Iceland Covid Vaccine NFCS


Iceland introduced a no-fault compensation scheme for COVID-19 vaccine injuries in 2020, which is regulated under the Act no. 156/2020 of December 23, 2020, Amending the Patient Insurance Act no. 111/2000 (Right to Compensation Due to Vaccination), and the Patient Insurance Act No. 111/2000 (as amended).

The administrator of this scheme is Sjúkratryggingar Íslands (Icelandic Health Insurance), which is an agency administering public health insurance in Iceland, handling negotiation and payment for health services and carrying out additional tasks. Icelandic Health Insurance is regulated by the Act on Health Insurance, no. 112/2008, and its board members are appointed by the Minister of Health.

As Icelandic Health Insurance is funded through the State Treasury (see Act no. 112/2008, Article 54) the funding for this NFCS seems to come from the Icelandic state budget.


Vaccines Covered

This NFCS covers vaccines against COVID-19 administered between 2020 and 2023 provided by the Icelandic health authorities. Liability covers damage resulting from the properties of the vaccine or its incorrect handling, including during its transport, storage, distribution or vaccination by a healthcare professional.

Although not specifically indicated in the law, it seems this scheme includes vaccines approved for emergency use and standard approvals.


Injuries Covered

This NFCS covers both temporary and permanent injuries.

Under this NFCS all injuries are potentially covered.


Charges for making a claim

There are no known charges for making a claim under this scheme.



Under this scheme the following categories of individuals are permitted to make a claim:

  • An injured vaccinated person;
  • Those dependants who lose their supporting person upon the death of the injured person.

The claimant is allowed to nominate a legal representative to make their claim under this scheme.


Losses covered

This scheme pays the following:


Live vaccine recipient

Dependants of vaccine recipient

Person close to a deceased vaccine recipient

Both eligible economic and eligible non-economic losses are compensated

Not specified

It is not known whether any compensation is available for legal heirs of a deceased vaccine recipient.


It is not known whether NFCS payment consists of periodic payments, lump sum payments, or a mix of periodic payments and lump sum payments.

It is not specified whether funeral costs are covered under this NFCS.

Compensation under this scheme calculated on an individual basis using tariffs/guidelines to assist with quantification.

Loss of earnings are paid under this scheme. They are quantified on an individual basis.

Compensation under this scheme is capped, with a top value of ISK 5,000,000.

There is a minimum claim value under this NFCS of IKR 116,057 for incidents occurring in 2020; IKR 121,047 for incidents occurring in 2021.


Time limits for claims

The scheme does not set a time limit between vaccination and the adverse event occurring.

A claim under the scheme must be brought within four years from the moment the injured party received or could have received knowledge of the injury, but no later than ten years after the incident that resulted in the injury.


Evaluating claims – standard of proof required

The injury should be 'in all probability' caused by Covid-19 vaccination.


Appeals and the right to litigate

There is a restricted right to litigate - a claim for damages might be filed only for any outstanding amount not compensated by the NFCS.

There is an external review process where the decision of the Icelandic Health Insurance can by challenged by filing an appeal with the Welfare Appeals Committee.


Useful information and links

It is not known whether the scheme produces periodic reports including data on claims & financial performance.


Links to legislation:

Act no. 156/2020:

Act No. 111/2000:


Other resources:

Vaccine NFCS page on the Icelandic Health Insurance website:

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