By David Albright and Olli Heinonen1
August 31, 2017
Summary
The International Atomic Energy Agency (IAEA) made at best a general statement in its last
quarterly reporting (spring 2017) about its monitoring and verification of Section T, annex 1 of
the Joint Comprehensive Plan of Action (JCPOA). This innovative, key section closes a loophole in the Nuclear Non-Proliferation Treaty (NPT), explicitly banning Iran from undertaking certain
nuclear weapons development activities and controlling dual-use equipment potentially usable
in such activities. At the same time, the Iranian authorities have repeatedly stated that its
military sites are off limits to the IAEA, indicating that the IAEA currently has limited or no
access to Iranian military sites.2 Such access is an essential part of a broader effort to verify
Section T undertakings of Iran.
Discussions have frequently mischaracterized the verification of Section T (and associated access
to military sites) as a problem of finding violations via national means and then reporting them
to the IAEA for follow-up. In fact, the nature of the Section T conditions is analogous to verifying
that allowed activities and equipment are not misused in a manner similar to verifying declared
nuclear activities. Moreover, certain activities and equipment are subject to Joint Commission
approval. It is likely that some of the conditions in Section T are not currently being met and
may in fact be violated by Iran. If it has not already done so, the United States should also
establish (1) a list of equipment in Iran controlled under Section T, including any that may
currently be outside of required Section T controls and (2) a list of Iranian sites associated with
Section T, either because of activities or equipment at these sites. The United States and other
members of the P5+1 should press the IAEA to develop and establish an effective, credible
verification regime under Section T that includes access to military sites and the sharing of relevant information. The United States and Britain, France, and Germany should also raise
Section T and the likely need for approvals of certain Iranian equipment and activities at the
next Joint Commission meeting. Toward that goal, Iran should declare to the IAEA its sites and
equipment subject to Section T verification and approvals.
