Undeclared nuclear material and  activities are those a state has not declared and placed under safeguards  but is required to do so pursuant to its CSA. The U.S. Department of State  coordinates the United States’ financial and policy relationship with IAEA. IAEA Uses Its Authorities to Carry out Its Verification Activities under the JCPOA

manufacturing; and (3) conditions on uranium ore concentrate. Under the JCPOA, IAEA also conducts certain activities agreed to by  Iran, such as monitoring of Iran’s uranium mines and mills, according to  IAEA officials. Further, under the  JCPOA, Iran agreed to provisionally apply, and seek ratification of the  Additional Protocol, which gives the agency’s inspectors access to an  expanded range of declared activities and locations, including buildings at  nuclear sites, and locations where undeclared activities may be  suspected. The JCPOA includes a mechanism in which its participants commit to  resolve an access request from the agency within 24 days after the  request is made. IAEA Has Identified the Financial, Human, and Technical Resources Necessary to Verify the Nuclear- Related Commitments in the JCPOA

Our preliminary observations indicate that IAEA has estimated the  financial, human, and technical resources necessary to verify Iran’s  implementation of nuclear-related commitments in the JCPOA. IAEA has  estimated that it needs approximately $10 million per year for 15 years in  additional funding above its current safeguards budget to fund additional  inspections, among other things. IAEA officials said that, pursuant to the Statute, the agency intends to  propose to the Board of Governors that the approximately $5.7 million for  all Additional Protocol activities and inspector costs attributable to the  JCPOA be funded through IAEA’s regular budget after 2016. Consequently, according to a 2015 IAEA report, all of IAEA’s JCPOA  work through 2016 will be funded through extra-budgetary contributions. IAEA  officials told us that the agency plans to transfer 18 experienced  inspectors and nearly twice that number of other staff to its Iran Task  Force from other divisions within its Safeguards Department that cover  countries and regions beyond Iran. In addition, according to IAEA officials, existing safeguards technical  resources are sufficient to implement IAEA’s activities under the JCPOA. Verifying the JCPOA’s Nuclear-Related Commitments May Present Potential Challenges to IAEA’s Safeguards Efforts

Our preliminary observations indicate that IAEA may face some potential  challenges in monitoring and verifying Iran’s implementation of certain  nuclear-related commitments in the JCPOA, according to current U.S.  and IAEA officials as well as some former U.S. officials, several former  IAEA officials, and many expert organizations we interviewed. IAEA Faces an Inherent Challenge in Detecting Undeclared Nuclear Materials and Activities

Our preliminary observations indicate that detection of undeclared nuclear  materials and activities is an inherent challenge for IAEA particularly with  regard to activities that do not involve nuclear material, such as some  weapons development activities and centrifuge manufacturing, according  to current U.S. officials, a former U.S. official, several former IAEA  officials, and several expert organizations we interviewed. According to  U.S. government officials, as well as a former U.S. official, detection of  undeclared material and activities in Iran and worldwide is IAEA’s  greatest challenge. Iran has previously failed to declare activity to IAEA. According to a former IAEA official as well as current IAEA and U.S.  government officials we interviewed, IAEA has improved its capabilities in  detecting undeclared activity. IAEA Access Depends on Iran’s Cooperation and the JCPOA Mechanism to Resolve Access Requests Is Untested

Our preliminary observations indicate that IAEA could face potential  challenges in gaining access to Iranian sites, according to two former  U.S. government officials, a former IAEA official, and one expert  organization. Appendix I: Objectives, Scope, and Methodology

This report provides our preliminary observations on (1) the Joint  Comprehensive Plan of Action (JCPOA) commitments that the  International Atomic Energy Agency (IAEA) has been asked to verify and  its authorities to do so, (2) the resources IAEA has identified as  necessary to verify the JCPOA, and (3) potential challenges and  mitigating actions, if any, IAEA and others have identified with regard to  verifying the JCPOA. We will issue a separate report with the final results  of our work later this year. We also analyzed IAEA documentation  concerning the safeguards legal framework, including the Statute of the  IAEA, which authorizes the Agency to apply safeguards, at the request  of parties, to any bilateral or multilateral arrangement; “The Structure and  Content of Agreements Between the Agency and States Required in  Connection with the Treaty on the Non-Proliferation of Nuclear Weapons”  (information circular (INFCIRC)/153), which provides the basis for the  comprehensive safeguards agreement that most countries have  concluded with IAEA and that covers all of the countries’ civilian nuclear  activities; Iran’s Comprehensive Safeguards Agreement (INFCIRC/214);  the Model Additional Protocol (INFCIRC/540), which provides the basis  for an Additional Protocol  that most countries with a CSA have concluded  with IAEA to provide additional information about countries’ nuclear and  nuclear-related activities; and the November 2011 IAEA Safeguards  Report, which details items concerning “possible military dimensions” of  Iran’s nuclear program; IAEA’s report on its investigation of the possible  military dimensions; and the related Board of Governor’s resolution.
Why GAO Did This Study

