Analysis of the IAEA’s Comprehensive Iran NPT Safeguards Report May 2025

Excerpt

The International Atomic Energy Agency (IAEA) on May 31, 2025, released a comprehensive report on Iran’s non-compliance with its Nuclear Non-Proliferation Treaty (NPT) safeguards obligations. The report was requested by the Board of Governors in a November 2024 resolution.

New Information

• In a report spanning 22 pages, the IAEA presents new details from its assessments about Iran’s activities involving undeclared nuclear materials, related equipment, as well as their nuclear weapons relevance, at four sites in Iran under agency investigation since 2019: Lavisan-Shian, Marivan, Varamin, and Turquz-Abad. 
• For the first time, the IAEA reveals its assessment that the four sites and missing nuclear material in Iran are directly connected.
• It concludes that Lavisan-Shian, Marivan, and Varamin, as well as “other possible related locations” were “part of an undeclared structured nuclear programme” and that Iran retained nuclear material or related equipment from this program at Turquz-Abad from 2009 to 2018, with current whereabouts unknown.
• The IAEA also discusses and connects these activities to an unaccounted-for amount of uranium once present at Iran’s Jaber Ibn Hayan Multipurpose Laboratory (JHL).
• The report does not define or mention the name of the structured nuclear program. But it should be noted that the IAEA is referring to Iran’s crash nuclear weapons program of the early 2000s, codenamed the Amad Plan. This program formally ended in 2003, but Iran’s nuclear weapons efforts continued afterwards in a reduced, more camouflaged manner. As such, the use of the word “structured” is misleading as to the situation during the Amad period and afterwards.
• The IAEA report falls short on integrating its latest findings into a true comprehensive assessment of all Iran’s nuclear weapons work, both during Amad and afterwards. Such an assessment could integrate the four sites with findings about the other roughly 15 Amad Plan major sites and facilities, discussed in Iran’s Nuclear Archive, which the IAEA possesses in its entirety.
• The report selectively references only one other Amad site by name—the Bandas-Abbadas/Gchine mine and mill—but does not provide further context. The IAEA briefly mentions Iran’s planned, scaled-up uranium conversion facility, known in the nuclear archive as the “New Tehran Plant,” and briefly mentions activities conducted at Parchin. It also fails to mention that the Fordow enrichment site was being built as part of the Amad Plan and codenamed the al Ghadir project, expressly designed to make weapon-grade uranium, starting with less than five percent enriched uranium produced at the Natanz enrichment plant. The al Ghadir project, focused on Iran’s major bottleneck in its nuclear weapons program, continued in secret after the formal end of the Amad Plan in 2003. It was discovered by Western intelligence several years later, and its public revelation in 2009 forced Iran to place it under safeguards. It can hardly be lost on the reader that this site is now making highly enriched uranium of no civilian use and is capable of making enough weapon-grade uranium for a nuclear weapon in a matter of days. This Iranian effort, as well as other ones, aimed at overcoming key bottlenecks in its nuclear weapons effort are absent from the IAEA report.
• The report provides new information on the extent of Iranian attempts to sanitize locations of interest to the IAEA and provide false information when faced with questions. It states, “the provision of inaccurate and sometimes contradictory explanations seriously obstructs” the IAEA’s efforts. The IAEA is explicit that although the matters on Lavisan-Shian and Marivan are considered “no longer outstanding,” this does not mean the matters are “resolved.”

Findings and Recommendations

The United States and E3 will reportedly work to pass an IAEA Board of Governors resolution at the board meeting that begins on June 9. In addition to clearly stating that Iran is in non-compliance with its safeguards commitments in its comprehensive safeguards agreement and in Article III of the NPT, the resolution should refer Iran’s case to the UN Security Council for action.

A referral to the UN Security Council need not in any way end the IAEA’s effort to obtain answers from Iran; in fact, it should enhance the IAEA’s quest for answers, as was the case in 2005 when the Board of Governors first referred Iran’s non-compliance to the UN Security Council. In the resolution adopted on September 25, 2005, the board requested the IAEA step up its efforts to bring Iran into compliance with its safeguards obligations and “pursue additional transparency measures” to “reconstruct the history and nature of all aspects of Iran’s past nuclear activities and to compensate for the confidence deficit created.” The years following that referral were marked by increased IAEA efforts to address its concerns about Iran’s nuclear weapons efforts, backed by increased resources from IAEA members, particularly in terms of new, actionable information. That referral and sequencing should be repeated today.

Whether or not the resolution contains an explicit referral to the UN Security Council, the E3 should trigger the reimposition of UN Iran sanctions via the snapback procedure outlined in the Joint Comprehensive Plan of Action and associated UN Resolution 2231. This action would also cause the return of the UN Security Council demand that Iran end its uranium enrichment program.

Andrea Stricker is deputy director of the Nonproliferation and Biodefense Program at the Foundation for Defense of Democracies (FDD) and an FDD research fellow.