The IAEA’s Iran NPT Safeguards Report - September 2022

by David Albright, Sarah Burkhard, and Andrea Stricker [1]

September 8, 2022

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Executive Summary


  • Iran has consistently violated its obligations under its comprehensive safeguards agreement (CSA), a key part of the Nuclear Non-Proliferation Treaty (NPT) to cooperate with the International Atomic Energy Agency (IAEA) and fully account for its past and present nuclear activities.

  • For nearly four years, the IAEA has been investigating the presence of man-made uranium particles at three Iranian sites and was seeking information about nuclear material and activities at a fourth site.

  • In March 2022, the IAEA found Iran in breach of its safeguards obligations for failing to declare its use of nuclear material at one of these sites, Lavisan-Shian. In June 2022, the IAEA’s 35-nation Board of Governors passed a censure resolution against Iran for non-cooperation with the IAEA with only China and Russia voting against.

  • This analysis summarizes and assesses information in the IAEA’s latest NPT safeguards report on Iran, issued on September 7, 2022. It also provides background information on the former Iranian nuclear weapons sites under IAEA investigation.


  • Since the last IAEA report in June, there has been no progress or cooperation from Iran to resolve the outstanding safeguards issues.

  • The IAEA requests “technically credible explanations” regarding the presence and origin of uranium particles detected at the three locations, as well as the “current location(s) of the nuclear material and/or of the contaminated equipment.” Thus, it is unlikely that the four locations publicly discussed by the IAEA are the only remaining sites in Iran with traces of undeclared uranium.

  • The IAEA concludes, as of September 2022, it is “not in a position to provide assurance that Iran’s nuclear program is exclusively peaceful.” This means the IAEA cannot verify Iran’s compliance with its CSA and the NPT and is implying Iran is violating both agreements.


  • It is critical for the IAEA to continue its investigation of Iran’s violations of nuclear safeguards under the NPT. Absent an immediate, marked shift in Iran’s actions, the IAEA Board of Governors should pass a resolution condemning Iran’s non-cooperation and then refer the issue to the UN Security Council.

  • The United States and Europe should refuse Iran’s demands to end the ongoing IAEA investigation as a condition for a revived nuclear deal under the Joint Comprehensive Plan of Action (JCPOA) framework. The West should instead pressure Iran to cooperate with the IAEA by strengthening sanctions, including enacting the so-called snapback of UN sanctions, allowed in case of Iranian non-compliance with the JCPOA.

Latest NPT Safeguards Report

For nearly four years, the IAEA has been investigating the presence of man-made uranium particles at three Iranian sites and was seeking information about nuclear material and activities at a fourth site. The four sites are Turquz Abad, Varamin, Marivan, and Lavisan-Shian, previously referred to by the agency as Locations 1-4. In March 2022, the IAEA found Iran in breach of its safeguards obligations for failing to declare its use of nuclear material at Lavisan-Shian. Out of the four sites of concern, three were discussed in Iran’s Nuclear Archive.

It is unlikely that these four locations are the only remaining sites in Iran with traces of undeclared uranium. In reports and press briefings, IAEA Director General Grossi has voiced concerns about additional unknown locations from which or to which Iran may have moved nuclear material or contaminated equipment.2 Further, the IAEA may have identified additional sites it seeks to access based on information in the Nuclear Archive. The IAEA has been corroborating information in the Nuclear Archive against Iran’s mandatory declaration of nuclear material and activities, in line with the IAEA’s mandate to ensure that Iran’s declaration is correct and complete. On September 7, the Institute published the location of yet another site identified in the Nuclear Archive, where Iran may have carried out tests using uranium.3 While the site was previously known, the Institute only recently obtained the site’s coordinates from officials knowledgeable about the Nuclear Archive. The site, called Golab Dareh, is one of four known sites associated with explosive testing of nuclear weapons components and the development of associated, high-speed diagnostic equipment. It appears to be another site that may harbor traces of undeclared uranium, and there are likely others.

On March 5, 2022, the IAEA and Iran agreed to a timetable for Iran to provide the agency with information and explanations to clarify the IAEA’s discovery of man-made uranium particles at Turquz Abad, Varamin, and Marivan, a process ending with a June 2022 IAEA report. Under its legal nonproliferation obligations, Iran is bound to explain the activities that led to the use or production of this nuclear material. The IAEA noted, as in its previous report, that it “provided Iran with numerous opportunities, in different formats through exchanges and meetings in Vienna and Tehran, to clarify these issues, but without success.” By the time of the director general’s June report, Iran had failed to provide technically credible explanations and the IAEA reported Iran’s failure to comply with the agreed timetable. This led the IAEA’s 35-nation Board of Governors to pass a censure resolution against Iran at the June board meeting with only Russia and China voting against it.

