(1)

On 26 July 2010, the Council adopted Decision 2010/413/CFSP (1), concerning restrictive measures against Iran.

(2)

On 14 July 2015, China, France, Germany, the Russian Federation, the United Kingdom and the United States, supported by the High Representative of the Union for Foreign Affairs and Security Policy (the ‘High Representative’), reached an agreement with Iran on a long-term comprehensive solution to the Iranian nuclear issue. The full implementation of the Joint Comprehensive Plan of Action (JCPOA) was to ensure the exclusively peaceful nature of the Iranian nuclear programme, and provide for the comprehensive lifting of all nuclear-related sanctions.

(3)

On 20 July 2015, the United Nations Security Council (UNSC) adopted Resolution 2231 (2015) endorsing the JCPOA, urging its full implementation in accordance with the timetable established in the JCPOA and providing for actions to take place in accordance with the JCPOA.

(4)

On 20 July 2015, the Council welcomed and endorsed the JCPOA and committed itself to abiding by its terms and to following the agreed implementation plan. The Council also fully supported UNSC Resolution 2231 (2015).

(5)

On 18 October 2015, the Council adopted Declaration 2015/C 345/01 (2), noting that the commitment to lift all Union nuclear-related sanctions in accordance with the JCPOA was without prejudice to the dispute resolution mechanism set out in the JCPOA and to the reintroduction of Union sanctions in case of significant non-performance by Iran of its commitments under the JCPOA. Furthermore, the Council committed to reintroducing without delay all Union nuclear-related sanctions that had been suspended or terminated, in the event of significant non-performance by Iran of its commitments under the JCPOA upon a joint recommendation to the Council by the High Representative, France, Germany and the United Kingdom.

(6)

On 14 January 2020, the High Representative, as Coordinator of the Joint Commission of the JCPOA (the ‘Coordinator’), received a letter from the Foreign Ministers of France, Germany and the United Kingdom referring a matter concerning the implementation of Iran’s commitments under the JCPOA to the Joint Commission for resolution through the Dispute Resolution Mechanism, as set out in paragraph 36 of the JCPOA. On the same day, the Coordinator issued a statement indicating that he would oversee the Dispute Resolution Mechanism process (the ‘process’).

(7)

On 24 January 2020, the Coordinator issued a statement indicating that, pursuant to the process, he had undertaken extensive bilateral and collective consultations and that all JCPOA participants had reconfirmed their determination to preserve the JCPOA, which was in the interest of all. The Coordinator indicated that, notwithstanding differences on modalities, there was agreement that more time was needed due to the complexity of the issues involved. The timeline for the process was therefore extended. All parties involved agreed to pursue expert-level discussions addressing concerns regarding nuclear implementation, as well as the wider impact of the withdrawal of the United States from the JCPOA and its re-imposition of sanctions against Iran, concerning which all JCPOA participants had expressed regret.

(8)

On 21 December 2020, in a Joint Ministerial Statement on the JCPOA, the JCPOA participants re-emphasised their commitment to preserving the agreement and stressed their respective efforts in that regard. The statement underlined that the Ministers had discussed how full and effective implementation of the JCPOA by all remained crucial, as well as the need to address ongoing implementation challenges, including on nuclear non-proliferation and sanctions-lifting commitments. The Ministers agreed to continue their dialogue in order to ensure full JCPOA implementation by all sides. The Ministers acknowledged the prospect of a return of the United States to the JCPOA and underlined their readiness to positively address that return in a joint effort.

(9)

From April 2021 to August 2022, the Coordinator led diplomatic talks to negotiate the return of the United States to the JCPOA and to ensure the full and effective implementation of the JCPOA by Iran. Despite those efforts, including several meetings of the Joint Commission during that period, it was not possible to reach an agreement.

(10)

On 14 September 2023, the Coordinator received a letter from the Foreign Ministers of France, Germany and the United Kingdom related to the implementation of the JCPOA. The Foreign Ministers stated that Iran was in non-compliance since 2019 and that they considered that this had not been resolved through the process. They expressed their intention not to take steps regarding the lifting of further sanctions on 18 October 2023, the JCPOA Transition Day. On the same date, the Coordinator issued a statement indicating that that he had circulated the ministerial letter to the other JCPOA participants, and that he would consult with all JCPOA participants on the way forward.

