By the end of August, Britain, France, and Germany – the remaining European participants in the 2015 Iran nuclear deal – have to decide whether to invoke the “snapback” mechanism under UNSC Resolution 2231. The provision allows a JCPOA participant to notify “significant non-performance,” automatically restoring pre-2015 UN sanctions unless the Security Council affirmatively decides otherwise. The E3 have tied this deadline to “Termination Day” on 18 October 2025, when 2231’s provisions would otherwise lapse. The aim is to avoid letting the resolution expire amid a widening verification gap on Iran’s nuclear program.
That gap opened after the twelve-day war in June, when coordinated Israeli-U.S. strikes hit Iranian nuclear sites at Natanz, Fordow, and Isfahan. In response, Tehran enacted a law suspending cooperation with the IAEA. Inspections and routine verification have not resumed since then. A visit to Tehran by the IAEA deputy chief earlier in August was limited to talks rather than inspections, but both sides have indicated that such contacts will continue. Iran now holds significant quantities – around 400 kg – of uranium enriched to 60 percent, while all on-site inspections and remote monitoring by the IAEA have ceased. There are growing international concerns that this combination carries especially serious proliferation risks.
Seeking to arrest the slide before October, the E3 have reportedly floated a procedural off-ramp. The proposal is to extend the end-of-August snapback decision by up to six months if Iran restores IAEA cooperation and transparency and returns to serious talks, i.e., renewed access and clarity on current enrichment activities and the status and location of the highly enriched uranium stockpile.
From European capitals, this looks like a stabilising pause. In Tehran, however, it is read as an early, one-way concession that risks surrendering the last usable leverage without concrete relief or guarantees. In these circumstances, the more realistic path seems to be a roadmap for phased cooperation with the IAEA, anchored in a parallel and serious diplomatic track with both Europe and the United States. However, with the E3’s end-of-August deadline approaching, the window for such an approach may close within weeks, making quick action on both sides essential.
Iran’s divided debate
Tehran’s official position has been to reject the legitimacy of the snapback mechanism altogether. Foreign Minister Abbas Araghchi has described any activation as “equivalent to a military attack,” arguing that the E3 lost the right to invoke snapback after abandoning their own commitments under the Joint Comprehensive Plan of Action (JCPOA). Araghchi has written to both the UN Secretary-General and the Security Council, asserting that European officials’ recent positions, including an apparent push for “zero enrichment” in Iran, violate the spirit of the agreement and strip the E3 of legal standing.
Still, he has conceded that snapback would make Iran’s situation “more difficult and complicated,” signalling recognition of its potential negative impact. Other officials have echoed this line. Foreign Ministry Spokesperson Esmail Baghaei has in multiple occasions tried to delegitimise the snapback, portraying it as an abuse of process.
Yet beneath the surface, concern is evident. A leaked Ministry of Intelligence report, published by Iran International, warns that activation of snapback would drive up unemployment and fuel public dissatisfaction. This can be seen as an acknowledgement that renewed UN sanctions could deepen Iran’s already fragile economic and social conditions.
The Iranian parliament, dominated by hardliners, has adopted a more confrontational tone. Several MPs have threatened that Tehran would withdraw from the Nuclear Non-Proliferation Treaty (NPT) if snapback were triggered. Such rhetoric goes further than the Masoud Pezeshkian administration’s cautious statements and appears aimed at signalling resolve. In fact, the administration officials have avoided committing to such a decision, suggesting that they wish to keep the door open to compromise, however narrow.
At the same time, some voices in the expert and political community argue that snapback should be met with escalation. Their suggestions range from openly pursuing nuclear weapons, to adopting a full “nuclear opacity” posture, to extending the range of Iran’s missiles in order to threaten Europe more directly. Thus far, there is no evidence that the leadership has adopted these positions, but their growing prominence reflects the frustration of a constituency that believes diplomacy has reached a dead end.
Countering this narrative is a coalition of experts and former diplomats who stress the dangers of escalation. In a significant move, 78 veteran diplomats released a public statement in late July warning against the “return or intensification of sanctions” and urging policymakers to adopt a “pragmatic and interest-driven” approach that relies on dialogue. Abdolreza Faraji-Rad, a professor of geopolitics and former diplomat, has been among the most outspoken in this camp. “The best way to prevent activation of snapback is direct negotiations between Iran and the United States,” he argued, adding that IAEA experts should be allowed to verify uranium stocks as part of such talks.
Other voices have proposed more creative solutions. Former senior diplomat Qassem Mohebali has warned that enrichment without an agreement risks war and has suggested that Iran should preserve the right to enrich but refrain from exercising it until an appropriate time. Former ambassador Jalal Sadatian, by contrast, has opposed any pause in enrichment but has supported the idea of forming a regional nuclear consortium with Arab neighbours as a way of legitimising Iran’s program while enhancing transparency.
