This article was automatically translated from the original Turkish version.
Snapback sanctions are a mechanism that provides for the re-imposition of previously applied international restrictions on Iran due to its nuclear program, under a specific procedural framework. This practice, also known as the "trigger mechanism," is governed by a special provision included in the annex of United Nations Security Council Resolution 2231, adopted in 2015.
The basis for activating the mechanism is the allegation that Iran has violated its obligations under the 2015 Joint Comprehensive Plan of Action (JCPOA). It is claimed that Iran has exceeded uranium enrichment limits, restricted cooperation with the International Atomic Energy Agency (IAEA), and failed to meet the transparency conditions stipulated in the agreement.
The parties responsible for activating the mechanism are the European signatories to the agreement: the United Kingdom, France, and Germany (E3). On 28 August 2025, the E3 countries issued an official notification. After the 30-day period expired without any agreement being reached, sanctions automatically re-entered into force. The sanctions came into effect at midnight on 28 September 2025, and all UN sanctions lifted in 2015 were reinstated.
On 14 July 2015, the Joint Comprehensive Plan of Action (JCPOA) was signed between Iran and the five permanent members of the United Nations Security Council—the United States, Russia, China, France, and the United Kingdom—along with Germany. The European Union also participated as a representative.
Under the agreement, Iran accepted certain restrictions on its nuclear program. Uranium enrichment activities were limited to specified levels and quantities. Heavy water reactor operations were halted or modified for non-nuclear purposes. Iran also granted the International Atomic Energy Agency (IAEA) full access and comprehensive inspection authority.
In return, nuclear-related sanctions imposed by the United Nations, the European Union, and the United States against Iran were lifted. This allowed Iran to reintegrate into international financial and energy markets.
The JCPOA also included a special provision, known as the snapback clause, which allowed for the automatic re-imposition of sanctions if Iran failed to comply with the agreement. This clause was endorsed by UN Security Council Resolution 2231 and gained binding international legal status.
16 January 2016 was designated as the "Implementation Day" under the Joint Comprehensive Plan of Action (JCPOA). On this date, following Iran’s commencement of its nuclear-related commitments, the process of lifting previously adopted sanctions was activated under UN Security Council Resolution 2231.
In addition to the United Nations, the European Union suspended its nuclear-related sanctions and lifted restrictions on the banking and financial sectors. The United States also temporarily suspended certain sanctions as stipulated by the agreement. As a result, Iran regained international access to its energy sector, particularly for oil and natural gas exports.
The lifting of sanctions enabled Iran to rejoin the global financial system and international trade mechanisms. This development increased Iran’s access to external resources and led to a significant rise in energy revenues.
On 8 May 2018, US President Donald Trump announced the United States’ unilateral withdrawal from the Joint Comprehensive Plan of Action (JCPOA). Following this decision, the United States reimposed severe economic sanctions on Iran.
The sanctions imposed restrictions on Iran’s oil exports, financial sector, banking transactions, and maritime transport. Operations between the Central Bank of Iran and international banks were limited, and trade in energy and petrochemical products was targeted.
European countries did not support the US withdrawal and declared their intention to maintain the agreement. However, despite the European Union’s political stance, European companies struggled to sustain commercial relations with Iran due to the impact of US secondary sanctions. This effectively prevented Iran from realizing the economic benefits it expected from the deal.
Following the United States’ withdrawal from the Joint Comprehensive Plan of Action (JCPOA) in 2018, Iran began progressively failing to meet its obligations under the agreement. Starting in 2019, a phased expansion of nuclear activities was initiated.
The Iranian government raised its uranium enrichment level above the 3.67% limit stipulated in the agreement. By 2020, this level had reached 60%. During the same period, heavy water production and reprocessing activities were also resumed.
The International Atomic Energy Agency’s (IAEA) inspection authority was restricted, access to certain facilities was denied, and transparency conditions were narrowed. These steps amounted to the suspension of key obligations under the JCPOA.
Iran stated that it was prepared to return its nuclear activities to compliance with the agreement, but only if the sanctions were lifted. However, due to the continued existence of sanctions, the implementation of its commitments under the agreement was halted.
Diplomatic efforts to revive the agreement were restarted at various points following the United States’ withdrawal in 2018. During the presidency of Joe Biden, negotiations aimed at reviving the deal began in 2021 but yielded no concrete progress.
In December 2024, talks were held at the level of deputy foreign ministers between the United Kingdom, France, and Germany (E3) and Iran, but the process ended without results. In 2025, five rounds of indirect negotiations took place between the United States and Iran in Muscat, Oman, and Rome. Initial phases of these talks included positive statements, but no agreement was reached on technical issues. In particular, the United States’ demand that Iran completely halt uranium enrichment was rejected by Iran.
