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Summary of JCPOA Implementation

Introduction:
The Joint Comprehensive Plan of Action (JCPOA) was negotiated from the fall of 2013 to the date
of announcement of the agreement on July 14, 2015 (Finalization Day) by the U.S., UK, France,
Germany, Russia, China and Iran, with participation of the European Union. The final agreement, a
159-page document, is one of the most complex and carefully elaborated arms control agreements
in recent times and reflects the high level of technical, scientific, and political detail that had to
be considered by each of the seven negotiating parties. The agreement includes a timeline that
extends from Adoption Day (October 18, 2015) to Termination Day (October 18, 2025) and beyond.
The JCPOA Commission, made up of representatives of the negotiating powers, is responsible
for executing the agreement. This summary provides a brief outline of this complex document
including steps to be taken in the years ahead, as well as permanent commitments made by Iran
and other parties.

1. Completed Benchmarks of JCPOA:

1. Finalization Day (July 14, 2015). Iran and P5+1 countries endorse the JCPOA. Iran and the IAEA
begin working on arrangements to implement transparency measures.
1.1 U
 N Security Council Endorses the JCPOA (July 20, 2015) with Resolution 22311 and votes
unanimously to terminate all prior UN nuclear-related sanctions upon Implementation
Day subject to re-imposition through a snapback mechanism. Iran and the IAEA begin
developing arrangements to implement transparency measures. 2
1.2 P
 MD Roadmap Engagement Begins (JulyDecember 2015). During this period, Iran
provides explanations and documents to the IAEA on outstanding issues regarding the
Potential Military Dimension (PMD). 3
1.3 C
 ongressional Review Period Expires (September 16, 2015) as mandated by the
bipartisan Iran Nuclear Review Act. 4
1.4 I ranian Parliament and Guardian Council Approve the JCPOA (October 14, 2015)
bringing the Iranian governments review process to a close. 5
1.5 I AEA Confirms Irans Completion of all Activities, Addressing Concerns Over its Past
and Present Nuclear Program (October 15, 2015), including addressing any outstanding
ambiguities and providing IAEA inspectors with access to information and sites.
1. R
 esolution 2231 (2015), Adopted by the Security Council at its 7488th meeting, on 20 July 2015, for full text see:
http://www.un.org/en/ga/search/view_doc.asp?symbol=S/RES/2231%282015%29
2. F
 or the Finalization Day text, go to: https://www.documentcloud.org/documents/2165441-iran-nuclear-deal.
html#document/p153
3. T
 he IAEA receives information from Iran under Road-map Agreement. See: https://www.iaea.org/newscenter/pressreleases/
iaea-receives-information-iran-under-road-map-agreement
4. F
 or full text, see: https://www.congress.gov/bill/114th-congress/house-bill/1191/text/pl
5. 1
 61 members of Irans Parliament supported the JCPOA and 59 disapproved, while 13 abstained.
For more see: http://bigstory.ap.org/article/aa3498ac7dc842cf8266bfa5ad7a26a0/top-iranian-council-approves-nuclear-deal

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2. Adoption Day (October 18, 2015)

2.1 I ran Implements Additional Protocol (October 15, 2015) and notified the IAEA that it
will provisionally begin implementation of the IAEAs Additional Protocol (an enhanced
inspections regime) and Modified Code 3.1 beginning on Implementation Day.
2.2 T
 he U.S. and China Co-chair the Arak Reactor (IR-40) Modernization working
group and release a joint statement on its new framework. JCPOA participants begin work
on redesigning the IR-40 reactor.
2.3 U
 .S. Prepares to Cease Application of Most Nuclear-related Sanctions on
Implementation Day via presidential waivers. 6
2.4 E
 U Adopts Regulations to Terminate Virtually all Nuclear-related Sanctions on
Implementation Day, subject to snap-back commitments. 7
2.5 P
 MD Final Report Submitted (December 2, 2015). IAEA Director General provides its
Board of Governors the final assessment of the resolution of all of Irans Possible Military
Dimensions (PMD) issues. 8

