February 2025

A. Back to basics – the JCPOA timeline. Annex V of the 2015 Joint Comprehensive Plan of Action (‘JCPOA’ or Iran Nuclear Deal) sets out the Agreement’s anticipated 10-year timeline:

· Adoption Day (18 October 2015): 90 days after UN Security Council endorsement
· Implementation Day (16 January 2016): Iran met specified nuclear steps and sanctions relief was activated
· Transition Day (18 October 2023): 8 years after Adoption Day, or earlier if the IAEA issued its “Broader Conclusion” about Iran’s nuclear material. On this date, further EU/US sanctions relief was due, and Iran was to pursue ratification of the Additional Protocol
· UNSCR Termination Day (18 October 2025): 10 years after Adoption Day. On this date, the UN Security Council resolution endorsing the JCPOA automatically expires/terminates, provided sanctions have not been reinstated (“snapback”). This means the UNSC would no longer be seized with the Iran file, and the remaining JCPOA-related restrictions under the resolution end

October 2025 therefore marks the formal international end date of the UN’s JCPOA resolution (2231) unless the deal has collapsed beforehand.

B. What should happen on October 18th. At the UN level all provisions of UNSCR 2231 end, including restrictions on Iran’s nuclear activities (procurement channel, transfers of sensitive nuclear-related technology), limitations on enrichment R&D, stockpiles, etc. (though some had shorter timelines and already lapsed earlier) and the UNSC’s oversight role of Iran’s compliance with the JCPOA. The special Procurement Channel (requiring UNSC approval for Iran to import nuclear-related dual-use materials) also terminates, allowing Iran to legally import such items, provided it follows IAEA safeguards.

The EU must terminate all remaining provisions of Council Regulation (EU) No 267/2012, Council Decision 2010/413/CFSP, and any remaining restrictive measures tied to nuclear activities, i.e. all remaining nuclear-related sanctions.

The Agreement text says that by Transition Day (2023), the US would already have sought legislative action to end many nuclear-related sanctions, and by Termination Day (2025), its expectation was that all nuclear-related US secondary sanctions tied to the UNSC framework would be gone, aligning Iran with the treatment of other Non-Proliferation Treaty (NPT) states. In practice, US compliance ended in 2018 with the Trump withdrawal, making US obligations at this point moot.

C. What is likely to happen. Years of Iranian non-compliance with the JCPOA, in fairness stemming from Trump’s withdrawal from the deal, means that Iran will not enjoy full sanctions relief on October 18th:

· The default outcome without action is that UNSCR-2231 expires and snapback authority ceases to exist on Termination Day. This will be the case provided sanctions have not been reinstated (“snapback”).

· Any remaining JCPOA participant (e.g., UK, France, Germany, China, Russia) can instigate snapback unilaterally by notifying the UNSC of “significant non-performance” by Iran; 30 days later, all prior UN Iran sanctions automatically return, with no veto possible. Any objective assessment of Iran’s behaviour (expelling inspectors, concealing enriched uranium, continuing high-level enrichment and refusing to account for undeclared material) points to significant non-performance. The IAEA’s ability to verify compliance is already heavily constrained after Iran curtailed inspector access and disabled monitoring cameras. That verification gap itself strengthens the E3 case for snapback, since the absence of transparency is treated as non-compliance.

· Europe (E3/EU) will not lift sanctions – and has form here: on Transition Day, the EU kept non-proliferation restrictions and listings that were supposed to sunset, citing Iran’s non-compliance. The UK issued a parallel statement at that time. A year later the EU further widened its Iran framework to cover missiles and drones and support to Russia and regional groups, again showing Europe’s readiness to sustain/expand autonomous sanctions outside the JCPOA calendar.

· The E3 (France, Germany, UK) warned the UN in writing that they are prepared to trigger UN snapback by late August/early September absent Iranian movement in on-going talks. As the US cannot credibly trigger snapback itself, it has urged the E3 to do so; Congress has formally called on the E3 to initiate snapback before October.