The planned resumption of negotiations in Muscat on 15 June 2025 was canceled following Israel’s attacks on Iran. During the 12-day conflict, the United States bombed several Iranian nuclear facilities on 22 June. Subsequently, Iran enacted a law suspending its limited cooperation with the International Atomic Energy Agency (IAEA).
Diplomatic contacts with European countries after June 2025 also proved fruitless, rendering all efforts to revive the agreement unsuccessful.
The United Kingdom, France, and Germany (E3) formally notified the United Nations Security Council on 28 August 2025 of their intent to activate the snapback mechanism. Following this notification, a 30-day period began, during which, if the Council did not adopt a new resolution, previously lifted sanctions would automatically be reinstated.
Diplomatic efforts were made during this period. Meetings were held in Istanbul on 25 July and in Geneva on 26 August, but no agreement was reached. The E3 countries demanded that Iran take three key steps:
Iran either rejected these demands or provided inadequate responses. Iran argued that the European countries lacked legal standing and had forfeited their status as participants. As no new resolution was adopted by the end of the 30-day period, snapback sanctions automatically came into effect at midnight on 28 September 2025.
Under the presidency of South Korea, a draft resolution proposing the continuation of eased sanctions on Iran was put to a vote in the United Nations Security Council. Russia, China, Pakistan, and Algeria voted in favor. The United Kingdom, France, Denmark, Slovenia, Sierra Leone, Panama, the United States, Greece, and Somalia voted against. Guyana and South Korea abstained. The draft resolution failed to secure the necessary votes and was not adopted.
On 26 September 2025, a draft resolution presented by Russia and China, proposing a six-month delay of sanctions on Iran, was put to a vote. Russia, China, Pakistan, and Algeria voted in favor. The United Kingdom, France, Denmark, Slovenia, Sierra Leone, Panama, the United States, Greece, and Somalia voted against. Guyana and South Korea abstained.
The draft, which sought additional time for diplomacy to reach a last-minute agreement with Iran, was rejected due to nine opposing votes. This outcome marked the failure of a second attempt to halt the snapback process.
Following the vote on 26 September 2025, members of the Security Council made differing statements. The Russian representative stated that Western countries had turned the process against Iran into a tool of blackmail and escalated tensions. The Chinese representative emphasized that more time should be granted for diplomacy with Iran, noting that a six-month delay could provide an opportunity for progress.
US Permanent Representative to the United Nations Linda Thomas-Greenfield asserted that Iran continues its uranium enrichment activities and obstructs cooperation with the IAEA. British representative Barbara Wood clarified that the snapback process was foreseen under Resolution 2231, all required procedures had been followed, and the re-imposition of sanctions was legally valid.
The representatives of Pakistan and Algeria stressed that the re-imposition of sanctions alone would not resolve the issue and that diplomatic efforts must continue. The Guyanese representative noted that the division within the Council deepened global security challenges.
At midnight on 28 September 2025, previously adopted United Nations Security Council sanctions against Iran were reinstated. These include Resolutions 1696, 1737, 1747, 1803, 1835, and 1929, adopted between 2006 and 2010.
With the re-entry into force of these resolutions, the arms embargo, which had expired in 2020, was reinstated. Conventional arms transfers to Iran are now prohibited.
The development and launch of ballistic missiles capable of delivering nuclear weapons are banned. In addition, restrictions on uranium enrichment, heavy water production, and reprocessing activities were reinstated.
Financial and travel bans were also reinstated. The assets of numerous Iranian individuals and entities were frozen, and travel restrictions were imposed on them.
Under UN Security Council Resolution 1929, restrictions on maritime trade linked to Iran were reinstated. This resolution grants member states the authority to inspect and, if necessary, seize shipments to or from Iran.
Under this provision, Iranian commercial vessels and cargo shipments have become subject to international inspections. The resolution includes provisions aimed at preventing the transport of materials and technologies that could be used in nuclear weapons development. Member states are obligated to inspect, halt, or seize suspicious cargo bound for or originating from Iran. This practice has led to restrictions on Iran’s maritime trade activities and increased vessel inspections in international waters.
Following the activation of the snapback mechanism in the UN Security Council, the European Union also reinstated its own sanctions regime. The European Council, on 29 September 2025, adopted a decision imposing sanctions that are both consistent with UN Security Council resolutions and based on the EU’s independent legal framework.
Under this decision, the assets of the Central Bank of Iran and major commercial banks were again frozen. Access to the assets of listed individuals and entities was blocked, and travel bans were imposed. Direct or indirect financial support to listed persons and entities is prohibited.
Within the scope of economic and financial sanctions, trade, finance, and transportation sectors have been subjected to renewed restrictions. In the energy sector, the import, purchase, and transport of crude oil, natural gas, petroleum products, and petrochemicals from Iran are banned. The sale or provision of key equipment for Iran’s energy sector is also prohibited.
