The Internet in The Women, Life, Freedom Era
The Internet in The Women, Life, Freedom Era
PE ACE A N D SECU R I T Y
THE INTERNET IN
National Information Net-
work (NIN), a system design-
ed to control and surveil in-
ternet usage, which played
Miaan Group
September
June 2024 2021 The report concludes with
policy recommendations for
improving internet freedom
and security in Iran.
PE ACE A N D SECU R I T Y
THE INTERNET IN
THE WOMEN, LIFE,
FREEDOM ERA
Iran’s Progress in Censorship and Surveillance –
and Options for European Policymakers
Content
1 INTRODUCTION 2
6 POLICY RECOMMENDATIONS 18
FRIEDRICH-EBERT-STIFTUNG – THE INTERNET IN THE WOMEN, LIFE, FREEDOM ERA
INTRODUCTION
The “Women, Life, Freedom” protest movement in Iran, known as the “Green Movement.” This wave of dissent
catalyzed by the tragic death of Mahsa Jina Amini, a young marked the first instance in which Iranians heavily leveraged
Kurdish-Iranian woman1, in the custody of Iran’s morality the internet as a tool for mobilization and communication,
police on September 16, 2022, marked a significant shift in even giving rise to the term “Twitter revolution”3 among
the country’s socio-political landscape. Anti-government some commentators. Iranian leaders soon saw the need for
social mobilization reached historic levels, with months of a comprehensive approach to information controls, and by
sizable protests taking place in over 100 cities and all 32 January 2011, Iran’s Fifth Development Plan had set the cre-
provinces in the country.2 The movement was organized ation of the National Information Network (NIN) in motion.
through various online forums and galvanized through shar- While online censorship initiatives had already started be-
ing videos of police violence against protestors on platforms fore 2009, it was after the “Green Movement” that such
such as Instagram and Telegram. measures were formalized and intensified. This period also
witnessed the enactment of cybercrime laws and increased
As Amini’s arrest came after she allegedly failed to comply efforts to provide clear cyber policies to manage informa-
with the Islamic Republic’s hijab mandate, women and wom- tion flows and curb dissent.
en’s bodies played a central role in the protests, particularly
in their early days. Women began openly resisting hijab laws The NIN, an amalgamation of regulations, market incen-
in public and posting videos of themselves doing so. tives, infrastructure, and technologies, is a localization pro-
ject aimed at isolating Iranian users from the global internet.
The Iranian government responded to the “Women, Life, By restricting user’s access to information and services based
Freedom” movement with an aggressive crackdown, which outside the country, the Islamic Republic gives itself maxi-
extended to online spaces. Initially, authorities aimed to mum control over content, connectivity, and private user da-
quell the protests and social mobilization through a range of ta. This localization effort, in part, has given rise to a vast ex-
censorship tactics, such as localized and mobile-only inter- pansion of public and private initiatives to develop Iran-
net blackouts, digital curfews, and aggressive attacks based digital infrastructure, tools, services, and content.
against VPN services. But soon after, policymakers looked Iran’s localization plan has also been inadvertently accelerat-
for ways to intensify their information controls. In particular, ed by US extra-territorial economic sanctions that have
the Islamic Republic began developing a more sophisticated forced Iranian companies and users to pull their websites,
surveillance framework, hoping to consolidate its control services, and data off international cloud providers and
over the population further, maintain social order, and en- move them onto Iran-based servers.
force its religious and ideological mandates.
The second era catalyzing the NIN project started in Novem-
The evolution of Iran’s internet policies and information con- ber 2019, when a country-wide uprising against economic
trol can generally be divided into three eras. Each era and political injustice occurred after a sudden fuel subsidy
emerged in response to a significant social uprising, shaping cut. The state’s response, marked by severe crackdowns, de-
the government’s strategy for digital oversight and control. tentions, and violence, led to the death of at least 300 dem-
onstrators, according to Amnesty International, and a week-
The first era began after the 2009 contested presidential long internet blackout.4 The shutdown resulted in Iranians
elections, which led to months of large-scale protests
2
Introduction
losing access to all international content and services, such and services, such as Iran-based messaging apps, social me-
as BBC Persian, Twitter, and WhatsApp, essentially isolating dia, and other domestic alternatives for online services rang-
Iranians from the world and each other. This was the first in- ing from navigation apps to email and search engines, pre-
stance in the world where such an extensive and prolonged ferring instead to use international ones even after those in-
internet shutdown had occurred. ternational ones are blocked
However, just as significantly, the shutdown demonstrated Against this backdrop, this report investigates how internet
the functionality of the NIN, as Iran’s domestic content and access and digital rights in Iran are shaped by various fac-
services remained online and usable. In other words, while tors, such as technology, government policy, and sanctions,
Iranians could not access international services, most could and offers policy recommendations for improving internet
still go online to check their bank accounts, read the local freedom and security. The report covers five main topics:
news, order cars on ride-sharing apps, and so on.
1. The development and implementation of the domestic
What we are seeing in the NIN’s third era, born out of the intranet, the NIN.
“Women, Life, Freedom” movement,5 is an Islamic Republic
leveraging this project to its full potential, employing a suite 2. The state of internet access and censorship in Iran and
of regulations and digital instruments to build toward a hy- the challenges for internet users.
per-surveillance regime that can detect and counter both
online and offline forms of political and moral dissent and 3. The government’s increasing efforts to develop a hy-
monitor the lifestyle choices of Iranians. per-surveillance regime to enforce its political, social,
and moral rules, especially as they pertain to women in
The “Bill to Support the Culture of Chastity and Hijab,” for public and digital spaces.
example, introduced into the parliament in August 2023,
would impose harsh penalties for non-adherence to com- 4. The effects of US and EU sanctions on internet access in
pulsory hijab standards in physical and digital spaces and Iran.
create a set of responsibilities for state agencies in enforcing
those standards.6 5. Policy recommendations for improving internet access
and freedom in Iran, addressing the needs and concerns
Authorities are also developing various technologies, such of various stakeholders.
as the Nazer application7 for reporting hijab violations and
facial recognition systems designed to monitor compliance
with modesty laws.8 Furthermore, the Islamic Republic’s
most ambitious new effort is to use the NIN infrastructure
and platforms to collect big data and create “lifestyle” pro-
files of Iranians.9
3
FRIEDRICH-EBERT-STIFTUNG – THE INTERNET IN THE WOMEN, LIFE, FREEDOM ERA
In 2006, then-Telecommunications Minister Mohammad According to the SCC’s “Comprehensive Plan and Architec-
Soleymani announced that Iran would begin constructing a ture of the National Information Network” document in
“National Information Network” (NIN) in two to three years. 2020, the architecture of the NIN consists of three layers:
After the 2009 Green Movement, in which the internet was infrastructure, services, and content, each further divided
used to mobilize mass protests, the Islamic Republic’s per- into two sublayers. This structure ensures a comprehensive
spective on the internet changed tremendously, and the NIN and organized approach to managing the network’s vari-
was recast as a national security project as much as a tele- ous components.
communications infrastructure development project.