In its latest report, the IAEA reports no further progress or cooperation from Iran, noting, “The safeguards issues related to these three locations remained outstanding.” The report indicates, “…Despite the Agency’s stated readiness to engage with Iran without delay to resolve these issues, Iran has not engaged with the Agency. Consequently, there have been no developments in this reporting period and none of the outstanding issues have been resolved.” The director general writes that he “is increasingly concerned that Iran has not engaged with the Agency on the outstanding safeguards issues during this reporting period and, therefore, that there has been no progress towards resolving them.”

The IAEA, in essence, reports that Iran is in breach of the NPT and will remain so until it cooperates. It “reiterates that unless and until Iran provides technically credible explanations for the presence of uranium particles of anthropogenic origin at three undeclared locations in Iran and informs the Agency of the current location(s) of the nuclear material and/or of the contaminated equipment, the Agency will not be able to confirm the correctness and completeness of Iran’s declarations under its Comprehensive Safeguards Agreement. Therefore, the Agency is not in a position to provide assurance that Iran’s nuclear programme is exclusively peaceful.”

The IAEA Board of Governors, which next convenes from September 12 to 16, should pass a new censure resolution demanding Iran’s compliance with its NPT obligations. This resolution should include a stipulation that if Iran fails to cooperate by the next board meeting, the board will refer the case to the UN Security Council for countermeasures.

The United States and its European counterparts, Britain, France, and Germany (the E3), should reject Iran’s attempt to link closure of the IAEA’s investigation with renegotiation or re-implementation of the 2015 nuclear deal, known as JCPOA. Iran has demanded the parties ensure the probe’s closure prior to a new deal’s implementation. In addition, if the parties lift sanctions on Iran in the lead-up to a new deal’s re-implementation day, it is unlikely Iran will cooperate with the IAEA. Linking the JCPOA and IAEA probe could also force a showdown with Iran at the IAEA that may end with the United States and E3 voting at the board to preemptively close the IAEA investigation in order to re-implement the deal, much as they did to implement the JCPOA in 2015. Director General Grossi has stood firm, however, saying there can be no political solution to his investigation.

Member states have a second chance to uphold the NPT and send a signal to Iran, as well as other would-be proliferant states, that they will not tolerate NPT violations. Their failure to act will undermine the IAEA’s authority, lead to the NPT’s degradation, and other states seeking nuclear weapons.

IAEA/Atomic Energy Organization of Iran (AEOI) Joint Statement

On March 5, following a visit by Director General Grossi to Tehran, the IAEA and the AEOI released a Joint Statement to “accelerate and strengthen their cooperation and dialogue aimed at the resolution of [outstanding] issues.” The agreement aimed to resolve by the June 2022 board meeting the IAEA’s remaining questions about three undeclared Iranian sites where it found man-made uranium in 2019 and 2020.

In a marked difference from the workplan leading up to the implementation of the JCPOA, the agreement did not commit the IAEA to “close” its investigation or satisfy itself with a series of joint meetings and false Iranian statements or declarations. The IAEA/Iran joint statement denied Iran the opportunity to simply “check the boxes” of a scheme without honest cooperation. As Grossi put it, “There is no artificial deadline [for concluding the investigation], there is no predefined outcome, there is no predefined name for what I am going to do.”

The IAEA reported in June that pursuant to the agreed timeline, Iran provided information to the agency on March 19 described as “predominantly information that Iran had previously provided to the Agency but also included new information, which was subsequently assessed by the Agency. The information provided by Iran did not address all of the Agency’s questions.” The IAEA submitted additional questions to Iran on April 4. The IAEA and Iran met in Tehran on April 12, May 7, and May 17. During the last meeting, “Iran provided separate videos and presentations expanding on its explanations related to Locations 1, 3 and 4.” Still, the IAEA found the explanations to be not technically credible.

IAEA member states must support Grossi’s quest for answers.

Read the full analysis as PDF here.

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

2. For example, Grossi wrote in a May 2022 safeguards report: “[Some of the] isotopically altered particles [found at Turquz Abad] must have come from another unknown location.” See: IAEA Director General, “NPT Safeguards Agreement with the Islamic Republic of Iran,” GOV/2022/26, May 30, 2022,

3. David Albright and Sarah Burkhard, “The Fourth Nuclear-Weapons-Related Testing Site Located: Another Parchin Site, More Undeclared Nuclear Material Possible,” Institute for Science and International Security, September 7, 2022,

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