The state's impermissible plans would give rise to liability for damages

The finance minister's plans for legislation on the winding-up and settlement of the ÍL Fund are based on an inadequate analysis of legal and financial factors and amount to an attempt to sidestep the state's financial obligations. The proposed legislation would amount to expropriation, would be unconstitutional, and would be liable to render the Icelandic state liable for damages, which could result in significant additional expenditure by the state treasury in the form of default interest and costs. This is among the points made in the comments of twenty pension funds on the minister's proposal document, which has been published in the government's consultation portal.

The comments of the twenty pension funds, submitted to the consultation portal today by the law firm LOGOS, further state that the finance minister's plans are liable to damage the reputation of the Icelandic state and its credibility in the financial market. They could disrupt the balance of the financial market with unforeseen consequences for asset prices and investors' interests. The minister's plans are therefore ill-considered and could cost the state significant sums, in addition to prolonged litigation both domestically and abroad.

Below are the comments the pension funds have made on the minister's plans, along with an overview of the main points.

• Comments on the proposal document
• Summary of comments on the proposal document