Is “Layered Filtering” the Future of Iran’s National Information Network?

Iran’s ICT Minister has hinted at constructing a flexible new filtering apparatus in the coming months and years. So how worried should we be?

Iran’s ICT Minister has hinted at constructing a flexible new filtering apparatus in the coming months and years. So how worried should we be?

Despite an effective ban on their sale, Virtual Private Networks (VPNs) continue to run circles around the Iranian state’s attempts to control and censor online content and platforms. This ongoing struggle against VPNs continues to pose problems for ICT Minister Mohammad-Javad Azari Jahromi in Parliament, where he has been under pressure to provide innovative solutions in this (so-far) losing battle.

After being summoned to Parliament to answer questions about citizens’ use of VPNs and the implementation of SIM card registration requirements, ICT Minister Mohammad-Javad Azari Jahromi alluded in passing to another possible solution to the challenges faced by the existing filtering system. Jahromi only noted the prospect of a ‘layered filtering’ system very briefly, but the notion contains echoes of earlier, half-announced initiatives.

In particular, Jahromi’s language around ‘layered filtering’ brings to mind an announcement he made in December 2017, when he said that the scheme was ready to be unveiled. At the time his comments raised concerns among some observers, and he was subsequently questioned by the media about his plans. Within days, Jahromi was denying reports of a new filtering system.

Beyond the 2017 announcement, and the brief mention of the idea in the Majles on 2 September, no public information is available about the scheme or the thinking behind it. Yet, piecing together what has been said alongside what we know about Iran’s imminent plans for the National Information Network (or SHOMA), we believe ‘layered filtering’ systems may have the potential to seriously threaten digital and civic rights in Iran in the months and years ahead.

In this issue of Filterwatch, we attempt to shed light on what ‘layered filtering’ might look like if it were to be implemented. We argue that in light of the number of policy and technological developments that have taken place over the last two years, digital rights advocates must take Jahromi’s suggestions seriously.

Based on the available evidence, we are increasingly concerned that the suggested model will create a fragmented regime that threatens privacy and encourages surveillance, with varying levels of privilege assigned to different groups of citizens based on their societal status or occupation. This must be viewed as a serious threat to Iran’s pluralistic online space, and an obstacle to Iran’s transition to a democratic information society.

The Concept of ‘Layered Filtering’

Due to a lack of official documentation about ‘layered filtering’, it remains unclear exactly what the policy might entail. In his address, Jahromi stated that the current problem with Iranian filtering is that it imposes the same blanket restrictions on all citizens. This statement hints that the scheme may seek to give different degrees of unfiltered internet access based on users’ identities, and/or their professional status. It remains unclear who might be entitled to a lower degree of censorship, how they might be able to access an unfiltered internet, and what infrastructure would be used to deliver the system.

In the example he gave to the Majles, Jahromi questioned why the same level of filtering should be implemented for professionals or university students as for schoolchildren. While it is troubling to imagine the ICT Ministry giving greater digital rights to a group of Iranians based on their academic or occupational status, one existing scheme does exactly that, albeit on a much smaller scale: a scheme granting unfiltered internet access to 100 journalists , which was rolled out by the ICT Ministry in April 2018. Although the scheme was later abandoned, on 6 August 2019, a Ministry of Culture official announced that the scheme would be renewed.

Another filtering scheme championed by Jahromi has been the introduction of SIM cards for minors. Currently, all mobile phone providers in Iran offer tailored services for children and teenagers, with special SIMs offering access to only a limited number of websites. ‘Anarestan’ is a commercial project owned by Amin Strategic Management Development Co. (Amin SMD), which has played a leading role in the development and promotion of such SIM cards in partnership with Iran’s largest mobile operator MCI. It claimed in October 2018 that 1.5 million free SIM cards have been claimed by parents so far. A list published by IranCell shows that users of these SIMs have their access limited to a very small number of websites, with those sites available all controlled by state-backed institutions such as IRIB, the government, and religious institutions.