– The infrastructure layer encompasses communication
Iran’s NIN was largely inspired by the by the approach of and information infrastructure sublayers. The communi-
other countries to the internet, which promoted economic cation infrastructure sublayer includes various mediums,
development within the context of strict information con- such as wireless, wired, cable, and fiber, alongside the
trols. The NIN is an amalgamation of laws and regulations, provision of communication services. The information
infrastructure, technologies, market incentives, and con- infrastructure sublayer focuses on data centers, comput-
tents designed to create a localized alternative to the world- ing resources, and data storage solutions.
wide web.
– The services layer consists of basic services with es-
The NIN project is a double-edged sword. While it can be sential tools and application services. Basic services and
credited for expanding Iranian telecommunication infra- essential tools comprise cloud infrastructure services,
structure and providing valuable baseline internet access for operating systems, search engines, basic navigation and
many Iranians, it simultaneously creates a broad-ranging map services, email, messaging and social networks,
system to curb free, safe access to the internet. public key infrastructure with digital certificates, digital
service platforms, repositories, libraries, and essential
APIs. Application services encompass e-government
NIN – AN ARCHITECTURE services, audio and video services, advanced navigation,
BUILT FOR CONTROL smart home products, data analysis services, food deliv-
ery apps, and more.
In 2011, the legislation of Iran’s Fifth Development Plan for-
mally characterized the NIN as an IP-based framework, – Atop these two layers is the content layer, divided
complete with the necessary switches, routers, and data into content format and content application sublayers.
centers to direct online traffic domestically. This setup was This layer includes games and entertainment, govern-
intended to establish a secure, private, and nationally-con- ment data, encyclopedias and publications, augmented
tained intranet. reality content, virtual reality content, image and video
content, as well as audio and music content.
The Supreme Council for Cyberspace (SCC), the country’s
highest internet regulatory body, further refined the design With the Seventh Development Bill, enacted on May 20,
and requirements of the NIN in 2016 with the enactment of 2023, the ICT Ministry aims to connect 20 million house-
the “Explanation of the Requirements of the National Infor- holds to the NIN through fiber optic cables by 2026,
mation Network.” This document refined the design and re- near-universal coverage, including all urban areas and 99%
quirements of the NIN, providing further details and clarify- of villages with over 20 households.10
ing and enhancing the specifications of the NIN. The SCC
outlined the NIN as a communication infrastructure with
completely independent domestic management, capable of
offering various types of content and nationwide communi- 10 “The Iranian government’s use of technology to control and surveil
its citizens,” Louis Shakibi, Filterwatch, October 12, 2023, https://fil-
cation services and providing secure services, including en- ter.watch/en/2023/10/12/the-iranian-governments-use-of-technolo-
cryption and digital signature, to all users. gy-to-control-and-surveil-its-citizens/.
4
The Rise of the National Information Network
The NIN was constructed on top of the pre-existing infra- state’s approach to information control.14 Local alternatives
structure that links Iran to the global internet through two are hosted within the country, comply with the laws of the
primary secure border gateways with specific ports for ex- Islamic Republic of Iran, and have infrastructural dependen-
ternal connection. The Infrastructure Telecommunication cies on the government. In effect, authorities can regulate
Company (ITC) has the sole authority to import and dissem- and censor content on these platforms while also having ac-
inate internet bandwidth within Iran. Acting as the interme- cess to user data.
diary, the ITC acquires international internet bandwidth and
distributes it to local Internet Service Providers (ISPs). Mean- At the same time, authorities block countless international
while, the Institute for Research in Fundamental Sciences websites and applications. These include navigation apps
(IPM) is tasked with allocating bandwidth predominantly to like Waze, major social media and messaging platforms like
educational institutions and government agencies. Addi- Instagram and Telegram, various news outlets like BBC Per-
tionally, the IPM is pivotal in administrating top-level do- sian, and application stores like Google Play. These plat-
mains such as .ir and .iran. forms can only be accessed using Virtual Private Networks
(VPNs), making the local alternatives much easier to access.
This centralized gateway system simplifies the process for
the authorities to isolate the NIN from the international in- The government also employs a range of other policies to
ternet, allowing them to swiftly disconnect the domestic drive users towards the NIN platform and websites. By law,
network from the outside world when deemed necessary. traffic within the NIN costs far less than traffic to the global
internet, forcing consumers to make pocketbook decisions
In May 2024, Iranian lawmakers reintroduced a controver- about whether to use international platforms.15
sial bill proposal, the “User Protection Bill,”11 into parlia-
ment’s agenda.12 One of the main goals of this bill is to To incentivize the private sector to use and operate on do-
hand over control of the internet’s entry/exit gateways in mestic platforms, the government also offers businesses
Iran to the military, which would facilitate extensive and ex- special tax breaks, bank loans16, placement in science and
trajudicial surveillance of users at the gateways. The bill had technology parks, and a share in traffic sales revenue for
been floating around the parliament since 2021 and twice content producers on domestic platforms.17
came near a vote. However, digital rights advocates in Iran
raised grave concerns about the bill’s impact on internet Since 2012, the Iranian government has implemented poli-
freedom and privacy, sparking an enormous public outcry, cies that require the use of locally developed messaging
which effectively forced lawmakers to abandon the legisla- apps for various online activities. This includes transactions
tive efforts. Yet, in May 2024, MP Ahmad Rastineh stated in banking, accessing e-government services, and the enroll-
that the newly reintroduced bill, having met certain proce- ment process for educational institutions. “Domestic social
dural requirements, could be swiftly ratified with just ten messengers” in this context are defined as those with over
minutes of discussion on the parliamentary floor, effective- 50% Iranian ownership and exclusively hosted within the
ly bypassing a general assembly vote and enabling it to be country. Examples include Bale, Eitaa, Rubika, and So-
directly enacted.13 roush.18 These regulations effectively compel most Iranians
to install and use these domestic messengers to some de-
gree. Moreover, the e-government portals themselves serve
DOMESTIC SERVICES AND PLATFORMS as massive databases of user data that authorities can easily
access and cross-reference.
A key aspect of the NIN is the development, support, and
mandated use of domestic platforms. These platforms serve By creating a wide array of localized online services and con-
as alternatives to international basic services, online tools, tent, the Islamic Republic has also eased the pain of internet
apps, and platforms, ranging from navigation apps to na- shutdowns. During major disruptions or shutdowns, access
tional email to search engines. While authorities regularly to the global internet is cut, but the local alternatives remain
tout the economic benefits of local services and app mar- online. In other words, a functional NIN minimizes the neg-
kets, this localization strategy is also a pivotal part of the
5
FRIEDRICH-EBERT-STIFTUNG – THE INTERNET IN THE WOMEN, LIFE, FREEDOM ERA
Figure 1
“Relatively Successful Test of the ‘National Internet,’”
ative impact of shutdowns on Iranian users and businesses erational Goals of the National Information Network.”20
and thus lowers the government’s social, political, and eco- These objectives included “allocating a 70 to 30 percent
nomic costs. traffic share ratio for domestic versus foreign services” and
“setting tariffs at two to three times higher for accessing the
Of note, after the nationwide internet shutdown in 2019, global network compared to the domestic content and ser-
Mohammad-Javad Azari Jahromi published a video stating vices of the NIN.” Based on a directive from the Regulatory
that banking and online services operated on the NIN were Authority issued in December 2021, the fixed and mobile in-
still functional.19 For the then-minister of communications, ternet tariff rates increased by 34%.21 According to officials,
this was proof of the NIN’s functionality. this price hike applies only to international internet traffic
and does not affect domestic traffic.
