Ministry of Health announces increased equity in healthcare following SKE recommendations – it is important that they are implemented

In this country, the government has authorised the operation of both public and private healthcare. For the healthcare services to have the incentive and ability to offer the best possible service to all the nation's people, it is important that they all operate under comparable working conditions. This has not been guaranteed.

With this in mind, in recent years SKE has directed recommendations to health authorities to level the playing field between private and public healthcare. Among other things, their operating conditions need to be levelled, discrimination in the pricing of diagnostic services tackled, a clear framework for the relationship and contracts between public and private facilities established, and their tax treatment harmonised.  Furthermore, the situation needs to be levelled out with clear rules on central services, comparable oversight, and equality in doctors' specialist training.

Last November, the Competition Authority reaffirmed previous guidance. The guidance, along with a news article on the Competition Authority's website, is available. here.

The Ministry of Health responded to the Competition Authority's request with a letter dated 31 December 2025, outlining specific changes. It is important that these are implemented and that the current course is maintained.

The ministry's response to the supervisory authority's recommendations

The ministry's response states that it intends to make specific changes in its work, intended to level the playing field for private healthcare centres vis-à-vis public ones, taking into account their different operating environments.

Specifically, the ministry outlined the following changes:

1. Flat unit price from 1 January 2026

The Ministry announced that from 1 January 2026, all healthcare centres would pay the same unit price for the research services of Landspítalinn. This addresses a long-standing discrepancy where private centres paid a higher price than public ones.

2. Restructuring of central services

The Ministry is working on changes to central services within the healthcare system. These include:

• establishment of Digital Health, a new central development and service centre,
• Transfer of mental health services in prisons to Landspítali,
• Review of the arrangements and accessibility of the Health Information Centre.

3. Monitoring, specifications and a new regulation

A new regulation on healthcare is being developed which will clarify requirements for healthcare centres, regardless of their form of operation. This will address concerns that public centres have not been subject to the same level of oversight as private ones.

4. Equalisation in vocational training and the tax environment under consideration

The Ministry confirms that the funding for specialist doctors is now distributed equally regardless of the form of organisation. Furthermore, in cooperation with the National Health Insurance and the Ministry of Finance, it will be examined whether the VAT refund can be implemented in a different way to ensure greater neutrality in operations.

HRN's answer, 29 December 2025 

The Competition Authority's position and further recommendations

The Competition Authority's recommendations were originally made in October 2017 and had only been partially addressed. According to the ministry's response to the authority's latest recommendations, important changes have now been made with regard to investigation costs. This is very positive.

Changes to the central service are also proposed. In the regulator's view, it is important that this central service is established with the aim of serving all aspects of the healthcare system in a comparable and fair manner, and that individual parties are not favoured at the expense of others.

The Competition Authority urges the ministry to complete the projects described in its responses. Furthermore, the Authority recommends that the healthcare funding model and other operational environments are regularly reviewed with a view to ensuring a level playing field, taking all factors into account.

Further details on the Competition Authority's recommendations

In October 2017, the Competition Authority issued recommendations to the Ministry of Health to level the playing field for private and public healthcare centres. The recommendations were prompted by comments received from private healthcare centres about competitive discrimination. The letter to the ministry also addressed the changes that had taken place in the primary healthcare system in the capital region and the importance of users being able to switch between healthcare centres regardless of their form of organisation, thereby creating an incentive for the centres to improve service, efficiency and cost-effectiveness within the system.

The Competition Authority made the following recommendations to the minister:

1. A general review should be carried out of the different conditions under which public and private healthcare centres operate. The Minister for Health should, amongst other things, advocate for the different situations faced by public and private healthcare centres regarding patient insurance to be reviewed, and for measures to be taken to level the playing field in this respect.
2. Ensure that Landspítali does not discriminate between business partners when pricing its research services.
3. A clear and defined framework will be established for the relationships and contracts between the Capital Area Health Service and private healthcare centres.
4. That the tax treatment of public and private healthcare centres, respectively, should be as equal as possible.

In November 2025, the Competition Authority reiterated the recommendations and considered it particularly urgent to equalise discrimination regarding research costs, in addition to the following:

• It is important that the health authorities include specific provisions on competitive neutrality in contracts entered into for centralised service and monitors their follow-up. Currently, this service is primarily provided by the Health Service of the Capital Region, but the same should apply regardless of the service provider. For example, it is important that a central service does not direct clients to sites other than their registered one unless special circumstances warrant it.
•  Private healthcare providers have pointed out that public healthcare providers do not operate under the same level of oversight as private providers with regard to Requirement specifications. Thus, certain public institutions have not met the minimum requirements for opening hours, staffing and services. There is no monitoring to ensure that public health centres comply with the requirements, and there are no consequences for failing to do so.
• It is important that private healthcare centres enjoy equal treatment with public ones when it comes to specialisation in general practice. According to the complainants, the state has funded around 20 specialist training posts for general practitioners annually, but private practices have not had the opportunity to apply to make use of them.
• It is important that the cost model for health centres takes into account that private health centres have to pay a special Premium for patient insurance.
• It could be considered to arrange a refund for value-added tax in a different way to the current system, to make it easier for each business unit to assess and decide which tasks are outsourced and which are not, e.g. telephone answering, cleaning, IT systems, etc.