Given the recent implementation of these two schemes, and their enthusiastic reception from Jahromi, they perhaps offer strong indicators of his ambitions for the future of Iran’s filtering regime. That is, that the state is shifting its practices away from direct and uniform methods of filtering, and instead towards a system that adapts filtering methods for different target populations.

Between the Lines — The Policies Underpinning the Move

As we mentioned, there is little-to-no formal documentation around a ‘layered filtering’ agenda. The only concrete policy document that we can so far associated with this policy is the ‘Valid Identity System in Cyberspace’, which was passed by the Supreme Council of Cyberspace on 31 August. The document was mentioned by Jahromi when he addressed the Majles, but at present it remains unavailable, making it impossible for civil society to apply proper scrutiny.

Nevertheless, in the last few years, the move towards the development of a uniform national online identity system has been mentioned in a number of other policies and proposed legislation. The five bills drafted jointly between the ICT Ministry and the Judiciary make it clear that an identity system is deemed essential for fully realising the eGovernment ambitions of the Rouhani administration. The Managing Social Messengers Bill, drafted by the anti-Internet ‘Cyberspace Faction’ grouping in the Iranian Majles, similarly demands verifiable online identities for Internet users in Iran.

The Grand Plan — Boosting Local Tech and Localising of the Internet

The foundation for rolling out a national ‘layered filtering’ system is an online identity authentication regime, as well as the more effective disruption of circumvention tools such as VPNs. In recent months there have been some notable technological developments which may equip Iran with the means to implement such a system.

On 7 July Jahromi retweeted a promotional video that claimed students at Tehran’s Sharif University have developed a domestic version of the Android OS. Jahromi celebrated by pointing out the recent removal of a number of Iranian apps from the Google Play Store, claiming that the widespread roll-out of a domestic operating system would mean an end to foreign companies denying Iranians access to domestically developed apps.

He has also been a vocal supporter of phones produced by GLX, which are claimed to be manufactured inside Iran. On 22 July he posted a selfie of himself with the phone, announcing that he had switched from Samsung to GLX. The phone is currently powered by the Android OS, but an upcoming version named ‘Aria Mini’ will be preloaded with the new Iranian OS, and should be released in the coming months.

Jahromi posted a selfie on Instagram in order to show off a new domestically-made GLX handset.

GLX phones are produced by a company named Hamrah Gooya Arvand Communication, which was founded in 2007. The company is not widely known in Iran, but over the years has claimed to have sold products under the GLX brand in international markets. In January 2015, the business claimed that it had started exporting phones to Yemen and Iraq.

Although GLX’s current market share was only a quarter of a percent according to Cafe Bazaar data published on 14 July, it is likely that we will see a rise in the number of its users in the coming months. As Small Media pointed out earlier this year in the case of domestic messaging apps, Jahromi’s ICT Ministry does not primarily rely on criminalising the use of foreign products or apps to promote domestic products.

Instead, the ICT Ministry relies on incentivising Iranian users to make the switch to domestic apps and services. This started off when the government lowered the price of domestically hosted data, whilst raising the cost of accessing international content providers. When it came to domestic messaging apps, Jahromi attempted to coax users into making the switch in order to smoothly access government and online banking services. Therefore, it would make sense that the same philosophy will be applied to encourage users to jump over to domestically-produced mobile phones equipped with a home-grown OS.

In recent months there have been two major developments which may make buying domestically produced phones a much more attractive prospect for some Iranian users, and in particular for those on lower-incomes.

The most important development has been the comprehensive introduction of the ‘National Mobile Registry’ by the ICT Ministry. The scheme has made it compulsory for Internet Service Providers (ISPs) to only provide connectivity to mobile phones that register their IMEI number with the ICT Ministry. In effect, the scheme has served to limit the trafficking of imported mobile phones to Iran. This scheme, combined with the sharp decline in value of the Iranian rial, has led to a dramatic rise in the cost of mobile phones in Iran.