WAR AGAINST INTERNATIONAL Figures related to the country’s inbound internet bandwidth
BANDWIDTH have not been officially published. In late 2021, reports indi-
cated that internet companies blamed the reduction in
Part and parcel to the government’s promotion of NIN con- speed and quality of their services on insufficient bandwidth
tent, tools, and services is an effort to limit international imports since President Ebrahim Raisi’s administration start-
bandwidth. As mentioned above, accessing the global inter- ed.22 They cited this shortage as the reason for the declining
net is notably more expensive for users than accessing the
NIN. The “Comprehensive Plan and Architecture of the Na-
tional Information Network,” approved on October 7, 2020, 20 “NATIONAL INFORMATION NETWORK MACRO-PLAN AND ARCHI-
TECTURE RESOLUTION,” Filterwatch, https://filter.watch/en/docs/
by the SCC, contained more than 30 objectives for the “Op- national-information-network-macro-plan-and-architecture-resolu-
tion/.
21 “Blocking Access to the Global Internet Through Economic Pres-
sure,” Filterwatch, February 16, 2024, https://filter.watch/
19 “Azari Jahromi's explanation about the National Information Net- en/2024/02/26/policy-monitor-jan-2024/.
work and the one-week global network outage: I apologize for the 22 “Infrastructure CEO: We have no problem with bandwidth imports,”
internet outage on my part,” Khabar Online, November 23, 2019, Zoomit, February 6, 2022, https://www.zoomit.ir/tech-iran/379232-
https://www.khabaronline.ir/news/1323957. no-problem-importing-bandwidth/.
6
The Rise of the National Information Network
7
FRIEDRICH-EBERT-STIFTUNG – THE INTERNET IN THE WOMEN, LIFE, FREEDOM ERA
The Iranian government employs various methods of cen- the most widely used platform in the country.28 Instagram’s
sorship to control the online activities and expression of its filtering was very illustrative because, at the time, a sizable
citizens, especially during times of social and political unrest. number of local businesses had been operating on Insta-
These methods include filtering, shutdowns, and throttling. gram, and they were adversely impacted by the move.29 Ac-
At the same time, Iranian internet users, technologists, and cording to statistics provided by online market experts in
digital rights activists have resisted these censorship meth- Iran, of the estimated 630,000 Iranian vendors active on In-
ods by developing and relying on VPNs, circumvention tools, stagram before it was blocked, only about 220,000 re-
and satellite technologies. mained by December 2022.30 In other words, within approx-
imately three months, more than 400,000 businesses tem-
porarily or permanently left Instagram, resulting in an esti-
FILTERING AND CONTROL OVER CONTENT mated loss of around USD 190 million in e-commerce sales.
Following the disputed presidential election of 2009 in Iran, Instagram was also the leading platform Iranians were using
a wave of citizens turned to social media to express their dis- to share information and videos about the protests and po-
sent and organize protests.26 This led to the Iranian govern- lice misconduct. By blocking Instagram and many other
ment’s decision to ban Facebook and Twitter. Subsequently, platforms, authorities were seemingly looking to hide infor-
the Computer Crimes Act was enacted in 2009, establishing mation and evidence of human rights violations, as well as
the “Committee for Determining Instances of Criminal Con- hinder social mobilization through digital communication
tent” online.27 This committee’s directives for the blocking tools. The crackdown on VPNs, essential for accessing glob-
or filtering of online content became mandatory for internet al news portals and social media sites and bypassing mes-
service providers. saging restrictions, has drastically limited free internet ac-
cess, as Iranians lack effective tools for circumvention.31
Filtering is accomplished with two basic methods: blocking
keywords in the domain name and blocking specific ad-
dresses. The rationale behind these censorship practices
varies, encompassing objectives from upholding the Islamic 28 “Sardar Jalali: The filtering of Instagram and WhatsApp has been
carried out by the order of the Supreme National Security Council.”
Republic’s moral standards to limiting access to information Donyay Eqtesad, October 31, 2022, https://donya-e-eqtesad.com/
from disfavored sources such as foreign-based news chan- %D8%A8%D8%AE%D8%B4-%D8%B3%D8%A7%DB%8C%
nels, human rights websites, websites of political opposi- D8%AA-%D8%AE%D9%88%D8%A7%D9%86-62/3913115-%
D9%81%DB%8C%D9%84%D8%AA%D8%B1-%D8%A7%DB%
tion groups, and others not aligned with the government’s 8C%D9%86%D8%B3%D8%AA%D8%A7%DA%AF%D8%B1%
policies. Filtering policies have led to the permanent block- D8%A7%D9%85-%D9%88%D8%A7%D8%AA%D8%B3%D8%
ing of widely used social media platforms (i. e., Instagram) A7%D9%BE-%D8%A8%D9%87-%D8%AF%D8%B3%D8%AA%
D9%88%D8%B1-%D8%B4%D9%88%D8%B1%D8%A7%DB%
and international messaging applications (i. e., WhatsApp 8C-%D8%B9%D8%A7%D9%84%DB%8C-%D8%A7%D9%85%
and Telegram). D9%86%DB%8C%D8%AA-%D9%85%D9%84%DB%8C-%D8
%A7%D9%86%D8%AC%D8%A7%D9%85-%D8%B4%D8%
AF%D9%87-%D8%A7%D8%B3%D8%AA.
During the peak of the Woman, Life, Freedom protest in
29 “Irreparable Damage to the Digital Economy caused by Govern-
September 2022, the Supreme National Security Council is- ment Deployed Internet Shutdowns and Online Censorship,” Louis
sued the order to block Instagram, the last major interna- Shakibi, August 10, 2023, https://filter.watch/en/2023/08/10/irrepa-
tional social media platform that was not blocked and by far rable-damage-to-the-digital-economy-because-of-to-internet-shut-
down-and-online-censorship/
30 “Irreparable Damage to the Digital Economy caused by Govern-
ment Deployed Internet Shutdowns and Online Censorship,” Louis
26 “EDITORIAL: Iran’s Twitter revolution,” The Washington Times, June Shakibi, August 10, 2023, https://filter.watch/en/2023/08/10/irrepa-
16, 2009, https://www.washingtontimes.com/news/2009/jun/16/ rable-damage-to-the-digital-economy-because-of-to-internet-shut-
irans-twitter-revolution/. down-and-online-censorship/
27 “Computer Crimes Act,” Cyber Police, September 13, 2013, https:// 31 “Iran Technology; The Ministry of Communications was tasked with
sherloc.unodc.org/cld/uploads/res/document/computer-crimes-act_ identifying and disabling VPNs.” January 4, 2023, https://digiato.
html/Computer_Crimes_Act.pdf. com/article/2023/01/04/ministry-communications-block-vpn-access.