3. Implementation Day (January 16, 2016). IAEA verification that Iran has complied with
all nuclear-related measures.
3.1 Steps Taken by Iran
Removes IR-40 calandria from the Arak Reactor and fills it with cement.
Places all Arak fuel under IAEA supervision and cannot produce or test natural uranium
pellets, fuel pins or fuel assemblies designed for the Arak Reactor.
Ships out excess heavy water (this shipment was fully completed in February 2016).
Disassembles, removes and stores under IAEA seal, 13,000 IR-1 centrifuges at Natanz
Enrichment Complex (this includes 1,008 IR-2M centrifuges installed but not operating
in the main hall at Natanz).
Limits all IR-1 operating centrifuges to 5,060, and cascades, in their current
configuration, to no more than 30 at Natanz (for 10 years).
Removes advanced centrifuges (IR-2m and IR-4) test cascades.
Reduces to 1,044 IR-1 centrifuges at the Fordow Fuel Enrichment Plant, two cascades of
which will be operational for non-uranium enrichment work.
Removes all nuclear material from Fordow (Iran cannot conduct any uranium
enrichment or related Research and Development (R&D), or have any nuclear material
at Fordow for 15 years).

6. F
 or President Obamas statement on adoption day, see: https://www.whitehouse.gov/the-press-office/2015/10/18/
statement-president-adoption-joint-comprehensive-plan-action
7. F
 or the joint statement by EU High Representative Federica Mogherini and Iranian Foreign Minister Javad Zarif,
see: http://eeas.europa.eu/statements-eeas/2015/151018_01_en.htm
8. T
 o see the final assessment on the past and present outstanding issues on Irans nuclear program, including PMD,
see: https://assets.documentcloud.org/documents/2631873/IAEA-document.pdf

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Submits long-term R&D plan to IAEA, limiting R&D on advanced centrifuges, in

particular. Ongoing R&D is not permitted to accumulate enriched uranium and limits
testing at two locations, Natanz and the Tehran Research Center (mechanical testing
only) for 15 years.
Reduces 3.67% uranium stockpile to 300kg or less (for 15 years).
Caps uranium enrichment at 3.67% of U-235 (for 15 years).
All uranium oxide enriched above 5% and up to 20% is fabricated into fuel plates for the
Tehran Research Reactor, transferred outside Iran, or diluted to an enrichment level of
3.67% or less.
Iran is only permitted to replace broken or damaged active IR-1 centrifuges from its
stock of monitored stored machines and is only permitted to produce new machines
should its store of IR-1s fall below 500.
Provisionally implements the Additional Protocol and fully implements Modified Code 3.1.
Provides the IAEA with inventory of all centrifuge manufacturing components.
Maintains its nuclear program at the above restricted level.
Made a 15-year commitment not to reprocess spent fuel.
Agrees to only import dual-use materials with prior approval from the
Joint Commission.
Requests approval from the Joint Commissions procurement working group prior to
importing or purchasing any dual-use technologies and materials, except for certain
cases detailed in UN Security Council Resolution 2231 (10 years).
3.2 S
 teps Taken by the UN Security Council. Passes a new UNSC Resolution 2231 that
terminates all previous Iran UNSCRs and sanctions related to Irans nuclear program,
but maintains a snapback mechanism to re-impose sanctions should a major violation be
detected. The UNSC also includes specific restrictions, including regarding the transfer of
proliferation-related goods. 9 Resolution 2231 called upon Iran not to test ballistic missiles
capable of delivering nuclear warheads either for a period of 8 years or until the IAEA
reaches its Broader Conclusion, whichever is sooner. Under the resolution, ballistic missile
sanctions remain in place for 8 years and there is a prohibition on sales of heavy weaponry
(tanks, large caliber artillery, armored vehicles, warships, missiles, etc.) for 5 years or until
the IAEA reaches its Broader Conclusion, whichever is sooner.
3.3 Steps Taken by the U.S.
The U.S. suspends sanctions of non-U.S. persons, as it relates to Irans nuclear issue.
The U.S. lifts sanctions on: foreign subsidiaries of U.S. firms; exports of civil aviation
goods and services to specific Iranian airlines (provided they have a license); and on
imports of rugs and food from Iran.
The U.S. suspends sanctions on non-U.S. trade with Iran, provided such trade does not
involve activities in support of terrorism, violations of human rights, or restricted arms
and ballistic missile-related goods and services.
9. I n adopting the new UNSC Resolution 2231, the provisions in UNSC 1696, 1737, 1747, 1803, 1834, 1929, 2224 are terminated
but subject to re-imposition in the case of a serious violation.