At the same time, GLX phones are significantly cheaper than other Android phones on the market. These two policies make it entirely possible that we will witness a rise in the use of GLX phones armed with a domestic OS, and perhaps even pre-installed apps, including domestic messaging apps delivering eGovernment services. Such conditions would make it much easier for Iranian authorities to impose a layered filtering regime, linked with users’ verified identities. The growth of accessibly-priced GLX phones with packaged domestic messaging apps could also pose new challenges for Iranians seeking to use VPNs to bypass the domestic filtering regime.

Digital Segregation — The Threat to Digital Rights, Activism, and Online Pluralism

A combination of Jahromi’s rhetoric in the Majles, recent policy developments, and the active support being offered to localise technology development raise serious concerns about the future of anonymity and access to information in Iran. In light of Iranian authorities’ track record, and the lack of meaningful data protection laws or digital rights protections, Jahromi’s proposed localisation plans should be understood as posing meaningful dangers for digital rights in Iran.

If such plans are implemented, they will bring about two fundamental challenges to digital rights in Iran which perhaps have not been viewed as significant over the past decade: firstly, a model of online browsing linked to users’ real identities raises the possibility of unprecedented levels of mass surveillance and the monitoring of user data.

Secondly, it is important to note that layered filtering could bring about a highly fragmented digital sphere in Iran, with users unaware of the rights and privileges afforded to others. This would not only pose huge challenges to the ability of digital rights activists and technologists to resist online censorship and surveillance, but could also contribute to fragmenting and dispersing the public sphere in Iran.

The Road Ahead — How We Got Here, and What Comes Next

Looking back at the last two years, the implementation of a layered filtering regime in Iran would not be a huge surprise. From day one, Rouhani’s administration has demonstrated an overriding commitment to localising the internet by investing heavily in Iran’s National Information Network, SHOMA. The development of this project also demonstrated the government’s commitment to expanding internet access beyond urban centres. Lastly, through measures such as the implementation of higher tariffs for those accessing international services, Rouhani’s administration has penalised users who employ VPNs or access banned websites.

It is also possible that the development of the infrastructure for layered filtering (such as cheaper internet access, and cheaper mobile phones) may be welcomed by many citizens. Marginalised economic groups that have not previously had access to the Internet would only see the expansion of services into their area, and the subsidisation of domestic technology.

Additionally, those with university affiliations or affluent professional jobs could potentially gain unhindered access to certain sites such as Twitter. In light of these benefits to a range of social groups, it must be seriously considered that such dangerous measures could be delivered with minimal public outrage, with the project’s long-term damage to freedom of expression online not necessarily being immediately apparent.

Jahromi and Rouhani’s administration have also benefited from sanctions and Iran’s isolation from international tech companies, as it provides further incentives to localise the country’s internet. Jahromi has repeatedly condemned sanctions for penalising Iranian businesses, but in his public addresses elsewhere he has claimed that sanctions have had a positive effect for localisation.

Another element that cannot be ignored is the absence of pro-reform MPs from debates around the status of the Internet in Iran. Although many of them were elected off the back of their pro-Telegram campaigns in 2016, to this day they have never challenged Jahromi’s comments or actions that have led to greater localisation and censorship. Jahromi’s comments in the Majles have gone completely unchallenged by such MPs and there has been no outrage or effort to get him to clarify the implications of his plans for citizens’ rights.

Beyond the #Filternet

The battle for digital rights in Iran initiated widespread outrage and campaigns against the filtering of foreign mainstream platforms and social networks. Over the last ten years, a game of cat and mouse involving filtering and circumvention tools has left many Iranians and officials feeling that the filtering regime has become redundant. But all signs hint at Iran intensifying its oppressive hold on the Internet, with new measures — intertwined with accelerated localisation of the internet and technology — bringing about new and significant challenges to digital rights in Iran.

A layered filtering regime would not only pose new social challenges for Iranian society in the form of a fragmentation of the online sphere, but it could also provide Iranian officials with a suite of powerful new tools to surveil its citizens and control the flow of information online. For this reason, it is crucial that civil society remains on guard against any further developments towards the implementation of ‘layered filtering’ on Iran’s Internet.