8
Access to the Internet in Practice
SHUTTING DOWN THE INTERNET tions Regulatory Authority reporting over 100% mobile in-
AS “CRISIS MANAGEMENT” ternet penetration, while fixed broadband access remains
below 13%.35
Since 2009, Iran has used internet policy as a tool for na-
tional security and social control. Alongside blocking and It is understood that requests for internet shutdowns at the
filtering content, the Iranian government has pioneered a provincial level must be made by the respective governors
number of restrictive methods designed to limit internet and approved by the Interior Minister. When internet shut-
access, particularly during times of social and political un- downs are requested for several provinces at once, the Pres-
rest, most famously total internet shutdowns.32 As men- ident must approve the action.
tioned, the growth of the NIN has made it less costly for
Iranian authorities to shut down the internet, as domestic While Iranian officials claimed the shutdowns were success-
services can continue running isolated from the interna- ful, their economic repercussions have been significant, with
tional internet. examples including a record sell-off at the Tehran Stock Ex-
change, disrupted shipping, and currency exchange services
During the November 2019 internet blackout, which result- halted.36 Different estimates place the economic loss of the
ed from the National Security Council ordering a nationwide ten-day 2019 shutdown at USD 370 million37, USD 611 mil-
internet shutdown that lasted a week, all access to interna- lion38, or a staggering USD 1.5 billion39, according to the for-
tional connections and services was effectively blocked. mer president of the Iran Chamber of Commerce, Mohsen
During this period, authorities violently clamped down on Jalalpour.
demonstrations, resulting in at least 300 protesters killed.33
The shutdown demonstrated the government’s information During the Women, Life, Freedom protests, internet disrup-
control capacity and marked the operational beginning of tions and shutdowns reportedly cost the Iranian economy
the NIN as an independent digital ecosystem. Despite the USD 773 million in September 2022 alone.40
blackout, access to domestic services like online banking,
rideshare apps, and online shopping was maintained.
USERS RESPOND WITH VPNS, SATELLITE,
During the Woman, Life, Freedom protests, the authorities AND CIRCUMVENTION
demonstrated a refined and highly tailored approach to
shutdowns. After the protests began on September 16, Despite the sweeping array of NIN information controls
2022, internet shutdowns were first observed that evening. emerging over the last 15 years, the Iranian public has been
With protests often peaking at night, the imposition of rather successful at escaping the limits of the NIN and ac-
evening shutdowns, starting around 4 PM local time, be- cessing the content, tools, and experiences they seek.41
came a recurring pattern referred to as a “digital curfew.” Most notably, the vast majority of Iranians turned to VPNs to
bypass the pervasive state filtering of platforms, messaging
During protests in Sistan and Baluchistan, Khuzestan, and
Tehran in 2020, 2021, and early 2022, authorities relied on
localized shutdowns.34 Women, Life, Freedom protests met 35 “The quarterly report of the Regulatory Authority shows; The pen-
a similar fate, with shutdowns happening at the level of etration rate of fixed internet continues to decline,” April 28, 2024,
https://www.sharghdaily.com/%D8%A8%D8%AE%D8%B4-%D9
provinces, cities, and even neighborhoods, effectively only %81%D9%86%D8%A7%D9%88%D8%B1%DB%8C-298/928401-
targeting areas where protests took place. %D9%85%DB%8C%D8%B2%D8%A7%D9%86-%D8%B6%D8%
B1%DB%8C%D8%A8-%D9%86%D9%81%D9%88%D8%B0-%
D8%A7%DB%8C%D9%86%D8%AA%D8%B1%D9%86%D8%
Another form of shutdown tailoring involves only blocking AA-%D8%AB%D8%A7%D8%A8%D8%AA-%D9%87%D9%85%
mobile data. These mobile-only shutdowns comprised the DA%86%D9%86%D8%A7%D9%86-%DA%A9%D8%A7%D9%
vast majority of shutdowns since 2019. They primarily affect 87%D8%B4%DB%8C-%D8%A7%D8%B3%D8%AA.
internet connections from major cellular network providers 36 “Massive Iranian internet shutdown could be harbinger of something
even darker to come, experts warn,” Independent, November 30,
such as Irancell, MCI, and RighTel. Mobile internet is a cru- 2019, https://www.independent.co.uk/news/world/middle-east/iran-
cial aspect of internet access in Iran, with the Communica- internet-shutdown-protests-communications-tehran-a9226731.html.
37 “Massive Iranian internet shutdown could be harbinger of something
even darker to come, experts warn,” Independent, November 30,
2019, https://www.independent.co.uk/news/world/middle-east/iran-
32 “IRAN AND THE INTERNET,” IRANIAN DIGITAL INFLUENCE EFFORTS:
internet-shutdown-protests-communications-tehran-a9226731.html.
GUERRILLA BROADCASTING FOR THE TWENTY-FIRST CENTURY,
Jan. 1, 2020, pp. 11-14, Accessed on Jstor, https://www.jstor.org/sta- 38 “Government Internet Shutdowns Have Cost $53 Billion Since 2019,”
ble/resrep24668.6. Top10VPN, https://www.top10vpn.com/research/cost-of-inter-
net-shutdowns/.
33 “Iran: Details released of 304 deaths during protests six months after
security forces’ killing spree,” Amnesty International, May 20, 2020, 39 “The impact of the internet outage on the country's trade sector;
https://www.amnesty.org/en/latest/news/2020/05/iran-details-re- Jalalpour: The internet outage caused a $1.5 billion loss to the econ-
leased-of-304-deaths-during-protests-six-months-after-security-forc- omy,” Khabar Online, November 23, 2019, https://www.khabaron-
es-killing-spree/#:~:text=Amnesty%20International%20has%20 line.ir/news/1323822/.
released%20details,on%2016%20and%2017%20November. 40 “Government Internet Shutdowns Have Cost $53 Billion Since 2019,”
34 “Internet Shutdown Trends in Iran: November 2019 to July 2021,” Top10VPN, https://www.top10vpn.com/research/cost-of-inter-
Melody Kazemi, Filterwatch, September 3, 2021, https://filter.watch/ net-shutdowns/.
en/2021/09/03/internet-shutdown-trends-in-iran-from-november- 41 “Freedom on the Net 2023, Iran,” Freedom House, https://freedom-
2019-to-july-2021/. house.org/country/iran/freedom-net/2023.
