Ticking the Boxes: Tehran’s Road to ‘Implementation Day’

The ‘implementation day’ of the Iranian nuclear agreement comes after the International Atomic Energy Agency (IAEA) confirmed that Tehran had, in effect, complied with its key obligations under the Joint Comprehensive Plan of Action (JCPOA). Since October, Iran has been rapidly working towards meeting its obligations, curbing its most sensitive nuclear activities and co-operating closely with the IAEA. 

Iran’s greatest challenge was implementing the ‘Road-map for the Clarification of Past and Present Outstanding Issues’, agreed with the IAEA in order to provide a framework for resolving international concerns about the possible military dimensions of its nuclear programme. Following the implementation of the roadmap, the IAEA closed its file on the possible military dimensions of Iran’s nuclear programme in mid-December. In accordance with the steps specified in the JCPOA, in the meantime, Iran has:

• Removed two-thirds of its 19,000 centrifuges, limiting the total number of operational centrifuges at its Natanz and Fordow enrichment facilities to 6,104
• Removed the core from its Arak heavy-water reactor to prevent the facility from producing any weapons-grade plutonium; it has also agreed an outline for the redesign of the reactor with the P5+1 
• Removed 98 per cent of its stockpile of low-enriched uranium, shipping the majority to Russia, leaving it with a remaining stockpile of 300 kg, less than a quarter of the amount required to produce one nuclear weapon if further enriched 
• Capped its level of uranium enrichment to 3.67 per cent U-235, substantially below what would be needed for nuclear-weapons production.

Despite opposition within Iran, President Hassan Rouhani’s administration has kept its commitment to proceed smoothly with the implementation of the deal and has reiterated this pledge to gain domestic support. The president has invested two years of political capital into the resolution of the nuclear standoff. After concluding the historic agreement, he had the challenging task of showcasing its benefits at home, especially in light of the parliamentary election to be held next month. Given that hardliners in the country could make electoral gains, Rouhani had to demonstrate that the deal would result in major economic improvements. This meant complying with its requirements and getting to implementation day quickly. 

The Next Phase

Implementation day is not the end of the matter – the process which lies ahead will be no less technical and arguably even more procedural. During the next stages of the agreement, Tehran must allow the IAEA to conduct enhanced levels of monitoring; it will also have to adhere to new legal frameworks governing the Agency’s access to the country’s nuclear sites. The IAEA will be able to request information and inspections to verify that the country is not building undeclared nuclear facilities or engaging in weapons-related work. Iran will also need to prove that its research and development activities at the Natanz site are conducted ‘in a manner that does not accumulate enriched uranium’, and that no enrichment is taking place at the Fordow facility, converted into a nuclear, physics and technology research centre. Furthermore, Iran will be required to seek approval for all nuclear-related procurement from a designated procurement channel which will require Iran to submit appropriate documentation and end-use declarations. Each purchase will proceed through national licensing agencies around the world and parties to the JCPOA will have twenty days (extendable to thirty) to consider the proposed export. 

Co-operation is Key

Intensive co-ordination between domestic actors in Iran will be required to implement these highly technical processes. In light of the number of individuals and entities which have been involved in the nuclear programme, whether through facility construction or management or overseas procurement, this could be particularly challenging. Accusations of foul play may occur if one entity fails to co-ordinate its activities. 

Domestic co-ordination in other countries will also be necessary, particularly when it comes to the expanded licensing processes for nuclear-related exports. Local agencies in foreign countries must ensure that relevant exports are identified, accompanied by the required documentation and receive approval from the international working group before proceeding.

Yet it is international co-ordination between Iran, its JCPOA partners and the IAEA that will be most essential for smoothing any bumps as the country approaches the next milestone in about eight years: a confident conclusion by the IAEA that all nuclear material in Iran is used in peaceful activities.

Aniseh Bassiri Tabrizi - Research Analyst, International Security Studies, RUSI

Implementation Day: Analysing Iran's Compliance of the Nuclear Deal 

• Introduction
• Political Challenges to the Iran Deal in Tehran and Washington
• Ticking the Boxes: Tehran’s Road to ‘Implementation Day’
• The Devil is in the Detail: The Financial Risks to the Economic Success of the Iran Deal
• Iran Implementation Day Recommendations