However, even those advocating dialogue emphasise that any meaningful agreement must be struck with Washington, not with Europe. The prevailing view in Tehran is that Europe holds only the “stick” of snapback, while the real “carrots,” i.e., sanctions relief and security assurances, rest with the United States.
The prevailing view in Tehran is that Europe holds only the “stick” of snapback, while the real “carrots,” i.e., sanctions relief and security assurances, rest with the United States. Hamidreza Azizi
Meanwhile, Tehran has been working diplomatically to marshal support from Russia and China. Both Moscow and Beijing have already questioned the legitimacy of a European snapback, warning that it would destabilise the region and risk further escalation. Iranian officials hope that strong opposition from these powers, even if it cannot prevent snapback procedurally, will delegitimise the measure and mitigate its political impact. At the same time, they have warned that Europe would lose any role in Iran’s nuclear diplomacy if snapback were triggered. This can be read as a signal that Tehran sees its future engagement on the nuclear issue taking place either directly with Washington or with non-Western partners.
A narrow path forward
For the E3, the logic of linking a snapback extension to renewed IAEA access is clear enough. Addressing the stockpile of highly enriched uranium would defuse the most urgent proliferation concern, while a temporary reprieve could buy time for further negotiations. Politically, it would also signal that Europe still has a role in managing the crisis rather than ceding the field entirely to Washington.
From Tehran’s perspective, however, the offer looks far less attractive. First, disclosing the location and potentially sealing the uranium would deprive Iran of what many officials consider their last bargaining chip vis-à-vis the United States. Without leverage, Tehran fears it would be forced into a weak position in any eventual negotiation. This anxiety is sharpened by the reality that the enrichment program has already been effectively halted after the Israeli-U.S. strikes, and any attempt to resume it would risk triggering further attacks.
Second, Iranian leaders believe that disclosing the stockpile’s location would make it a more vulnerable target for potential future strikes. Their concern is reinforced by past accusations that the IAEA has, directly or indirectly, enabled Israeli operations by leaking sensitive information about Iran’s program.
Third, by accepting the extension, Iran would implicitly legitimise the snapback process that it has long insisted Europe has no right to invoke. As former diplomat Korosh Ahmadi has noted, “If we accept an extension, we are essentially conceding Europe’s authority to activate snapback.”
Yet outright rejection carries its own risks. Triggering snapback would not only reimpose multilateral sanctions but would also further erode Iran’s fragile economic stability, deepen its diplomatic isolation, and potentially accelerate military escalation. For this reason, Iran’s best course is not to dismiss Europe’s proposal wholesale, but to reshape it into a broader phased approach.
Instead of conditioning an extension on Iran’s immediate full transparency, both sides could first agree on a roadmap: Iran beginning with limited, reversible steps to restore partial IAEA cooperation, while the E3, in parallel, engage Russia, China, and the US in the UNSC to secure more time for diplomacy. Hamidreza Azizi
Such an approach would neither require Iran to acknowledge the E3’s legal authority to activate snapback, nor to hand over its perceived 60 percent leverage at the outset. After conversations with his European counterparts, Foreign Minister Abbas Araghchi recently indicated that any extension of the mechanism is ultimately a matter for the UN Security Council, not for Tehran to approve. This may be interpreted as a sign of a softening stance. In practice, it would mean that instead of conditioning an extension on Iran’s immediate full transparency, both sides could first agree on a roadmap: Iran beginning with limited, reversible steps to restore partial IAEA cooperation, while the E3, in parallel, engage Russia, China, and the United States in the UNSC to secure more time for diplomacy. Any such process would also have to involve a parallel engagement track with Washington and Europe, so that phased sanctions relief and security assurances could be matched to incremental transparency, with the fate of the 60 percent stockpile left to the final stage. This way, both sides would preserve their leverage until the end, rather than risking it at the outset.
This strategy requires flexibility on both sides. For Tehran, it means resisting the temptation to escalate toward weaponisation or NPT withdrawal and instead using the opportunity to reach a face-saving diplomatic solution. For the E3, it means acknowledging the limits of their own leverage and working with Washington to design a realistic sequencing of incentives and obligations. Without such coordination, Europe risks being sidelined as Iran defaults either to confrontation or to a direct bilateral track with the US. The snapback deadline may be looming, but a narrow path remains open for those willing to take it.
The European Leadership Network itself as an institution holds no formal policy positions. The opinions articulated above represent the views of the authors rather than the European Leadership Network or its members. The ELN aims to encourage debates that will help develop Europe’s capacity to address the pressing foreign, defence, and security policy challenges of our time, to further its charitable purposes.
Image: Flickr, Blondinrikard Fröberg