9
FRIEDRICH-EBERT-STIFTUNG – THE INTERNET IN THE WOMEN, LIFE, FREEDOM ERA
apps, and websites. Indeed, VPNs have become an indispen- for daily life. In addition, for years now, judicial and security
sable part of the daily digital life for most Iranians. authorities have been prosecuting producers and distribu-
tors of internet filtering circumvention tools and filing cases
An August 2023 report by the Iran Parliamentary Commis- against them in judicial bodies.47
sion of Industries noted that the volume of anonymous
bandwidth on the international network, indicative of VPN However, while authorities look to limit VPN usage, they are
use, had quintupled within a year. By November 2023, Iran’s slowly introducing government-approved VPNs. This move
Parliament Research Center reported that 90% of internet towards government-approved VPNs is tied to a broader
users used VPNs.42 The Research Center estimated that plan for tiered internet access that would balance internet
about 60 million Iranians had downloaded VPNs and other restrictions with the need for global connectivity. This au-
circumvention tools onto their devices. Psipone, Lanther, thorization-based system discriminates access, allowing in-
and Outlook are effectively free services dedicated to pro- dividuals varying levels of internet content based on their so-
viding reliable unfiltered access to the internet for Iranians. cial status, with journalists, for example, having limited ac-
cess to certain sites like YouTube.
The Iranian government has employed various strategies to
combat the use of circumvention tools. In addition to legal
and judicial efforts that ban the distribution and use of THE SATELLITE INTERNET CHALLENGE
VPNs, the government actively blocks these tools, particu-
larly during periods of civil unrest, such as the Woman, Life, In September 2022, at the peak of the Women, Life, Free-
Freedom protests. During these periods, the authorities tar- dom protests and the government’s internet shutdowns,
get the connection protocols of VPNs and block IP address- satellite internet provider Starlink announced that it would
es associated with them43, significantly hindering the availa- make its transmission available inside Iran.48 Some internet
bility of functional VPNs.44 freedom activists soon advocated for Iranians to rely on
Starlink and satellite technologies in general to avoid Iran’s
In response to the Women, Life, Freedom protests, VPN pro- censorship and internet infrastructure in its totality.49 In the-
viders were forced to rapidly adjust their protocols and in- ory, the dishes offer easy access to uncensored, relatively
vest in diversified ISPs and servers to throw off Iranian cen- fast, and reliable internet.
sors and meet public demand.45 Additionally, over the last
year and a half, technologists and VPN providers have been However, despite pervasive discussions around this alterna-
forced to develop new types of circumvention and VPNs tive, the use of Starlink in Iran is not widespread, as the dish-
that can, with varying levels of success, avoid government es are not legally available in the country and are costly.
attacks and deal better with internet shutdowns. Even if some Iranians could afford the service, US sanctions
have cut Iran’s financial sector off from the world, making it
On February 19, 2024, the Supreme Council of Cyberspace almost impossible for Iranians to purchase the service. Still,
announced a new resolution entitled “Exploring Solutions advocates tell the Miaan Group that the number of Starlink
to Increase the Share of Domestic Traffic and Counteract dishes in the country totals between 4,000 and 5,000 as of
Anti-Censorship Tools.”46 Clause 6 of the resolution explicit- May 2024, but many of them have not been put into oper-
ly prohibits using internet filtering circumvention tools, in- ation. These devices are typically obtained through smug-
cluding VPNs, which has raised public concern over the glers, and since their purchase and sale are illegal, their
criminalization of these commonplace tools that are crucial owners and operators are at risk of arrest.50 Starlink services
are also usually purchased by individuals outside of Iran for
in-country dish owners.
42 “Shocking parliamentary report on the statistics of VPN usage in
Iran,” Gadget News, November 17, 2023, https://gadgetnews. Iranian authorities have vigorously responded to the chal-
net/800682/vpn-using-statics-in-iran/. lenge posed by Starlink. The use of Starlink satellite internet
43 “Technical multi-stakeholder report on Internet shutdowns: The terminals is banned in Iran under the 1994 law prohibiting
case of Iran amid autumn 2022 protests,” OONI, https://ooni.
org/post/2022-iran-technical-multistakeholder-report/#circum-
the use of satellite reception equipment, which states, “the
vention-tools.
44 “Woman, Life, Freedom: A Roundup of the State of Digital Rights in
Iran During the Protests,” Filterwatch, January 27, 2023, https://fil-
ter.watch/en/2023/01/27/women-life-freedom-the-state-of-digital- 47 “The use of VPNs is prohibited, but not criminalized,” Filterwatch,
rights-during-the-protests/. March 4, 2024, https://filter.watch/en/2024/03/04/the-use-of-vpns-
is-prohibited-but-not-criminalized/.
45 “Fighting VPN criminalization should be Big Tech’s top priority, ac-
tivists say,” Ars Technica, March 20, 2023, https://arstechnica.com/ 48 “Elon Musk says around 100 Starlinks now active in Iran,” Reuters,
tech-policy/2023/03/fighting-vpn-criminalization-should-be-big- December 27, 2022, https://www.reuters.com/technology/elon-
techs-top-priority-activists-say/. musk-says-around-100-starlinks-now-active-iran-2022-12-26/.
46 “Solution to Increase the Share of Domestic Traffic,” Filterwatch, 49 “Satellite Internet Companies Could Help Break Authoritarianism,”
https://filter.watch/en/wp-content/uploads/sites/2/2024/03/%D8% Pouria Nazemi, Scientific American, https://www.scientificamerican.
A8%D9%87%D9%85%D9%8629_1402-%D8%B1%D8%A7%D9 com/article/satellite-internet-companies-could-help-break-authoritar-
%87%DA%A9%D8%A7%D8%B1-%D8%A7%D9%81%D8%B2% ianism/.
D8%A7%DB%8C%D8%B4-%D8%B3%D9%87%D9%85-%D8%- 50 “Inside the Clandestine Efforts to Smuggle Starlink Internet Into
AA%D8%B1%D8%A7%D9%81%DB%8C%DA%A9-%D8%AF% Iran,” Time, January 25, 2023, https://time.com/6249365/iran-elon-
D8%A7%D8%AE%DB%8C.pdf. musk-starlink-protests/.
10
Access to the Internet in Practice
11
FRIEDRICH-EBERT-STIFTUNG – THE INTERNET IN THE WOMEN, LIFE, FREEDOM ERA
As the Islamic Republic cements NIN in place, it has invest- recognition.58 The issue took on new significance in the
ed more into developing and deploying technologies to context of the Women, Life, Freedom movement, fueling
identify, monitor, control, and punish those who deviate more public concern.
from its religious, social, and political mandates. In fact, ac-
cording to a former government insider, one of the original In an interview with state media on April 8, 2023, Ah-
long-term goals of the NIN is to establish a hyper-surveil- madreza Radan, Chief Commander of the Iranian Police,
lance regime. announced that from March 20 to April 18, 2023, individ-
uals violating hijab regulations were “identified using ad-
Women and women’s bodies, in particular, have become a vanced technology and equipment, reprimanded, and re-
central focus of Iran’s recent surveillance technologies. Chal- ferred to the judicial courts.”59
lenges to mandatory hijab seen within the Women, Life,
Freedom movement only sharpened this focus. The emerg- Despite claims and speculation, the reality of the govern-
ing surveillance technologies include facial recognition and ment’s use of facial recognition surveillance practices re-
image processing, incident reporting apps, and a big-data mains unclear and is likely less sophisticated than officials
Lifestyle Monitoring System. Officials aim to bolster these purport. Evidence points to the continued use of tradition-
technologies through new laws and efforts to further con- al methods for monitoring and enforcement.60 For example,
trol and create content for cyberspace. If successful, these in 2019, the Iranian police sent SMS warnings to drivers for
technologies and policies, grounded in the NIN ecosystem, wearing improper hijabs in their cars. However, men with
will facilitate a level of surveillance, censorship, and profiling long hair also received these messages. These false posi-
yet unseen in Iran. tives suggest a reliance on simpler, older camera technolo-
gies and maybe even manual review, as facial recognition
As articulated by various authorities, a primary objective of would have pinpointed exactly who an alleged offender
such measures is to demonstrate the government’s firm was.
