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Iceland · Agentic SaaS development

SaaS Development for Iceland: VAT, Billing and Terms

A common mistake when selling subscriptions into Iceland is to assume the EU One Stop Shop handles the VAT. It does not: the OSS covers customers in the EU, and the country sits in the EEA but outside the EU, so Skatturinn runs its own registration for foreign sellers. Consumer terms have their own rule as well, and a national ID number that sign-up forms cannot simply demand.

Curiosive, a studio in Ankara, Türkiye, builds SaaS products with AI coding agents under senior engineer review. Agents produce the CRUD screens, admin views, migrations and test suites. Engineers design the tenant model, billing webhooks and entitlement logic, because those are the places a subscription product fails quietly. Your clocks run on GMT and ours on UTC+3, so six hours of each working day overlap.

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VAT on SaaS sold to consumers in Iceland: the VOES scheme

VAT rates there are 24% standard and 11% reduced. A foreign company selling electronically supplied services, including downloaded or streamed software and smartphone apps, to consumers there must register once those sales pass ISK 2,000,000 in any twelve-month period. It can use the simplified VOES registration, which is pay-only with no input tax deduction, with two-month declarations filed in krónur (ISK) and due one month and five days after each period ends. B2B sales to buyers registered under Article 5 of the VAT Act who can claim the VAT as input tax need no registration. For the product, that means the billing layer must record whether each customer is a registered business, keep a running ISK total of consumer sales against the threshold and produce figures in two-month periods. Engineers design that logic rather than leaving it to agents, and it is worth confirming the specifics with an accountant.

Payments in Iceland: card schemes, local acquirers and A2A

The central bank's Cost of Retail Payments report, published 20 January 2025 and covering 2023, found that the vast majority of payments at merchants' physical outlets ran on international card scheme infrastructure. It names Landsbankinn, Straumur (a Kvika subsidiary), Teya and Rapyd as acquirers, and notes that the account-to-account provider Blikk began operating in 2024. That describes in-person spending rather than online subscriptions, but it tells you cards are the habit customers bring, so card billing is the sensible default and A2A is something to watch rather than build first. Whatever the provider, we treat its events as the source of truth and make webhook handlers idempotent, so a redelivered event is never processed twice. Among our shipped products, PicKey (pickey.ai), a visual password manager for a client in India, includes subscription billing on Stripe.

Icelandic-language terms under the Marketing Act No. 44/2026

The Marketing Act No. 44/2026 has been in force since 16 May 2026. Article 14 requires advertisements to be in Icelandic, unless an advertisement is aimed only at foreign consumers, and requires the same of a business's general terms for services offered to consumers in the country and of any warranty statements given to them. Under Article 33, Neytendastofa can fine businesses up to 4% of the previous operating year's total turnover or the ISK equivalent of EUR 2 million, whichever is higher. A B2C SaaS therefore needs a localisation layer from the start: terms, plan descriptions and checkout copy that can be served in Icelandic, versioned so you can show which terms a customer accepted. We build that layer in Next.js. The translation itself should come from a qualified translator, not from a coding agent.

Kennitala and public sector e-invoices in SaaS billing

Under Article 13 of the data protection act, a business may use a kennitala, the national ID number, only with an objective purpose and where it is necessary for reliable identification. Persónuvernd's guidance adds that the test is not met unless other identifiers, such as name, address or customer number, are insufficient. So a sign-up form should not make it a required field by default, and the data model should hold it only where the purpose is documented. Selling to the public sector adds an invoicing format. Under Regulation No. 44/2019, public buyers must receive and process e-invoices conforming to EN 16931 as implemented by TS236:2017 from Staðlaráð Íslands. State bodies had to comply by 18 April 2019 and municipalities and public undertakings by 18 April 2020, so a SaaS selling to them needs an invoice path that produces that format.

Multi-tenant SaaS and accessibility for EU and EEA customers

Tenant isolation, plan and entitlement logic and permission checks are designed by engineers before any screen exists, since every later query depends on them. Agents then generate the screens, migrations and test suites around that core on PostgreSQL with Drizzle ORM and Hono. Accessibility is a moving target here. EFTA's EEA-Lex listed the European Accessibility Act as still under scrutiny for incorporation into the EEA Agreement on 2 October 2026, so it is not yet EEA law binding Iceland. In the EU it applies to listed services provided to consumers after 28 June 2025, including e-commerce and consumer banking, with microenterprises exempt, so a product in those categories that is also sold into the EU should meet it now. Reveal Software (reveal.software), video onboarding for a client in Romania, runs on this same stack.

Questions

The things people ask before starting.

Does a foreign SaaS company charge VAT on sales to customers in Iceland?

Yes for consumer sales once they pass ISK 2,000,000 in any twelve-month period, and the simplified VOES registration is available. The rates are 24% standard and 11% reduced. Sales to businesses registered under Article 5 of the VAT Act that can claim the VAT as input tax need no registration.

Does the EU One Stop Shop cover VAT on digital services sold to Iceland?

No. The One Stop Shop covers distance sales and cross-border services to customers in the EU, and this country is an EEA EFTA State, not an EU member. Foreign sellers of electronic services to consumers there register with Skatturinn once over the threshold, with declarations filed in krónur every two months.

Do SaaS terms of service have to be in Icelandic?

For consumers, yes. Since 16 May 2026, Article 14 of the Marketing Act No. 44/2026 requires general terms for services offered to consumers in the country to be in Icelandic. Neytendastofa can fine up to 4% of the previous operating year's total turnover or the ISK equivalent of EUR 2 million, whichever is higher.

Does the European Accessibility Act apply to SaaS products in Iceland?

Not yet. On 2 October 2026 EFTA listed the Act as still under scrutiny for incorporation into the EEA Agreement, with no Joint Committee Decision. If your product is one of its listed consumer services, such as e-commerce, and you also sell into the EU, it applies there unless you are a microenterprise.

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