Research by Filterwatch has uncovered details of a new, systematic and unlawful form of repression in Iran targeting journalists, civil activists, business owners, and various citizens as internet restrictions intensify.
This report analyzes the experimental implementation of the “SIM Card Deactivation” scheme, designed by security and judicial authorities to suppress civil society, journalists, students, and online business owners. Filterwatch’s findings indicate that this plan, currently in a limited and pilot phase, is part of the Islamic Republic’s broader strategies to prepare for potential future protests.
In this study, Filterwatch interviewed more than fifty individuals who experienced SIM card deactivation, including lawyers, political and civil activists across five different cities in Iran.
Interrupting communications, especially in today’s digital world, is itself a form of deprivation and a violation of rights, particularly digital rights.
The International Telecommunication Union (ITU) has emphasized in several official documents the importance of access to communications as a fundamental human right. Specifically, in the Declaration of Principles of the World Summit on the Information Society (WSIS), titled “Communication as a Human Right,” there is a strong emphasis on ensuring equal and non-digital access to information and knowledge.
Moreover, the deactivation of citizens’ SIM cards forces them to approach security authorities to regain access to essential services (such as banking, education, and communication).
The use of various laws and regulations by security and judicial bodies, without official notification or legal transparency, effectively constitutes an abuse of legal loopholes.
Key Findings of the Report
Objective of the “SIM Card Deactivation” Plan: This plan, implemented as an extrajudicial measure, is designed to identify, restrict, and sever communication among civil and social activists, as well as between activists and institutions or media outlets.
Extrajudicial Execution Without Judicial Order: Unlike typical procedures involving summons or detention, SIM card deactivations occur without legal orders or official notifications. Individuals are summoned to security and law enforcement agencies to resolve the status of their SIM cards.
Restrictions on Access to Banking and Educational Services: Citizens with deactivated SIM cards are unable to change the contact number linked to their bank accounts or university platforms, limiting their access to these services until their SIM status is resolved.
Obstruction of Access to the Sana System and Electronic Notifications: With deactivated SIM cards, affected individuals lose access to judicial notifications and summons through the Sana system.
Misuse of Legal Provisions to Justify SIM Card Deactivations: SIM card deactivations are purportedly justified under Article 247 of the Criminal Procedure Code, provisions of the Modesty and Hijab Law, and the Judicial Transformation Document, despite the lack of any specific legal basis allowing such actions.
Summons and Threats to Close Social Media Accounts: In multiple cases, individuals have been asked to delete their social media posts and pledge to refrain from posting similar content in the future.
Selective and Targeted SIM Card Deactivations: Active SIM cards used for banking, university, and essential services are deactivated, while inactive SIM cards remain operational.
Involvement of Various Organizations in Implementing the Plan: This initiative is attributed to orders from the Prosecutor’s Office, FATA Police, and the IRGC Intelligence Organization, with each entity playing a role in various stages of the plan’s implementation.
Security Risks to Citizens’ Social Media Accounts: SIM card deactivations prevent users from receiving secondary login verification codes, increasing the risk of their social media accounts being hacked.
Evidence indicates that, in addition to the spread of applications like “Nazer” (Monitor or Observer), the SIM Card Deactivation scheme is also underway, aimed at rapidly identifying protesters and severing their communication with one another, as well as with institutions, media, and other key entities.
For the first time, the Modesty and Hijab Law has been operationalized before being formally implemented by the President as head of the executive branch. The Judicial Transformation and Excellence Document, which facilitates the swift deactivation of SIM cards and banking services, has also contributed to this initiative, enabling a comprehensive crackdown.
Comprehensive Suppression Through SIM Card Deactivation
Sources close to Filterwatch have suggested that one purpose of deactivating citizens’ SIM cards may be to disable the Sana system (the electronic judicial notification system) to prevent individuals from receiving SMS summons through Sana or accessing this system altogether. As a result, judicial and security authorities can invoke Article 247 of the Criminal Procedure Code, which allows them to restrict access to SIM cards as a means of preventing criminal actions or unlawful behavior. This article grants judicial authorities the power to temporarily revoke privileges, such as travel permissions or motor vehicle operation, to encourage the accused to attend investigative sessions.
Furthermore, the Modesty and Hijab Law, alongside the Judicial Transformation and Excellence Document, provides judicial authorities with the power to impose certain restrictions based solely on an individual’s adherence to dress codes, regardless of their presence in court. This significantly increases the speed and ease of enforcing these limitations when deemed necessary.
According to Filterwatch’s investigation, if an individual has multiple SIM cards, only the one actively used for banking, university-related applications, or daily services such as ride-sharing or online shopping will be deactivated.
Affected individuals are also unable to purchase new SIM cards, even from alternative operators. Seventeen people interviewed by Filterwatch confirmed that after their SIM cards were deactivated, they attempted to obtain new SIM cards from various operators but were unsuccessful. A lawyer, who requested anonymity, told Filterwatch that mobile operators are prohibited from providing services to these individuals based on orders from the Prosecutor’s Office.
Since May 2024, following the approval of the Judicial Transformation and Excellence Document, judicial authorities have gained access to citizens’ civil registry, banking, and mobile phone data.
Additionally, citizens whose SIM cards were deactivated by judicial, security, or law enforcement orders have confirmed to Filterwatch that banks do not allow them to change the phone number linked to their accounts, effectively depriving them of banking services until their SIM status is resolved.
The same applies to university platforms and other similar services. Interviews with students from Shahid Beheshti University, Shiraz University, and Tabriz University reveal that, with the start of the new academic year, students at these institutions were unable to register due to their SIM cards being deactivated.