commitment to enforcing hijab laws, moral compliance, and
more. In the eyes of policymakers, they are building a digital Additionally, during the Women, Life, Freedom protests,
surveillance and monitoring system that will allow them to authorities primarily used existing CCTV systems in public
enforce their laws and regulations strictly, many of which vi- spaces to monitor and apprehend protesters, including
olate international human rights laws and ensure non-ad- women challenging the hijab law.61 Arrest techniques of-
herence to mandated hijab regulations, which will invariably ten involved posting images on pro-government social
be subject to legal penalties.57
12
Building towards a Hyper-Surveillance of Women, Lifestyles, and Public Morality
media to solicit public assistance in identifying violators, telligence and various other technologies to monitor local
further indicating a dependence on basic surveillance rath- populations. Iranian authorities regularly promote the idea
er than cutting-edge technology.62 of “smart cities.”
To date, the only evidence that the government is employ- Further complicating the landscape, a report by the research
ing facial recognition, a sophisticated artificial intelligence group Tehran Bureau indicates that other Asian firms, such
technology, is that officials have themselves said so. It is pos- as Huawei, have provided Iran with advanced surveillance
sible that officials made such claims primarily to intimidate technologies such as facial recognition, video surveillance,
the public and maintain social control. crowd monitoring, and communications interception. These
deals often include comprehensive training programs to
What Miaan’s research has shown, however, is a clear at- help Iran implement a “safe cities” model.
tempt by the Islamic Republic to develop facial recognition
technologies, as well as image processing software that
can look at online images to see if they violate Iranian NAZER APP
laws.63
An Android application called Nazer is used by the national
Around 2015, several Iranian companies, including Yaftar police force of Iran to report vehicles with female occupants
and Niafam, began collaborating with the Iranian prosecu- wearing “improper” hijab. In 2023 and 2024, authorities
tor’s office to develop these technologies. Leaked communi- punished women for violating hijab mandates while driving
cations between Yaftar and the prosecutor’s office, for ex- by issuing fines and impounding their cars after being iden-
ample, show that the company was specifically trying to de- tified by law enforcement. Nazer aims to streamline this
velop the capacity to detect moral infractions, such as imag- type of enforcement.
es of women without hijab or same-sex kissing.64 However,
as of this writing, little is known about how far these efforts Nazer is a Persian word that means “supervisor” or “overse-
have gotten. er.” For now, the app can only be used for hijab violations.
However, static analysis of its code reveals that with future
Additionally, Iran seems to have tried to purchase cameras updates, the app could also be used to report people for
capable of facial recognition and other surveillance systems protesting, drinking alcohol, “cruising around” in vehicles,
from foreign firms. According to media reports, from 2016 and other things the government deems criminal.
to 2018, the German company Bosch sold cameras to Iran
capable of “intelligent tracking.”65 While Bosch denied that Figure 2
these cameras were equipped with facial recognition capa- The Nazer App
bilities, they acknowledged that the Iranian state could po-
tentially integrate software from another provider to enable
facial image tracking using these cameras.
13
FRIEDRICH-EBERT-STIFTUNG – THE INTERNET IN THE WOMEN, LIFE, FREEDOM ERA
In its current state, Nazer is a suite of software that covers mentation of a social credit system by authoritarian regimes
various aspects of public and private life and relies on the poses a significant risk, where individuals with low scores
participation of “spontaneous public forces” or vetted vol- could progressively be denied access to public services
unteers who act as hijab enforcers and use the Nazer app to through AI-based automatic decision-making.
report offenders. This policy effectively gives moral policing
powers to private citizens.
HIJAB AND THE WAR ON
In all, Nazer is a digital tool for repression and surveillance CONTENT CREATORS
and lets police officers or volunteers make decisions without
substantive judicial oversight. Iranian authorities continue to put direct pressure on con-
tent creators in the form of threats, interrogations, arrests,
and punitive measures against online activists, social and
LIFESTYLE MONITORING SYSTEM political figures, celebrities, and influencers. As an example,
on October 17, 2022, security forces arrested Mozhgan Ilan-
The proposed “Lifestyle Monitoring System,” outlined in the loo, an Iranian filmmaker and documentary director, in Teh-
Seventh Development Plan Bill, is a far-reaching and evasive ran after she posted photos of herself without the manda-
data collection initiative intended to enhance the profiling tory hijab on Instagram.68 The Revolutionary Court sen-
capabilities of government agencies.66 This initiative, a col- tenced her to six years in prison for assembly and collusion
laborative effort between the Ministry of Culture and Islam- against national security, 15 months for propaganda against
ic Guidance and the Statistical Center of Iran, seeks to gath- the regime, 15 months for disturbing public order, and 15
er a wide set of data on various dimensions of the lives of in- months for encouraging immoral acts. Additionally, she was
dividuals, including living conditions, health, transportation, sentenced to 74 lashes and a fine of 80 million Iranian Rials
judicial status, and administrative activities. The system’s payable to the state treasury.69 Ilanloo’s case highlights the
stated goal is to “facilitate citizens’ lives,” suggesting an aim severe consequences activists and women who use online
to streamline and possibly personalize government services. spaces to express dissent from the Islamic Republic’s moral
Under the proposed legislation, government bodies, public and political mandates face.
service providers, and private companies, including online
taxi operators, e-commerce platforms, and other digital ser- In response to the Women, Life, Freedom movement, the
vices handling Iranian user data, must continuously upload Iranian police also launched the “Warden Initiative” on April
this data to the “System for Monitoring, Evaluating, and 15, 2023, which aims to stem hijab non-compliance.70 This
Continuously Measuring Public Culture and Lifestyle Indica- initiative explicitly aims to go after public figures who per-
tors,” also known as the Lifestyle Monitoring System. This sonally reject the compulsory hijab or promote not wearing
extensive data collection is enabled by the architecture of hijab or other acts deemed indecent. By May 2023, driven
the NIN, which includes both pre-existing infrastructure and by aggressive increased online surveillance, officials claimed
service layers. The government’s policy of forcing Iranian us- the initiative had identified and reported over 10,000 of-
ers to migrate to domestic applications and services further fending individuals and reported them to the police.71 Offi-
strengthens these data sources. cials also reported the initiative led to over 300 arrests, hun-
dreds of official warnings, summonses, content removal,
However, this central data collection, without adequate le- and at least 1,300 websites and social media accounts being
gal data protection and given the Islamic Republic’s human investigated or taken down.
