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.
The IAEA has been investigating Iran's undeclared nuclear material, activities, and facilities for over two decades, with a new major investigation ongoing since 2019. The agency previously investigated Iran's covert nuclear activities from 2002 to 2015, pausing from 2015-2018 while the Iran nuclear deal was in effect. With the evaluation of all safeguards-relevant information in 2018 and 2019, the IAEA identified a number of questions related to possible undeclared nuclear material and activities and requested answers.
As an NPT state party, the IAEA notes in its report, Iran is required to refrain from developing nuclear weapons (NPT Article II) and to disclose and permit the IAEA to apply safeguards over nuclear materials, activities, and facilities (NPT Article III). Pursuant to these obligations and under its comprehensive safeguards agreement (CSA), in light of potential violations, Iran must also cooperate with IAEA investigations, such as by permitting full access to sites, providing accurate technical explanations, and making available documentation, all with the aim of ensuring Iran's nuclear material is devoted exclusively to peaceful uses.
Since 2019, the IAEA has made numerous efforts to engage Iran, including in high-level meetings and technical consultations. Yet what the IAEA describes in its latest report is an egregious failure by Iran to fulfill its obligations, as well as an elaborate, ongoing cover-up. The latter included Iran's false explanations, denials, sanitization of sites, relocation of equipment and material, refusals to cooperate, and retributive actions such as de-designation of IAEA inspectors, among other tactics. In the new information, the IAEA obtained conclusive evidence of its highly confidential documents, including the questions intended to be asked by the IAEA in upcoming inspections, which according to the IAEA report, "raises serious concerns regarding Iran's spirit of cooperation and may undermine the effective application of safeguards in Iran." How Iran obtained the safeguards confidential report was not discussed in the report.
Overall, the level of non-compliance raised in this report warrants an IAEA Board of Governors censure resolution and referral of Iran's case to the UN Security Council.
Below is key new information from the IAEA's report, as well as findings and recommendations.
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. [2]
- 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."
Lavisan-Shian
A former headquarters of Iran's nuclear weapons program, established initially by the Physics Research Center, an entity which predated the Amad Plan and provided personnel, equipment, and material to the Amad Plan, including Amad's leader Mohsen Fakhrizadeh. Among many nuclear weapons activities conducted there, the IAEA focused on Iran's production during the Amad Plan of uranium deuteride (UD3) neutron initiators, aka an explosively driven neutron sources (EDNS), used in the center of the core of the Iranian implosion-type nuclear weapon. It produces neutrons that initiate the chain reaction in the weapon-grade uranium in the core as a result of an imploding shockwave.
The site had been sanitized in late 2003 and early 2004. After the Institute's publication of satellite images of the sanitization of the site, the IAEA used this study to ask for access, receiving access in June 2004. However, the sanitization was so thorough that no environmental sampling was possible, and the Iranians refused to give the IAEA access to the rubble that had been hauled away.
- On Lavisan-Shian, the IAEA states that in 2003, on at least two occasions, "natural uranium was drilled, processed and used" for the production of EDNS. It adds that EDNS produced at Lavisan Shian were "designed for testing" and that they were "integrated into scaled implosion-systems and explosively tested." Some of these tests happened in a high explosive chamber at Parchin, a site not discussed in the IAEA report but discussed in earlier ones.
- The IAEA assesses that the uranium metal used for the production of EDNS was part of approximately 10 kilograms (kg) of undeclared uranium metal produced in conversion experiments at JHL. The IAEA cannot determine whether the same uranium remains unaccounted for, whether it was "consumed," e.g., used in other activities, or whether it was mixed in with declared material. Thus, a certain amount of uranium stemming from JHL work and previously falsely declared by Iran as having been transferred to the uranium conversion facility at Esfahan remains missing.
- The report states that there are indications that neutron detectors and housing for neutron detectors were developed and tested at Lavisan-Shian, and that in 2003, "identical housing for neutron detectors was deployed in an explosive test at Marivan." (See Annex for an image of this housing at the Marivan test site.)
Marivan
An outdoor high-explosive testing site and support area, where Iran carried out large-scale high explosive experiments critical to the development of nuclear weapons. Iran was also evidently planning to make EDNS at the support site.
The IAEA discusses experiments in preparation for what is commonly called a "cold test" of a nuclear weapon, which entails a fully assembled nuclear device with a surrogate core of natural or depleted uranium rather than weapons-grade uranium. It is commonly the final test of a nuclear weapon implosion development program. After a successful cold test, the next step is building the nuclear weapon. Iran sanitized the site in 2019-2021, and the IAEA accessed it in 2020, finding man-made uranium particles.