This means that we can expect US political backing and parallel US designations to amplify any move at the UN by the E3.

D. What snapback would look like. At the UN level prior Iran resolutions (1696, 1737, 1747, 1803, 1835, 1929) would be restored, covering arms and missile-related embargoes, nuclear-related asset freezes and technology/transfer bans. These would again be binding on all UN members. Procedurally, re-imposition happens 30 days after the notification. Also expect national measures on top of UN sanctions by the EU, UK and US, with the US continuing and expanding secondary sanctions in the energy, banking and shipping sectors.

E. What the consequences will be. Snapback would result in severe economic consequences for Iran and wider diplomatic ramifications:

· Iran’s main revenue stream (oil & gas) would be hit hardest with exports shrinking further, exacerbated by access to global payment systems being blocked and investments deterred. Modernization of oil and gas facilities will stall as critical parts and technology imports are once again cut off, and even basic upkeep becomes harder, reducing production capacity (Iran had been expanding output, targeting 600,000+ bpd by year end). Exports currently hover around 1.5–1.7m bpd, almost all to China. A restored UN embargo plus tougher US secondary sanctions could force flows sharply lower unless Beijing decides to openly defy snapback. That tension will be a major test of how far China is prepared to shield Iran’s economy.

· In the past weeks Iran has threatened withdrawal from the nuclear Non-Proliferation Treaty (NPT), nuclear programme acceleration and military escalation, which could include the Gulf maritime disruption threatened during the Israeli attacks. Iran coordinated with Russia and China at the Iranian Mission to the UN in New York in late July, allegedly aimed at shielding Iran from sanctions.

· Further, snapback could collapse remaining negotiation channels, leading to a downward spiral in regional relations.

· The IRGC has used its media channels to prepare the population for snapback, with its political outlet Sobhe Sadegh urging a shift from “hope-building” to preparing the public psychologically for economic and social shock.

· The IRGC’s public warnings align with a leaked intelligence report issued by the Ministry of Intelligence to Iranian Government Ministries and state-owned enterprises. The note emphasises the potential for severe negative impacts including currency volatility, falling purchasing power, rising unemployment & layoffs and further social unrest/discontent and warns of cyberattacks on supply chains, automation systems and the country’s financial infrastructure. The Intelligence Ministry urged officials to seek alternative suppliers in China, Russia, Iraq and other less sanction-sensitive states. Currency volatility is already visible in black-market rates, and another sanctions cycle could trigger a steep Rial slide, driving inflation and raising the risk of renewed street protests.

F. The deeper domestic context. All this in the shadow of the 12-day war. The Supreme Leader is taking a much lower profile. His absence has left a political vacuum, especially in disciplining factional disputes, a role he previously handled personally. The IRGC has stepped in as enforcer, warning elites to keep rivalries private to avoid weakening Iran’s negotiating hand with the west. The Supreme Leader’s lower profile is fuelling speculation over succession, with the IRGC increasingly seen as the ultimate arbiter of elite disputes. That dynamic narrows space for pragmatists like Pezeshkian and hardens Iran’s external posture.

In one case, hardliner Saeed Jalili (ex-presidential candidate) publicly criticised advocates of renewed US talks as “golden calf worshippers” (implying betrayal in Farsi). IRGC media (Javan, Tasnim) slammed him for damaging unity, resulting in Jalili backtracking, publicly citing Khamenei’s April statement supporting Oman-mediated talks with Washington. In a second example, President Masoud Pezeshkian defended the idea of talks, asking critics, “What’s your alternative—fight and absorb more strikes?” Reformists praised his “realism”; hardliners accused him of “surrender.” The IRGC’s political chief Aziz Ghazanfari praised Pezeshkian’s honesty but warned him to avoid blunt public remarks, urging adherence to pre-approved scripts.