it into the Agreement. EFTA's register lists the AI Act as still under scrutiny with no decision, unlike the financial resilience regulation, which was incorporated in 2025.
Can we present a local Icelandic number?: Only one you legitimately hold, and not from abroad. Using false identifiers or numbers to deceive the recipient is prohibited by name, and calls arriving from outside Iceland presenting an Icelandic fixed-line number in the 4 or 5 ranges must have caller identification disabled before they arrive.

Elsewhere in Northern Europe

The rules differ by country even inside one region. These are the nearest guides to this one, each showing how phone numbers are obtained there.