rights track record, poses significant risks to the personal se-
curity and privacy of Iranians. The Lifestyle Monitoring Sys-
tem would permit law enforcement and judicial agencies to 68 “Mojgan Ilanlou has been arrested,” Donya Eqtesad, August 21, 2023,
https://donya-e-eqtesad.com/%D8%A8%D8%AE%D8%B4-%D8%
access personal data without adhering to legal procedures B3%D8%A7%DB%8C%D8%AA-%D8%AE%D9%88%D8%A7%
that guarantee data privacy and related rights. Additionally, D9%86-62/3995154-%D9%85%DA%98%DA%AF%D8%A7%D9
there is growing concern among experts that the system’s %86-%D8%A7%DB%8C%D9%84%D8%A7%D9%86%D9%84%
D9%88-%D8%A8%D8%A7%D8%B2%D8%AF%D8%A7%D8%B
database could be exploited, using artificial intelligence, to 4%D8%AA-%D8%B4%D8%AF.
profile citizens.67 For example, the government could ana- 69 “‘Mojgan Ilanlou’ sentenced to 10 years in prison and 74 lashes,”
lyze various data points to infer individuals’ political orienta- Shargh Daily, January 17, 2023, https://www.sharghdaily.com/
tions, potentially classifying them as opponents of the state. %D8%A8%D8%AE%D8%B4-%D8%B3%DB%8C%D8%A7%
D8%B3%D8%AA-6/867499-%D9%85%DA%98%DA%AF%D8%
Such algorithms could also likely predict the future behav- A7%D9%86-%D8%A7%DB%8C%D9%84%D8%A7%D9%86%D
iors of these individuals. Furthermore, the potential imple- 9%84%D9%88-%D8%A8%D9%87-%D8%B3%D8%A7%D9%84-
%D8%B2%D9%86%D8%AF%D8%A7%D9%86-%D8%B6%D8%
B1%D8%A8%D9%87-%D8%B4%D9%84%D8%A7%D9%82-%D
66 “Iran’s “People’s Lifestyle Assessment System”: A New Surveillance 9%85%D8%AD%DA%A9%D9%88%D9%85-%D8%B4%D8%AF.
Threat,” Louis Shikabi, Filterwatch, December 14, 2023, https://filter. 70 “Hijab Legislation in Cyberspace: the Government Expands its Efforts
watch/en/2023/12/14/irans-peoples-lifestyle-assessment-system-a- to Suppress Personal Freedoms in Iran,” Pooyesh Azizeddin, Filter-
new-surveillance-threat/. watch, September 24, 2023, https://filter.watch/en/2023/09/24/fata-
67 “‘Monitoring Lifestyle’ in Iran and the Nightmare of Artificial Intel- watch-april-july-2023/.
ligence in the Absence of Legal Guarantees,” Louis Shakibi, Filter- 71 “Police Spokesperson: 301 people arrested in the implementation
watch, December 23, 2023, https://filter.watch/en/2023/12/14/irans- of the chastity and hijab plan,” June 14, 2023, https://www.asriran.
peoples-lifestyle-assessment-system-a-new-surveillance-threat/. com/fa/news/894014/.
14
Building towards a Hyper-Surveillance of Women, Lifestyles, and Public Morality
15
FRIEDRICH-EBERT-STIFTUNG – THE INTERNET IN THE WOMEN, LIFE, FREEDOM ERA
In recent years, U.S. foreign policy has significantly influ- Consequently, Iranians are still largely cut off from a wide
enced Iran’s relationship with the global internet. While var- range of international communication tools and services,
ious sanctions have been imposed on Iran since the 1979 adversely affecting information access and digital security
Iranian Revolution, the most specific and stringent restric- across society. This highlights the impact of existing eco-
tions were prominently reinstated and expanded starting in nomic sanctions, promoted by them or their partners, on
2018. Broad U.S. sanctions have long prohibited any U.S. the ability of Iranians to access online tools and services.
company from conducting business with Iran. Since 2018,
these restrictions also apply to non-U.S. companies whose The U.S. Treasury’s Office of Foreign Assets Control (OFAC)
activities involve the U.S. in any direct or indirect manner, introduced General License D-1 in February 2014 and Gen-
including transactions processed through U.S. banks or eral License D-2 in September 2022, clarifying that tech
payment systems.74 firms can provide or sell personal and commercial communi-
cation tools and services to Iranians, including messaging
One result of these extraterritorial sanctions is that many apps, VPNs, satellite internet hardware, e-gaming, e-learn-
Iranian companies, websites, and users have been kicked ing platforms, automated translation, and user authentica-
off international servers and services, including those tion services.76 These broad authorizations allow all U.S. per-
based in Europe.75 This development accelerated the pro- sons and entities to engage in specified activities without
cess of internet localization by forcing Iranians and Iranian applying for a separate license.
businesses to migrate onto the NIN’s infrastructure, cloud
storage, and services, which are fully exposed to govern- Nonetheless, these general licenses have done little to per-
ment surveillance, private data collection, and information suade tech firms that they can provide their communica-
controls. tions services to Iranians. While OFAC remained open to
evaluating requests for specific licenses, companies have
In 2019, a tech activist created and maintained a list on had little economic incentive to invest in the complex appli-
GitHub of 282 companies that had blocked their services cation process and compliance requirements of specific
to Iran-based IP addresses. Even free services, such as free OFAC licenses.
Adobe products, have been unavailable to Iranian users.
Iranian developers, unable to utilize international The effectiveness of specific licensing policies greatly de-
cloud-hosting services and development tools, face chal- pends on the response of the management of relevant sites
lenges creating their own anti-surveillance and anti-cen- and companies. Additionally, sanctions have cut Iranians off
sorship applications to bypass government-imposed inter- from the international banking system and international fi-
net restrictions and increase the security of under-data. nancial services, making it extremely difficult to purchase in-
Leading providers, including Google Cloud, Amazon Web ternational online services, such as VPNs or satellite internet,
Services (AWS), DigitalOcean, and GoDaddy, continue to regardless of their legality.77
withhold their offerings from the Iranian market, thereby
impeding the nation’s ability to engage in secure and ef- To date, the open-source code library GitHub has been the
ficient digital exchanges. In some cases, these interna- only major tech enterprise to embark on a lengthy applica-
tional tech firms are risk-averse and over-comply with tion and invest in a parallel advocacy process to gain a spe-
sanctions. cific license from OFAC. For two years, GitHub argued its
74 “Iran Sanctions,” OFAC, US Department of Treasury, https://ofac. 76 “U.S. Treasury Issues Iran General License D-2 to Increase Support for
treasury.gov/sanctions-programs-and-country-information/iran-sanc- Internet Freedom,” US Department of Treasury, September 23, 2022,
tions. https://home.treasury.gov/news/press-releases/jy0974.
