As reported by Iran International, Kazem Gharibabadi, Iran’s deputy foreign minister, told the media that Russia, China and Iran on Friday, October 24, sent two letters.
One to the UN Secretary General and the President of the Security Council declared: ‘All provisions of Resolution 2231 have now lapsed, and attempts by European countries to reactivate sanctions through the so-called snapback mechanism are illegal and without effect.’
The second letter to IAEA Director General Rafael Grossi stated that Resolution 2231, which endorsed the 2015 Joint Comprehensive Plan of Action (JCPOA), formally expired on Oct. 18: ’With this termination, the reporting mandate of the Director General of the IAEA concerning verification and monitoring under Security Council Resolution 2231 has come to an end,’ and ‘as of 18 October 2025, this matter will be automatically removed from the Board of Governors’ agenda, and no further action will be required in this context.’ The letter added that the IAEA Board of Governors’ decision of Dec. 15, 2015, which authorized verification and monitoring for up to 10 years “remains valid and constitutes the sole guidance which the IAEA Secretariat is obliged to follow.”
Iranian Foreign Minister Abbas Araghchi sent an earlier letter to the UN Secretary General and the President of the Security Council stating that RES/2231’s termination on October 18 was “in full accordance with its explicit provisions,” and all related restrictions on Iran’s nuclear program had now lapsed.
IAEA Director General Rafael Grossi has been speaking regularly to the media. On the bigger picture, he said: “After the twelve-day war, Iran could have cut ties with the international community, withdrawn from the Non-Proliferation Treaty, and become a pariah state like North Korea. It didn’t.” Grossi said continued cooperation between Iran and the agency was vital to prevent escalation; Tehran was allowing inspectors access “in dribs and drabs” for security reasons, while efforts were continuing to rebuild trust and restore routine monitoring.
Where does all that leave the IAEA’s role in RES/2231 and in JCPOA?
What is JCPOA? It is an intergovernmental agreement; it binds the parties to agreed provisions. But it was understood that it has no authority regarding IAEA verification and monitoring of those provisions. Therefore, its Preamble and General Provisions, x, reads: ‘The International Atomic Energy Agency (IAEA) will be requested to monitor and verify the voluntary nuclear-related measures as detailed in this JCPOA. The IAEA will be requested to provide regular updates to the Board of Governors, and as provided for in this JCPOA, to the UN Security Council…’
And Operative Paragraphs 3 and 4 of UNSC/RES/2231 do just that:
‘3. Requests the Director General of the IAEA to undertake the necessary verification and monitoring of Iran’s nuclear-related commitments for the full duration of those commitments under the JCPOA…;’
‘4. Requests the Director General of the IAEA to provide regular updates to the IAEA Board of Governors and, as appropriate, in parallel to the Security Council on Iran’s implementation of its commitments under the JCPOA…’
In 3., note ‘for the full duration of those commitments’. That applies to the commitments greater than 10 years. And it is supported by the paragraph in the Introduction to RES/.2231: ‘Strongly supporting the essential and independent role of the International Atomic Energy Agency (IAEA) in verifying compliance with safeguards Agreements… and recognizing the IAEA’s important role in supporting full implementation of the JCPOA.’ Note ‘full implementation’.
Consider that the position of Russia, China and Iran prevails, and RES/2231 ended on October 18, 2025, without the ‘snapback’ sanctions. Operative Paragraph 8 applies: ‘Decides … that on the date ten years after the JCPOA Adoption Day, … all the provisions of this resolution shall be terminated, and none of the previous resolutions described in paragraph 7 (a) shall be applied…’ Note ‘all provisions’. Does that override the “full duration of those commitments’ in Operative Paragraph 3? I do not think so; I think the intent was that Iran and IAEA would continue to implement the commitments lasting for 15, 20 and 25 years. Since those commitments did not rise to the level of ‘international peace and security’, the Security Council did not have to be involved.
The commitments were laid out specifically in paragraph 15 of the body of JCPOA under Nuclear, TRANSPARENCY AND CONFIDENCE BUILDING MEASURES:
‘Iran will allow the IAEA to monitor the implementation of the voluntary measures for their respective durations, as well as to implement transparency measures, as set out in this JCPOA and its Annexes. These measures include: a long-term IAEA presence in Iran; IAEA monitoring of uranium ore concentrate produced by Iran from all uranium ore concentrate plants for 25 years; containment and surveillance of centrifuge rotors and bellows for 20 years; use of IAEA approved and certified modern technologies including on-line enrichment measurement and electronic seals; and a reliable mechanism to ensure speedy resolution of IAEA access concerns for 15 years, as defined in Annex I. (JCPOA Annex I – Nuclear-related measures, A. GENERAL, 1., states:‘…Unless otherwise specified, the durations of the commitments in this Annex are from Implementation Day.’)
On that basis, I believe Araghchi has overstated, saying “all related restrictions on Iran’s nuclear program had now lapsed.” I believe those JCPOA provisions continue in force after RES/2231 has ended and should be implemented by Iran and IAEA. But I may be wrong!
Now consider that the position of Russia, China and Iran does not prevail, and ‘snapback’ sanctions are in effect. RES/2231 Operative Paragraph 9 and 12 apply:
‘9. Decides, acting under Article 41 of the Charter of the United Nations, that the terminations described in Annex B and paragraph 8 of this resolution shall not occur if the provisions of previous resolutions have been applied pursuant to paragraph 12;’
‘12. Decides, acting under Article 41 of the Charter of the United Nations, that, if the Security Council does not adopt a resolution under paragraph 11 to continue in effect the terminations in paragraph 7 (a), then …after the thirtieth day …, all of the provisions of resolutions 1696 (2006), 1737 (2006), 1747 (2007), 1803 (2008), 1835 (2008), and 1929 (2010) that have
been terminated pursuant to paragraph 7 (a) shall apply …, and the measures contained in paragraphs 7, 8 and 16 to 20 of this resolution shall be terminated, unless the Security Council decides otherwise’.
And here is paragraph 8:
‘8. Decides... that on the date ten years after the JCPOA Adoption Day, … all the provisions of this resolution shall be terminated, and none of the previous resolutions described in paragraph 7 (a) shall be applied, …’
So, with paragraph 8 terminated by paragraph 12, it would appear to me that RES/2231 would not end on Termination Day, October 18, 2025, and neither would JCPOA provisions. But, again, I may be wrong.
What does all that add up to? I believe that with Russia chairing the Security Council through October, the Russia, China, Iran view prevails. Regular updates (quarterly reports) by IAEA to the Security Council should stop, unless the IAEA Board of Governors decides otherwise. In November, under a new chair, the Security Council may address this matter again. In both cases, IAEA implementation of JCPOA provisions beyond 10 years should continue. So, we will keep tuned.
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