In July 2015, multilateral talks with Iran culminated in an agreement called the Joint Comprehensive Plan of Action (JCPOA), through which Iran committed to limits on its nuclear program in exchange for relief from sanctions put in place by the United States and other nations. The International Atomic Energy Agency (IAEA), an independent international organization that administers safeguards designed to detect and deter the diversion of nuclear material for non-peaceful purposes, was requested to monitor and verify Iran's adherence to these limits. The U.S. Department of State coordinates the United States' financial and policy relationship with IAEA.
GAO was asked to review the authorities and resources IAEA has to carry out its activities regarding the JCPOA. On the basis of preliminary results of ongoing work that GAO is conducting, this report provides observations on (1) the JCPOA commitments that IAEA has been asked to verify and its authorities to do so, (2) the resources IAEA has identified as necessary to verify the JCPOA, and (3) potential challenges and mitigating actions IAEA and others have identified with regard to verifying the JCPOA. GAO analyzed the JCPOA and key IAEA documents and interviewed current and former IAEA officials, U.S. government officials, national laboratory representatives, and experts from research institutions.
GAO is not making recommendations at this time and expects to issue a final report on this work later this year.

What GAO Found

As outlined in the JCPOA, IAEA was asked to verify Iran's implementation of a range of nuclear-related commitments, and IAEA uses its authorities and conducts additional verification activities to do so, according to IAEA. Iran's commitments include limits on uranium enrichment levels and enriched uranium inventories. GAO's preliminary observations indicate that IAEA plans to verify Iran's implementation of these commitments through a range of activities conducted by its Safeguards Department, such as inspecting Iran's nuclear facilities and analyzing environmental samples. To verify Iran's implementation of its commitments under the JCPOA, IAEA officials told GAO that the agency uses its authorities and conducts additional verification activities agreed to by Iran under the JCPOA, such as monitoring Iran's uranium mines and mills. In addition, under the JCPOA, Iran agreed to provisionally apply the Additional Protocol, an agreement that will expand IAEA's access, including to locations where undeclared materials and activities—those that an IAEA member state is required to, but has not declared under its agreements with IAEA—may be suspected. The JCPOA also includes a mechanism in which participants to the agreement commit to resolve an access request from the agency within 24 days after the request is made.
GAO's preliminary observations indicate that IAEA has identified the resources necessary to verify the nuclear-related commitments in the JCPOA. IAEA has estimated that it needs approximately $10 million per year for 15 years in additional funding above its current safeguards budget for JCPOA verification. In addition, IAEA plans to transfer 18 experienced inspectors to its Iran Task Force from other safeguards divisions and to hire and train additional inspectors. According to IAEA officials, existing safeguards technical resources are sufficient to implement the JCPOA. According to IAEA documents, all of IAEA's JCPOA work through 2016 will be funded through extra-budgetary contributions. IAEA officials said that the agency intends to propose that of the $10 million, approximately $5.7 million for all Additional Protocol activities and inspector costs attributable to the JCPOA be funded through IAEA's regular budget after 2016.
GAO's preliminary observations indicate that IAEA may face potential challenges in monitoring and verifying Iran's implementation of certain nuclear-related commitments in the JCPOA. According to current and former IAEA and U.S. officials and experts, these potential challenges include (1) integrating JCPOA-related funding into its regular budget and managing human resources in the safeguards program, (2) access challenges depending on Iran's cooperation and the untested JCPOA mechanism to resolve access requests, and (3) the inherent challenge of detecting undeclared nuclear materials and activities—such as potential weapons development activities that may not involve nuclear material. According to knowledgeable current and former U.S. government officials, detection of undeclared material and activities in Iran and worldwide is IAEA's greatest challenge. According to IAEA documents, Iran has previously failed to declare activity to IAEA. However, according to a former IAEA official as well as current IAEA and U.S. government officials GAO interviewed, IAEA has improved its capabilities in detecting undeclared activity, such as by adapting its inspector training program.