Finding "Gold-Plating" in Iceland's Implementation of EU Law

When Iceland implements EU directives through the EEA agreement, the national version sometimes goes further than the directive requires — extra requirements, stricter penalties, broader scope. This "gold-plating" (gullhúðun) accumulates quietly across decades of legislation and weighs on the competitiveness of Icelandic businesses, yet finding it manually would consume enormous amounts of expert time.

In August 2024, Minister of Higher Education, Industry and Innovation Áslaug Arna Sigurbjörnsdóttir announced that the ministry would use artificial intelligence to do what specialists alone could not. Citizens Foundation built the system: a Policy Synth Gold-plating Research Agent that ingests the relevant EU directives alongside Icelandic laws and regulations, cleans and extracts every article, translates between languages, and then scans each national article against the EU text for every type of gold-plating — flagging additions, reviewing the law's supporting documents, and drafting a justification analysis for each finding.

Pilot: the Electronic Communications Code

The telecommunications sector served as the pilot. Analyzing Iceland's implementation of the EU Electronic Communications Code, the agent surfaced 52 instances of gold-plating not justified in the supporting documents — from extended penalty provisions to stricter monetary fine ranges — each ranked by Elo rating with citations into the legal text and direct links to Alþingi sources.

To keep the findings trustworthy, every analysis was run three ways in parallel — GPT-4o, Claude Sonnet 3.5 and GPT-4o mini — with results compared and human reviewers making the final call in shared documents and spreadsheets. The approach echoes what Ohio achieved using AI to clear outdated laws, estimated to save tens of thousands of public-sector work hours, and the models and guidelines from the pilot are designed to scale across other ministries and agencies.