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The U.S. begins to license the export of goods for civil aviation in Iran, subject to
revocation if Iran uses this support for military means.
The U.S. licenses the import of Iranian rugs and food goods.
The U.S. licenses foreign incorporated subsidiaries of U.S. companies to operate as
purely foreign companies for purposes of sanctions enforcement.
3.4 Steps Taken by the EU
The EU terminatessubject to re-imposition if Iran violates the dealall sanctions
imposed on Iran except for those dealing with Irans support for terrorism, violations of
human rights, and restricted arms and ballistic missile-related goods and services.
3.5 Steps Taken by the IAEA
IAEA verifies Iranian compliance with listed measures.
IAEA begins providing regular quarterly updates on the JCPOA to the IAEA Board of
Governors and the UNSC.
3.6 J oint Commission of the JCPOA, established under the JCPOA on Finalization Day
(July 14, 2015), meets for the first time on October 19, 2015. 10 The Joint Commission is
comprised of representatives from each of the P5+1 countries, Iran, and the EU, and meets
quarterly, or upon request of one of the participants.

4. Future Benchmarks of the JCPOA

4.1 U
 NSC Lifts Arms Import and Export Restrictions (October 18, 2020 which is Adoption
Day +5 years or the IAEA Broader Conclusion, whichever is sooner). The Broader
Conclusion is an IAEA finding that there are no undeclared nuclear material or activities
and that there are no indications of diversion of nuclear material.
4.2 T
 ransition Day (October 8, 2023 which is Adoption Day +8 years, or IAEA Broader
Conclusion, whichever is sooner)
Iran seeks Majlis ratification of the Additional Protocol.
UNSC restrictions on ballistic missiles are lifted.
UNSC financial restrictions on listed/sanctioned officials are lifted.
U.S. seeks legislative termination of sanctions suspended or waived as of
Implementation Day, as well as sanctions concerning Irans nuclear program
more generally.
U.S. delists more entities/persons specified in Annex II.
EU terminates or suspends virtually all remaining nuclear-related sanctions
and designations.
4.3 March 2024 (8.5 years After Adoption Day)
Iran may begin testing up to 30 IR-6 and IR-8 advanced centrifuges. Iran will proceed
with small and intermediate cascades.

10. F
 or more on the Joint Commissions functions, go to: http://eeas.europa.eu/statements-eeas/docs/iran_agreement/
annex_4_joint_commission_en.pdf

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Iran may begin manufacturing IR-6 and IR-8 centrifuges without rotors at a rate of up to
200 centrifuges per year for each type.

5. Termination Day (October 18, 2025 which is Adoption Day +10 year)
UNSCR 2231 is terminated; UNSC approval is now no longer required for transactions
with Iran.
EU terminates all remaining nuclear-related sanctions.
UNSC officially closes Irans nuclear file.
Irans obligation to enrich uranium using only 5,060 IR-1 centrifuges comes to an end and
Iran can begin phasing in advanced centrifuges for enrichment.
Iran is now able to test advanced centrifuges and conduct enrichment R&D with them.

6. Post Termination Day: Many Core Nuclear Restrictions and Important Inspections
Remain in Place Since Iran Will Remain a Member of the NPT and operate under
its IAEA Safeguards Agreement and Additional Protocol. After Termination Day, the
following will take place:
Continued IAEA enhanced monitoring for a further 5 years.
Cap on stockpile of enriched uranium at 300 kilograms for 5 years.
Cap on enrichment level at 3.67% for 5 years.
Containment and surveillance of centrifuge rotor tubes and bellows for a further 10 years.
IAEA monitoring of uranium ore concentrate for a further 15 years. 11
Ban on plutonium reprocessing for 5 years.

11. F
 or more details on the timeline, see: JCPOA Timeline, Center for Strategic and International Studies,
http://jcpoatimeline.csis.org. See also, Jennifer R. Williams, A comprehensive timeline of the Iran nuclear deal,
Brookings Institution, July 2015, http://www.brookings.edu/blogs/markaz/posts/2015/07/21-comprehensive-timeline-irannuclear-deal

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