75 “Locked out: Why is Amazon blocking Iranians from its services?” 77 “‘Maximum Pressure’ US Economic Sanctions Harm Iranians’ Right to
Maziar Motamedi, Al Jazeera English, October 2, 2019, https://www. Health,” Human Rights Watch, October 29, 2019, https://www.hrw.
aljazeera.com/economy/2019/10/2/locked-out-why-is-amazon- org/report/2019/10/29/maximum-pressure/us-economic-sanctions-
blocking-iranians-from-its-services. harm-iranians-right-health.
16
The Impact of Sanctions on Internet Access
17
FRIEDRICH-EBERT-STIFTUNG – THE INTERNET IN THE WOMEN, LIFE, FREEDOM ERA
POLICY RECOMMENDATIONS
This report offers the following actionable recommenda- risks due to surveillance and censorship. Actionable
tions to European governments that would enhance inter- steps that Europeans can take to promote safe dig-
net freedom in Iran. The goal is to mitigate censorship, en- ital practices in Iran include:
sure access to information, and hold the Iranian government
accountable for internet disruptions. These recommenda- 1.
Developing engaging public campaigns that
tions aim to empower Iranians to exercise their fundamental raise awareness about digital security practices;
human rights through a free and secure internet.
2.
Providing accessible resources in Persian, in-
cluding guidelines on secure communication,
1. INVEST IN VPNS, CIRCUMVENTION & privacy, and anonymity;
ALTERNATIVE TECHNOLOGIES FOR
INTERNET ACCESS 3. And supporting help desks to respond to urgent
security needs and provide real-time assistance.
a. Urgently allocate funding to VPNs and circumven-
tion technologies.
3. HOLD THE IRANIAN GOVERNMENT
i. As explained throughout this report, the Iranian ACCOUNTABLE
population heavily relies on VPNs and circumven-
tion tools to bypass censorship, access information, a. European states should act at the International
and communicate safely. However, there continues Telecommunications Union (ITU), including draft-
to be a shortfall in funding for free and secure VPNs ing a submission to the ITU, to ensure Iran is trans-
for Iranians. Germany and the EU should allocate parent and held accountable to the body’s rules.
funding to support the development, maintenance, European states should advocate for the follow-
and distribution of VPNs and circumvention tech- ing policies at the ITU.
nologies. These tools are essential for Iranians to
exercise their fundamental human rights online. i. Iran’s information control policies offend the ITU's
goals, including efforts to attain “meaningful con-
b. Prioritize “next generation” and “cutting-edge” nectivity” and achieve the Sustainable Develop-
technologies. ment Goals.80 The ITU’s approach thus far has over-
looked the broader implications of Iran’s restrictive
i. As Iran’s censorship systems become more com- Internet policies, which violate the rights of millions
plex, there is a strong need for innovation in bring- of Iranians to access information and communicate
ing about more censorship and shutting down re- freely.
sistant circumvention and security tools. Europeans
should allocate funding specifically to supporting ii. The ITU should hold Iran accountable for its censor-
new and more advanced forms of VPNs and other ship and surveillance. If Iran violates ITU rules or dis-
internet freedom technologies. rupts Internet connectivity without proper notifica-
tion and justifiable reasons, the ITU should impose
appropriate penalties.
2. INVEST IN PROGRAMMING FOR
DIGITAL SECURITY iii. The ITU should call on Iran to stop internet shut-
downs, as it has rightfully done in other countries’
a. Promote digital security practices in Iran.
i. As explained throughout this report, Iranians, in- 80 “Aspirational targets for 2030,” ITU, https://www.itu.int/itu-d/meet-
cluding activists and journalists, face significant ings/statistics/umc2030/.
18
Policy Recommendations
contexts, and consider their negative impact on lance tools and services to Iran’s security apparatus.
communities.90 These companies should be investigated, and sanc-
tions should be enforced by identifying relevant en-
iv. The ITU should insist that Iran promptly notifies it tities operating within European jurisdictions.
about any internet shutdowns or disruptions. Iran
should be obliged to provide a comprehensive and
transparent account of the actions that have led to 6. ENCOURAGE EUROPEAN BASED
such shutdowns, as mandated under the ITU Consti- CLOUD PROVIDERS AND TECH FIRMS
tution. This transparency is essential for the ITU’s abil- TO ENABLE SECURE SERVICES
ity to monitor and respond effectively to these issues. FOR IRANIANS
v. The ITU’s annual report rankings should also in- a. European-based cloud providers should:
clude a review of the effects of internet shutdowns
in countries like Iran. i. Support access to their infrastructures and explore
alternative payment channels (e. g., cryptocurrency)
vi. The ITU should support the rights of Iranians to ac- for Iranians. European cloud providers should also
cess uncensored and secure satellite internet. enable Iranians to set up their own VPNs using in-
ternational infrastructures.
4. IMPLEMENT TARGETED SANCTIONS ii. European cloud providers should partner with in-
WITH VIGOROUS HARM ASSESSMENTS ternational VPN providers that are dedicated to
providing free services to Iranians. Cloud providers
a. The European Union should sanction Iranian offi- should help these VPNs set up cost-effective and
cials, individuals, and entities directly involved in resilient networks.
digital censorship and surveillance.
b. European-based tech firms should:
i. Priority should be given to identifying and sanction-
ing high-ranking officials directly responsible for in- i. Integrate circumvention into communication tools
ternet shutdowns. (e. g., Wire, Pleroma) and offer them free of charge
to Iranian users. They should also develop guide-
ii.
Any sanctions considered should first undergo lines for seamless integration, emphasizing strong
comprehensive harm assessments before imposi- encryption and minimal performance impact.
tion to ensure minimal harm to the general popu-
lace. Such harm assessments should include broad
consultation with experts.
19
imprint
www.fes.de/bibliothek/fes-publikationen
THE INTERNET IN THE WOMEN, LIFE, FREEDOM ERA
Iran’s Progress in Censorship and Surveillance – and Options for European Policymakers
This report discusses Iran’s National Infor- The Iranian government has responded This report concludes with policy recom-
mation Network (NIN), a system de- to the »Women, Life, Freedom« move- mendations addressed to the European
signed to control and surveil internet us- ment with an aggressive crackdown ex- Union and Germany for improving inter-
age. The NIN was intensified in response tending to online spaces. Policymakers net access and freedom in Iran, address-
to the »Women, Life, Freedom« move- are developing a more sophisticated sur- ing the needs and concerns of various
ment, which marked a significant shift in veillance framework to consolidate con- stakeholders. These include investing in
Iran’s socio-political landscape. The NIN trol over the population, maintain social VPNs, circumvention, alternative internet
is an internet localization project aimed order, and enforce religious and ideolog- access technologies, digital security pro-
at isolating Iranian users from the global ical mandates. This includes the develop- gramming, holding the Iranian govern-
internet, giving the Islamic Republic max- ment of domestic internet platforms and ment accountable, implementing target-
imum control over content, connectivity, services and using other technologies for ed sanctions with vigorous harm assess-
and private user data. reporting hijab violations, such as facial ments, and encouraging European-based
recognition systems. cloud providers and tech firms to enable
secure services for Iranians.