The sale of gold, precious metals, diamonds, and related products to Iran or their import from Iran is prohibited. Certain software and specific equipment used in the maritime sector are also banned from sale or transfer to Iran.
In the transportation sector, Iranian cargo flights are barred from accessing EU airports, and restrictions have been imposed on Iranian cargo vessels entering EU ports. Providing maintenance and servicing for Iranian cargo aircraft and ships carrying prohibited goods is also prohibited.
Following the completion of the process initiated on 28 August 2025, the foreign ministers of the United Kingdom, France, and Germany issued a joint statement confirming that UN sanctions had been reinstated through the snapback mechanism. The statement emphasized that Iran had repeatedly violated its nuclear commitments, leaving no alternative but to initiate the procedure. The E3 countries stressed that Iran must never acquire nuclear weapons and affirmed their commitment to pursuing a new diplomatic solution through negotiations.
High Representative of the European Union for Foreign Affairs and Security Policy Kaja Kallas announced that the EU would immediately implement the UN sanctions against Iran. The EU emphasized that the re-imposition of sanctions must not end the diplomatic process and that Iran must fulfill its obligations under the Nuclear Non-Proliferation Treaty (NPT). In conjunction with the E3 notification, the EU Council adopted its independent sanctions regime against Iran on 29 September 2025.
US Secretary of State Marco Rubio called on Iran to “accept good-faith direct talks” following the re-imposition of sanctions. He also urged all UN member states to immediately implement the sanctions. The United States stated that Iran’s continued uranium enrichment and obstruction of cooperation with the IAEA constitute a threat to international security.
Russia and China declared the activation of the snapback mechanism legally invalid. Both countries argued that Europe lacks the right to initiate this process, as the balance of the agreement was disrupted by the United States’ withdrawal in 2018. They also advocated for a six-month extension to allow more time for diplomacy. Russia accused Western countries of using the process as a tool of political pressure. China stated that additional time could reopen avenues for negotiations.
The Israeli Ministry of Foreign Affairs assessed the re-imposition of sanctions on Iran through the snapback mechanism as an “important step.” The statement noted that this move directly responds to Iran’s violations concerning its military nuclear program and reaffirmed the goal of preventing Iran from acquiring nuclear weapons.
Iran has characterized the activation of the snapback mechanism as unlawful, baseless, and provocative. Iranian officials argue that the European countries lack legal standing to initiate this process. Iranian Foreign Minister Abbas Araghchi labeled the notification by the three European countries as “flawed in legal and procedural terms” and declared it invalid. In a letter to UN Secretary-General Antonio Guterres, Araghchi stated that the European countries took this step while failing to fulfill their own obligations.
Iranian President Masoud Pezeshkian claimed that the United States has been using various pretexts to block any potential nuclear agreement. He stated that during talks with European countries, Iran had made clear its readiness to cooperate with the International Atomic Energy Agency (IAEA), but the United States had continuously introduced new obstacles.
The Iranian Parliament convened a closed session following the re-imposition of sanctions, during which the economic hardships faced by citizens were discussed. Parliament Speaker Mohammad Bagher Ghalibaf announced that important decisions had been made but did not provide details. Ghalibaf also declared the snapback process illegal and stated that Iran would not be bound by these decisions.
Member of the Iranian Parliament’s Commission on National Security and Foreign Policy Ismail Kowsari stated that if sanctions are reimposed, Iran’s withdrawal from the Nuclear Non-Proliferation Treaty (NPT) would become a matter of discussion. Kowsari also announced that a proposal to develop nuclear weapons would be considered by the parliament in the future. Nevertheless, senior government officials have indicated they are not supportive of Iran’s withdrawal from the NPT.
In a statement by the Iranian Ministry of Foreign Affairs, it was asserted that the efforts by European countries and the United States to revive expired sanctions are invalid. Araghchi emphasized that UN Security Council Resolution 2231 was intended to expire on 18 October 2025 as agreed, and that no restrictions would remain valid after that date. In a letter to the UN, Araghchi called for an end to attempts to revive the sanctions mechanism.
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Background
The 2015 Nuclear Agreement (JCPOA)
Removal of Sanctions (2016)
US Unilateral Withdrawal (2018)
Iran’s Gradual Suspension of Commitments (2019–2020)
Diplomacy and Negotiations (2020–2025)
Activation of the Snapback Mechanism (2025)
Voting and Diplomatic Debates in the UN Security Council
19 September 2025 Vote
26 September 2025 Vote
Diplomatic Statements
Re-imposition of Sanctions
Re-entry into Force of UN Resolutions
Maritime Trade Controls
European Union Decisions
International Reactions
E3 Countries (United Kingdom, France, Germany)
European Union
United States
Russia and China
Israel
Iran’s Responses