Miaan`s cybersecurity experts have further emphasized concerns regarding the security of affected citizens’ social media accounts. Since some individuals rely on SMS for two-factor authentication to access their accounts, SIM card deactivation effectively cuts off access to their account information, increasing the likelihood of social media account hacks.
Filterwatch’s findings also indicate that even after completing judicial procedures, signing commitments, and closing their social media accounts, citizens do not necessarily have their SIM cards reactivated.
Which Groups Are Targeted by SIM Card Deactivation, and Which Authorities Are Involved?
According to data obtained by Filterwatch, nearly all social groups—including civil activists, journalists, students, as well as gamers, influencers, and online business owners—have been affected by the SIM card deactivation scheme.
The deactivation of citizens’ SIM cards has been ordered by the Prosecutor General’s Office, beginning at least since early summer 2024. Prior to this, FATA Police had also issued orders for SIM card deactivation targeting certain civil activists, former political prisoners, and anti-compulsory hijab activists. In some cases, individuals experienced simultaneous SIM card deactivation and bank account freezes.
Based on information gathered by Filterwatch, FATA Police typically summons individuals by phone. During interrogation sessions, law enforcement and security agents have demanded that citizens with deactivated SIM cards close their social media accounts.
In cases where SIM card deactivations were ordered by the Prosecutor’s Office, a different process unfolds. Since early summer 2024, individuals whose SIM cards have been deactivated report that upon visiting the main offices of mobile operators, they were informed that the “deactivation order was issued by high-ranking officials” and were advised to go to the Prosecutor General’s Office for further instructions. This suggests the involvement of both security and judicial entities in the SIM card deactivation process.
Multiple sources informed Filterwatch that the IRGC Intelligence Organization has been allocated space in local prosecutor’s offices for issuing final SIM deactivation orders and reviewing individual cases. Filterwatch has been unable to independently verify this information.
Some citizens with deactivated SIM cards have been summoned to the main judiciary building, specifically the Virtual Space Division, for “resolution.”
However, at the time of these contacts and during these “resolution” meetings, the individuals were not informed which specific authority had summoned them. In most cases, individuals were presented with printed images of their Instagram stories or tweets.
They were asked to sign all printed images and sign a commitment not to post similar content in the future.
Despite these commitments, account closures, and the removal of previously posted content, some individuals’ SIM cards remain deactivated at the time of this report.
For those who did not appear at the Prosecutor’s Office, official summons were issued by the Deputy Prosecutor’s Office, directing them to report to the IRGC’s Sarallah unit in Tehran to sign such commitments.
In one instance, an individual experienced both SIM card deactivation and the simultaneous filtering of their business website. While these restrictions occurred concurrently, Filterwatch cannot independently confirm any direct link between the SIM card deactivation and the website’s filtering.
Which Organizations Are Responsible for the Suppression?
Filterwatch’s inquiries with the Ministry of Communications reveal that even at the level of deputy minister, officials either have no knowledge of the actions taken or provide no response.
A lawyer, who spoke with Filterwatch in October 2024 on the condition of anonymity, stated, “At the request of the IRGC Intelligence Organization, mobile service providers have been instructed to deactivate SIM cards.” However, no official document or summons has been issued in these cases.
Filterwatch’s research and interviews with victims of this new repressive mechanism by the Islamic Republic indicate that among Iran’s security agencies, the IRGC Intelligence Organization plays the leading role in ordering SIM card deactivations for citizens.
On What Legal Basis Is SIM Card Deactivation Carried Out?
Within Iran’s Islamic and criminal punishment codes, no legal provision explicitly grants judges or judicial officers the authority to deactivate citizens’ SIM cards. However, Filterwatch’s review indicates that these deactivations are generally justified under Article 247 of the Criminal Procedure Code. This article authorizes investigators to use measures such as travel bans, driving prohibitions, or “prohibitions on employment in activities related to the alleged offense” to compel individuals who disregard summonses to present themselves to the judiciary.
Additional rulings have also facilitated the suspension of mobile services for judicial and security authorities. For example, although Article 247 of the Criminal Procedure Code does not mention SIM card deactivation, Article 4 of the Modesty and Hijab Law, approved by the Guardian Council in autumn 2024, includes penalties for advocates of optional hijab, including internet access restrictions and automatic fines debited from bank accounts.
Section 2 of the “Prevention of Suspect Flight” clause in the Judicial Transformation and Excellence Document also grants judicial authorities the power to restrict public and private economic, banking, and social services, including banking and telecommunications services, for “fugitives and wanted convicts.”
Additionally, Section 5 of the same document authorizes restrictions on users to “prevent crimes related to mobile SIM cards.”
Subparagraph 3 of Article 62, added in the May 2023 amendment to the Modesty and Hijab Law, grants the IRGC and judiciary access to databases containing information on advocates of optional hijab, including names, phone numbers, banking details, and location information.
SIM card deactivation violates other legal principles, such as Article 37 of the Constitution, which states, “No one shall be deemed guilty unless proven in a court of law.”
Penalty: Deletion of All Published Content
Filterwatch possesses documents indicating that at least two journalists whose SIM cards were deactivated were required by security or judicial authorities to delete all content posted on their social media accounts.
After summoning these journalists, the IRGC Intelligence Organization issued arrest warrants for them on charges including “propaganda against the regime,” “disturbing public opinion,” “spreading false information,” and “collusion and assembly.”
A review of social media accounts shows that one of these journalists, Sadaf Fatemi, who had her SIM card deactivated for a month, was forced by security agencies to delete her posts on Twitter and Instagram and replace her page with a “Payvandha” link page. Payvandha (payvandha.ir) is a page that redirects users to an interface showing links in place of filtered websites.
In other cases, after a period of SIM card deactivation, users were instructed to cease social media activities. These individuals typically ended up closing their social media accounts altogether.
