ARTICLE 19 is deeply concerned by a new Directive issued by Iran’s Ministry of Intelligence under Article 4 of the Law on Intensifying Punishment for Espionage and Cooperation with the Zionist Regime and Hostile States. By criminalising engagement, cooperation, or sharing content with designated ‘hostile’ entities, the Directive risks undermining independent reporting and documentation of human rights violations, while increasing pressure on civil society and diaspora communities. ARTICLE 19 calls for the immediate withdrawal of the Directive and the repeal of laws criminalising legitimate human rights work, journalism, and information sharing.
On 12 July 2026, Iran’s Ministry of Intelligence published a Directive identifying a range of organisations, media outlets, ‘human-media’ actors (انسانرسانهها), and online accounts as ‘hostile’ (معاند) under Article 4 of the 2025 Law on Intensifying Punishment for Espionage and Cooperation with the Zionist Regime and Hostile States Against National Security and Interests. Engaging with or assisting these entities in political, cultural, media or propaganda activities – or sending them information, photographs, videos, or other content deemed contrary to national security – may expose individuals to criminal prosecution. The Ministry further notes that the list will be updated over time and that the designation applies to the listed entities regardless of changes to their domains, platforms, or online identities.
ARTICLE 19 warns the Directive, as well as the underlying legislation, violates Iran’s obligations under the International Covenant on Civil and Political Rights, including the rights to freedom of expression, association and access to information. Its broad and undefined language gives authorities wide discretion to determine what can be criminalised. By criminalising communication with organisations and media outlets – including many engaged in legitimate human rights monitoring and reporting – the Directive is likely to have a profound chilling effect on those seeking to document violations and share information with the international community.
The risks are particularly high in the context of Iran’s ongoing repression of dissent and restrictions on independent reporting. During periods of protest and unrest in Iran, when security forces have repeatedly been using unlawful force resulting in deaths and life-changing injuries, victims, witnesses, and human rights defenders rely on independent media and civil society organisations to document and report abuses. The UN Independent International Fact-Finding Mission has repeatedly relied on documentation from civil society and victims to investigate violations in Iran.
The directive also raises serious concerns in the context of Iran’s well-documented pattern of transnational repression. While such practices are not new, the formal designation of organisations and individuals as ‘hostile’ risks providing additional justification for intimidation, harassment and other forms of pressure against Iranians abroad, including journalists, human rights defenders, researchers, survivors, victims’ families, and members of the wider diaspora.
ARTICLE 19 is particularly concerned that the Directive extends beyond organisations to identify individual journalists, researchers, and human rights defenders. Publicly identifying individuals in this manner may increase their exposure to targeted harassment, online abuse, doxxing, surveillance, and other forms of transnational repression, placing them at heightened risk both inside and outside Iran. Transnational repression is inconsistent with states’ obligations under international human rights law and the principles of sovereignty and non-interference.
This Directive represents a further escalation in the Iranian authorities’ efforts to criminalise legitimate human rights work and independent journalism.
ARTICLE 19 therefore call on the Iranian authorities to immediately rescind the Directive issued under Article 4 of the Law on Intensifying Punishment for Espionage and Cooperation with the Zionist Regime and Hostile States and to refrain from using national security legislation to criminalise legitimate journalism, human rights documentation, or communication with international organisations.
We also urge UN Members States to publicly condemn the Directive and its use and to raise concerns about the Directive in all bilateral and multilateral engagements with the Iranian authorities.
We urge international accountability mechanisms, including the UN Special Rapporteur on the situation of human rights in Iran and the Independent International Fact-Finding Mission on Iran, to continue to monitor and document human rights violations in Iran, including the impact of this Directive.
We call on governments to strengthen their efforts to respond to transnational repression by the Iranian government, especially promptly investigating and responding to acts of intimidation, harassment, surveillance, and threats targeting members of the Iranian diaspora in their respective countries and provide effective protection to those affected.