The bill titled “Supporting and Addressing Violations in the Field of Pervasive Audio and Video in Cyberspace”, which has been informally referred to in recent months as “Protection Bill No. 3” or “Siyanat 2025” and presented as an effort to organize censorship and filtering mechanisms for video content, was formally introduced in an open session of the Islamic Consultative Assembly on November 5, 2025.
A close reading of the bill shows that it does not constitute a coherent or carefully crafted piece of legislation. Most of the text is a repackaging and rearrangement of earlier laws and policy documents, while only a small number of provisions introduce a new and potentially dangerous mechanism for rapid censorship. The significance of this bill lies not in its length or scope, but in the institutional architecture it creates for content removal and platform control.
What Is “Pervasive Audio and Video”?
This law is concerned with regulating what Iranian authorities call “pervasive audio and video”. The term refers to any audio or visual content that is made widely and publicly accessible, including films and series on streaming platforms, home-entertainment networks, internet video programs, live online broadcasts, and professionally produced audiovisual content distributed through digital platforms.
The concept of “pervasive audio and video” originates from interpretations issued by Islamic Republic of Iran’s Guardian Council regarding the Constitution. Over time, this interpretation has been used as the legal basis for extending the authority of the Islamic Republic of Iran Broadcasting organization and its regulatory arm, SATRA, into the online and digital sphere.
Who Is the “Regulatory Authority”? SATRA and the Role of the Ministry of Islamic Guidanceture
Throughout the bill, the term “regulatory authority” is repeatedly used. At first glance, it appears to be a neutral and technical designation. In practice, however, it refers to specific institutions with a well-documented record of censorship.
At the center of this structure is the Organization for the Regulation of Pervasive Audio and Video, commonly known as SATRA. SATRA operates under the authority of the Islamic Republic of Iran Broadcasting (IRIB) organization and has, since 2019, gradually become the main body responsible for licensing, monitoring, and sanctioning video platforms, home-entertainment networks, and online audiovisual content. SATRA is neither independent nor a professional self-regulatory body. It is an executive arm of an institution that already holds a monopoly over broadcasting. This represents only one of several conflicts of interest embedded in the bill.
Alongside SATRA, the bill also refers to the Deputy for Cyberspace and New Media of the Ministry of Culture and Islamic Guidance. Traditionally, this ministry has been responsible for licensing and overseeing certain cultural and media activities. In the domain of pervasive audio and video, however, its role has been steadily weakened in recent years and, in many cases, reduced to that of a secondary or cooperative actor. The new bill does not resolve this institutional conflict. Instead, it places both bodies under the broad and ambiguous label of “regulatory authority.”
According to the bill, regulation of audio and video content in areas such as "news agencies, media outlets, books, advertising, video games, and similar activities" falls under the Ministry of Islamic Guidance. By contrast, regulation of "user-centric and publisher-centric media, including VoD platforms, especially those producing series, television-style programs, and advertising content" is assigned to the Islamic Republic of Iran Broadcasting organization through SATRA.
The key point is that none of these institutions have a judicial character. They are not courts, they are not judicial officers, and they are not subject to criminal procedure rules. Nevertheless, the bill grants them powers that, in practice, enable them to halt publication, remove content, and exert direct pressure on platforms and hosting providers.
Rewriting Existing Laws
The opening articles of the bill, largely reproduce concepts already found in resolutions of the Supreme Council of the Cultural Revolution (Under the control of the Supreme leader of the Islamic Republic) and in Iran's Seventh Development Plan. Definitions of pervasive audio and video, emphasis on the role of state broadcasting, references to regulation and licensing, and even the linkage of these activities to tax exemptions are all repeated without introducing new legal tools.
A clear sign of hurried copy-and-paste drafting is the repetition of contradictions present in earlier documents. As in the Supreme Council’s resolution, responsibility for regulating "advertising" within audio and video content is assigned once to the Ministry of Islamic Guidance and elsewhere to the IRIB, without any mechanism for resolving this conflict. Its reappearance in the new bill indicates a lack of legal refinement and critical review.
These articles introduce no new enforcement mechanisms and do not meaningfully alter the existing regulatory framework. Instead, they replicate the language of the Seventh Development Plan and general policy statements, giving the bill greater volume without adding substantive content.
The Beginning of a New Cycle of Immediate Censorship
The real rupture in the bill begins with Article 11. For the first time, it establishes an operational mechanism for immediate suspension of content publication, entirely outside the classical judicial process.
Under this article, the regulatory authority may order the suspension or removal of content for up to 48 hours. This order is not issued by a court and does not require a prosecutor’s decision. It is based solely on the administrative assessment of the regulator and may be enforced through a phone call or a text message.
At the next stage, a preliminary committee may extend this temporary order for up to one week. This committee is neither a court nor a judicial body, yet its decisions carry serious practical consequences. Failure to comply with the temporary order is itself treated as a separate violation. As a result, the default position becomes suspension and removal, rather than continued publication.
The most significant innovation in Article 11 is the regulator’s authority to intervene directly in the hosting layer. The bill allows the regulatory authority to act through hosting service providers to remove content or prevent access. This represents a shift away from platforms and toward infrastructure, a domain previously dominated by the judiciary or the Filtering Committee.
A Third Path of Censorship: Beyond Prosecutors and Network Filtering
To understand the significance of Article 11, it must be viewed alongside Iran’s two existing censorship mechanisms. The first consists of prosecutorial powers under the Islamic Penal Code and the Code of Criminal Procedure, which allow prosecutors to issue temporary orders in urgent cases. The second is the Committee to Determine Instances of Criminal Content (AKA Filtering Committee), chaired by the Prosecutor General, which exercises network-level filtering through internet service providers.
Article 11 is neither a repetition nor a replacement of these mechanisms. Instead, it creates a third path of censorship: an administrative and regulatory route through which the regulator can act directly against content, platforms, and hosting services without judicial involvement or network-level blocking.
In this third path, intervention is based on administrative judgment rather than criminal determination, and legal accountability is significantly more ambiguous than in judicial proceedings.
Institutionalizing Permanent Censorship
If Article 11 establishes a cycle of immediate censorship, Article 12 consolidates and stabilizes it. This article introduces a “Supreme Committee” as the final decision-making authority regarding continued restrictions. The committee holds ultimate authority over whether limitations remain in place and must be established within both regulatory bodies: SATRA and the Ministry of Islamic Guidance.
In practical terms, censorship that begins as a temporary and emergency measure under Article 11 can, under Article 12, become a long-term or indefinite condition. Although the bill formally states that these decisions do not preclude judicial review, the real order of power is reversed. Content is removed first, operations are disrupted, and economic and media pressure is applied. Judicial recourse remains only as a delayed and exhausting option.
A Hastily Drafted Text with a Clear Objective
Beyond its substance, the structure of the bill itself reflects haste. Irregular numbering, the omission of an article in the sequence, and other formal inconsistencies suggest last-minute insertions and rushed revisions. Such legislative sloppiness is not accidental. Ambiguity, contradiction, and poor drafting expand the discretionary power of implementing bodies and facilitate expansive interpretation.
The bill known as Siyanat 2025 is therefore best understood as an attempt to reconfigure the architecture of video censorship on Iran’s internet. Its opening articles recycle earlier laws, its middle sections inflate the text without adding substance, and its core power provisions establish an administrative censorship cycle and institutionalize it through quasi-judicial committees, creating a new route for content removal that operates independently of courts while complementing network-level filtering. The result is faster, more flexible, and broader censorship, without corresponding mechanisms of accountability.