(11)

On 6 October 2023, the Coordinator issued a statement indicating that following consultations with JCPOA participants, the issue concerning the implementation of Iran’s commitments under the JCPOA remained unresolved given the diverging views expressed.

(12)

On 16 October 2023, the Council adopted Decision (CFSP) 2023/2195 (3), which amended Decision 2010/413/CFSP. The Council considered that the Union had valid grounds for maintaining after JCPOA Transition Day the restrictive measures against certain persons and entities listed in Annexes I and II to Council Decision 2010/413/CFSP and Annexes VIII and IX to Council Regulation (EU) No 267/2012 (4). Therefore, the names of those persons and entities were transferred from Annex I to Council Decision 2010/413/CFSP to Annex II to that Decision and from Annex VIII to Council Regulation (EU) No 267/2012 to Annex IX to that Regulation.

(13)

The Council further considered that the Union had valid grounds for maintaining after JCPOA Transition Day the restrictive measures on financial messaging services, related to the transport sector, related to proliferation-sensitive nuclear activities and associated services, and those on metals and associated services, on software and associated services, and on arms and associated services.

(14)

The Council also considered that the Union had valid grounds for not terminating, after JCPOA Transition Day, the restrictive measures which were suspended on JCPOA Implementation Day by Council Decision (CFSP) 2015/1863 (5).

(15)

On 28 August 2025, the Coordinator and the President of the UNSC received a letter from the Foreign Ministers of France, Germany and the United Kingdom related to the implementation of the JCPOA. Through this letter, the Foreign Ministers notified the UNSC that, based on factual evidence, they believed Iran to be in significant non-performance of its commitments under the JCPOA, thereby opening the procedure to reinstate the UN sanctions lifted under UNSC Resolution 2231 (2015), in line with paragraph 11 of UNSC Resolution 2231 (2015).

(16)

On 29 August 2025, in line with Council Declaration 2015/C 345/01, the High Representative, France and Germany sent a joint recommendation to the Council, recommending that all Union nuclear-related sanctions that had been suspended or terminated, or both, be reintroduced without delay once the UN sanction have been reinstated, in line with UNSC Resolution 2231 (2015).

(17)

By 27 September 2025, the UNSC had not adopted a new resolution to continue lifting sanctions within 30 days of the notification of 28 August 2025. Therefore, in line with the provisions of paragraph 37 of the JCPOA, the provisions of UNSC Resolutions 1696 (2006), 1737 (2006), 1747 (2007), 1803 (2008), 1835 (2008) and 1929 (2010) are to be re-imposed.

(18)

The Council considers that the Union has valid grounds for re-imposing all Union nuclear-related sanctions on Iran that have been suspended or terminated under the JCPOA.

(19)

In this context, the Council also considers that given Iranian proliferation activities, particularly as regards items, materials, equipment, goods and technology contained in the Nuclear Suppliers Group and Missile Technology Control Regime lists, the most stringent restrictions should be maintained.

(20)

In line with the provision set out in paragraph 37 of the JCPOA, the re-imposition of restrictive measures is not to apply with retroactive effect to contracts concluded before 30 September 2025, or of ancillary contracts for the execution of such contracts, provided that the activities contemplated under, and the execution of, such contracts are consistent with the JCPOA and the re-imposed provisions.

(21)

Further action by the Union is needed in order to implement certain measures.

(22)

Decision 2010/413/CFSP should therefore be amended accordingly,

(1)

in Article 1, paragraph 2 is replaced by the following:

(2)

Article 3c is replaced by the following:

(3)

Article 3d is replaced by the following:

(4)

in Article 4b, paragraphs 1, 2, 3 and 4 are replaced by the following:

(5)

Article 4f is replaced by the following:

(6)

Article 4h is replaced by the following:

(7)

Article 4j is replaced by the following:

(8)

Article 7 is replaced by the following:

(9)

Article 15 is amended as follows:

(10)

Article 18 is replaced by the following:

(11)

Article 19 is amended as follows:

(12)

Article 20 is amended as follows:

(13)

Article 22 is replaced by the following:

(14)

Article 23 is replaced by the following:

(15)

in Article 24, paragraphs 1 and 2 are replaced by the following:

(16)

Article 25 is replaced by the following:

(17)

Article 26 is amended as follows:

(18)

Articles 26a, 26b, 26c, 26d, 26f and 26g are deleted;

(19)

Annexes III, IV, V and VI are deleted.