#E2025J0011EFTA Court Judgment: Iceland Found in Breach for Failing to Implement EU Consumer Protection Omnibus Directive (2019/2161)

On 9 December 2025, the EFTA Court issued a judgment in Case E-11/25, finding that Iceland had failed to fulfil its obligations under the EEA Agreement by not implementing Directive (EU) 2019/2161 — commonly known as the 'Omnibus Directive' — within the required deadline. The case was brought by the EFTA Surveillance Authority against Iceland for this legislative omission. Directive (EU) 2019/2161 is a landmark EU consumer protection reform that amended four major directives: the Unfair Contract Terms Directive, the Price Indication Directive, the Unfair Commercial Practices Directive, and the Consumer Rights Directive. Its core aims include increasing transparency for online marketplaces, combating fake reviews, ensuring price transparency (including prior price disclosure for discounts), and strengthening enforcement penalties. EEA/EFTA states, including Iceland, were required to transpose the Omnibus Directive into national law with an implementation deadline of 28 May 2022, with the rules applicable from 28 May 2022. Iceland failed to do so by the required date, triggering infringement proceedings by the EFTA Surveillance Authority. The court's ruling confirms Iceland's legal obligation to implement the directive and represents a formal condemnation of the state's legislative inaction. Iceland is now under a binding court judgment to complete transposition without further delay, or risk further legal and financial consequences.

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