- On Marivan, the IAEA reveals its assessment that in 2003, Iran conducted "a number" of explosive tests and that four of those tests utilized "full-scale hemispherical implosion systems," involving the initiation of high explosives, with the generation of a spherically inward shock wave, and a resulting compression of a nuclear explosive core, minus the weapons-grade uranium and EDNS.
- The IAEA also assesses that Iran was planning to conduct a cold test that would have contained nuclear material, evidently natural or depleted uranium in the core, in which an EDNS would produce the neutrons that a neutron detector was to detect. It states that Iran conducted a preparatory test of blast shielding for such neutron detectors. The Agency has no information as to whether this planned test or other similar ones were carried out at Marivan.
- Newly, the IAEA reports its assessment that Iran planned to make EDNS at Marivan. This would explain Iran's hasty razing of the Marivan support area following the IAEA's initial request to access the site in 2019.
- While the IAEA visited the Marivan support area and outdoor explosive test site in August 2020, the IAEA states it was not able to access the control bunker during the visit at the explosive site, and that Iran subsequently demolished the bunker.
Varamin
A secret Amad Plan pilot, laboratory-scale uranium conversion plant. Iran sanitized the site in 2004; the IAEA accessed it in 2020. It found man-made uranium particles.
- On Varamin, the IAEA newly provides a timeline and a list of equipment it assesses Iran used at the site and subsequently moved to Turquz-Abad (see below).
- The IAEA assesses that Varamin was set up in 1997 under the Physics Research Center, providing an "organizational link" between Varamin and Lavisan Shian. It assessed that Iran decommissioned and cleaned up the facility in late 2003/2004, "during which equipment and material, including nuclear material, was characterised, sorted, and shipped from the facility." The IAEA describes the equipment as "all essential equipment for a uranium conversion facility," including the presence of small uranium hexafluoride (UF6) cylinders, noting they were heavily contaminated, if not full of UF6. The IAEA notes that Iran took note of the contamination level and whether or not it considered the items "essential" when sorting the equipment.
- The report provides additional details about the shipping containers used to ship the equipment and materials, noting that Iran organized them according to their level of contamination, and that five out of 13 containers were considered by Iran as "essential."
- The IAEA also notes that a follow-on, production-scale facility was planned, codenamed the New Tehran Plant, and that it has "no information whether this additional facility was built." However, other information earlier published by the Institute suggests it was not built during the Amad Plan.
Turquz-Abad
An open-air warehouse in Tehran's Turquz-Abad district that held cargo containers and other items containing nuclear-related equipment and material. The site was sanitized in 2018-2019; the IAEA accessed it in2019 and found man-made uranium particles.
- On Turquz-Abad, the IAEA assesses that nuclear materials and related equipment from Varamin and JHL, and thus possibly from Lavisan-Shian, were stored at Turquz-Abad.
- Using satellite imagery, the IAEA observed Iran moving containers to and from the location from 2010 to 2018.
Modified Code 3.1
Modified Code 3.1 is a safeguards requirement that Iran disclose and provide information about the construction of new nuclear facilities.
- The IAEA reports that Iran continues to refuse to declare the construction of new nuclear facilities and provide key information as required under Modified Code 3.1 of the subsidiary arrangements to its comprehensive safeguards agreement (CSA). The IAEA notes, "Iran remains the only State with significant nuclear activities in which the Agency is implementing a [CSA], but which is not implementing" this code. This failure continues to raise concern that Iran has, will build, or is building additional nuclear facilities in secret, including a secret uranium enrichment plant.
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." [3] 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.
See the PDF for the full Annex.
1. Andrea Stricker is deputy director of the Nonproliferation and Biodefense Program at the Foundation for Defense of Democracies (FDD) and an FDD research fellow. [↩]
2. For fuller descriptions of these four locations, as well as others, and their relationship to today, see David Albright with Sarah Burkhard and the Good ISIS Team, Iran's Perilous Pursuit of Nuclear Weapons (Washington, D.C.: Institute for Science and International Security Press, 2021). [↩]
3. IAEA Board of Governors, Implementation of the NPT Safeguards Agreement in the Islamic Republic of Iran, Resolution adopted on 24 September 2005, GOV/2005/77, September 24, 2005, https://www.iaea.org/sites/default/files/gov2005-77.pdf. [↩]
