One of the most important measures to strengthen the effectiveness of the IAEA safeguards system is to promote the universal application of the Additional Protocol. Among the countries surveyed in this project, Australia, Austria, Canada, France, Germany, Indonesia, Japan, South Korea, Mexico, the Netherlands, New Zealand, Norway, Poland, Sweden, Switzerland, Turkey, the UAE, the United Kingdom and the United States consider the Additional Protocol “an integral part” of the current IAEA safeguards system. The Vienna group of ten also stated at the NPT PrepCom, “[They underline] the importance of international cooperation in assessing and addressing, in a timely manner, any legal and regulatory challenges in connection with the deployment of new technologies, including, but not limited to, small modular reactors, advanced reactor technologies and transportable nuclear power plants.92

Indonesia acknowledged the importance of the Additional Protocol, although it did not take the position described above, and argued: “Indonesia believes that a strengthened IAEA safeguards system, including the implementation of the Additional Protocol, is a critical component of our collaborative efforts to address the non-proliferation risk associated with all peaceful nuclear activity.” Indonesia also stated, “A comprehensive safeguards agreement, in conjunction with an Additional Protocol, contains the verification requirements that can provide assurance that an NPT state party is adhering to its obligations under the Treaty.”93

On the other hand, the NAM countries (with some exceptions) argue that the conclusion of the Additional Protocol should remain a voluntary measure for the NPT states parties, and they oppose making its conclusion a standard for the IAEA safeguards system. For instance, Brazil said, “Proposals geared towards aggravating the already profound imbalance between disarmament and non-proliferation obligations are the wrong medicine for the ailments of the regime. Altering the voluntary nature of the Additional Protocol or elevating it to the level of standard for the verification of non-proliferation obligations provided for in Article III of the NPT is not the way forward.”94 Egypt also stated, “[It] strongly rejects any attempts to impose any additional nonproliferation obligations that go beyond Article III of the Treaty. Proposals that strive to link instruments such as the voluntary Additional Protocol (AP) to the Treaty’s obligations represent an unacceptable breach of the delicate balance that the grand bargain of the Treaty aims to achieve.95 In addition, Iran argued: “The comprehensive safeguards agreement constitute the verification standard under Article III of the NPT. While nuclear-weapon States are not complying with their nuclear disarmament obligations, any call on non-nuclear-weapon States with comprehensive safeguards agreement in force to accept additional commitments beyond their obligations under comprehensive safeguards agreements is not acceptable.”96
Russia continues to “[support] the universalization of the Additional Protocol, but stresses the voluntary nature and inadmissibility of imposing it as a mandatory measure.”97
In a resolution titled “Strengthening the Effectiveness and Improving the Efficiency of Agency Safeguards,” adopted at the 2023 IAEA General Conference, the following points were stated regarding the Additional Protocols:98

➢ “[I]t is the sovereign decision of any State to conclude an additional protocol, but once in force, the additional protocol is a legal obligation, encourages all States which have not yet done so to conclude and to bring into force an additional protocol as soon as possible and to implement them provisionally pending their entry into force in conformity with their national legislation.”
➢ “[I]n the case of a State with a comprehensive safeguards agreement supplemented by an additional protocol in force, these measures represent the enhanced verification standard for that State.”

The IAEA has developed and approved the “state-level approach (SLA)” based on a state-level concept (SLC) under which the Agency considers a broad range of information about a country’s nuclear capabilities and tailors its safeguards activities in each country accordingly, so as to make IAEA safeguards more effective and efficient.

According to the IAEA, as of June 2023, SLAs were developed and approved for implementation for 71 States with a CSA and an Additional Protocol in force, and a broader conclusion; 37 States with a CSA and an Additional Protocol in force but without a broader conclusion; 26 States with a CSA but no Additional Protocol in force; and one State with a Voluntary Offer Agreement and an AP in force.99 The report also states that the SLA was developed for two countries (France and the United Kingdom) that have VOAs and an Additional Protocol in force.100
Regarding research and development of safeguards technologies, as part of its long-term plan,101 the IAEA conducted the “Development and Implementation Support Programme for Nuclear Verification 2022-2023,”102 in which 22 countries (including Australia, Brazil, Canada, China, France, Germany, Japan, South Korea, the Netherlands, Russia, South Africa, Sweden, Switzerland, the United Kingdom and the United States) and the European Commission (EC) participated.

The countries surveyed that had outstanding obligations to the IAEA regular budget in 2022 (as of September 2023) were Iran and Syria.103 It was also observed that payment of the 2023 dues by China has been delayed. As of late September, the full amount had not been paid, and by early November, only half of the dues had been contributed.

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92 NPT/CONF.2026/PC.I/WP.17, June 15, 2023.
93 “Statement of Indonesia,” Cluster 2, First PrepCom for the 11th NPT RevCon, August 7, 2023.

94 “Statement by Brazil,” First PrepCom for the 11th NPT RevCon, August 1, 2023.
95 “Statement of Egypt,” Cluster 2, First PrepCom for the 11th NPT RevCon, August 4, 2023.
96 “Statement of Iran,” Cluster 2, First PrepCom for the 11th NPT RevCon, August 7, 2023.
97 “Statement by Russia,” First PrepCom for the 11th NPT RevCon, August 1, 2023.
98 GC(67)/RES/11, September 29, 2023.

99 GC(67)/16, August 2, 2023.
100 Ibid.
101 IAEA, “IAEA Department of Safeguards Long-Term R&D Plan, 2012-2023,” January 2013.
102 IAEA, “Development and Implementation Support Programme for Nuclear Verification 2022-2023,” January 2022.
103 GC(67)/INF/7, September 22, 2023.