On 1^st September 2026, Human Rights Activists in Iran (HRA), with legal support from UpRights and the assistance of a German counsel, submitted a request to the Germany’s Federal Prosecutor General. The submission shared information regarding selected incidents collected and verified by HRA on the particularly violent and most recent crackdown on nationwide protests that began in Tehran on 28 December 2025 and spread to at least 203 cities across all 31 of Iran’s provinces, generating 682 recorded protest events over the following weeks. HRA’s documentation indicates that the response involved coordinated action by the Islamic Revolutionary Guard Corps, the Basij, the Law Enforcement Command, intelligence and security forces, and the judiciary, and that state forces used military-grade weapons and live ammunition against largely unarmed protesters. HRA has verified at least 7,068 deaths, including at least 6,548 protesters, 236 children, and 77 bystanders, and at least 53,987 arrests, figures the organisation describes as confirmed minimums rather than final totals. 

On this basis, the submission asks the Federal Prosecutor General to open a structural investigation into crimes against humanity committed by Iranian state authorities, under Section 7 of the German Code of Crimes against International Law (VStGB). The 109-page submission draws on over 60 interviews with victims, witnesses, and family members inside and outside Iran, together with documentary and digital evidence, and mapping of 48 suspected perpetrators, their institutional affiliations, and their place in the command structures. Although the submission primarily focuses on the nationwide protests and subsequent crackdown between December 2025 and January 2026, the requested structural investigation should not be confined to individual incidents or specific perpetrators but respond to the broader recurring pattern of repression by Iranian State authorities against perceived opponents and civilian protesters.  

The choice to file a request in Germany derives from the fact that Iran offers no realistic prospect of justice for the victims of the State repression. HRA has documented that the Iranian judiciary  itself facilitate the repression, with televised forced confessions obtained from detained protesters under conditions of torture and coercion being common. The International Criminal Court cannot fill that gap either, since Iran is not a party to the Rome Statute oraccepted the Court’s jurisdiction u, and a Security Council referral remains politically unlikely. Opening a structural investigation in Germany is an appropriate mechanism to investigate mass scale and State sponsored crimes against the civilian population as it does not require an identified suspect from the outset, allowing instead prosecutors to collect and preserve evidence, examine patterns across incidents, and map institutions and command structures now, so that individual proceedings can follow once a suspect comes within German jurisdiction. Germany applied successfully the same tool in relation to Syria, demonstrating that opening structural investigations in contexts where mass State sponsored crimes are being committed is an effective tool to facilitate long-term criminal accountability . Prosecutors cannot predict which suspect will travel to Europe or when, but crimes against humanity carry no statute of limitations under the VStGB, so evidence gathered now remains usable whenever that opportunity arises. 

In addition to the gravity of the crimes committed which in itself meets the threshold under the German procedural code for opening an investigation, the submission highlights that there a sufficient nexus with Germany which should lead the German prosecutor to decide in favour of opening an investigation. First – victims, witnesses and family members of victims with relevant knowledge of the crimes have left Iran with some already present in Europe. Second – Germany hosts the largest Iranian diaspora in Europe which provides a significant pool of potential testimonial, documentary and other evidence. Third – the absence of a suspect in Germany today should not mean that nothing can be done today. There is a realistic likelihood that suspected perpetrators may enter or transit through Germany or elsewhere in Europe. HRA’s documentation indicates that current and former Iranian government officials have travelled to Germany and other European States on numerous occasions, including for personal, family-related and medical reasons. Finally, Germany has emerged as a significant target of Iranian State-sponsored transnational repression which overlapping alleged perpetrators. Therefore, the opening of an investigation would not only contribute to accountability for alleged crimes against humanity committed in the context of the nationwide protests in Iran but could also serve to address related criminal conduct committed by Iranian State actors and their proxies on German territory. This makes the situation in Iran one with direct and continuing implications for Germany. 

On the 3^rd of September, UpRights’ Co-Director Valérie Gabard joined HRA in Berlin for “Justice Beyond Borders: Why Crimes Committed in Iran Matter to Germany and the European Union,” an event co-organised with HRA as part of our long-standing collaboration on justice and accountability for crimes committed in Iran. Valérie was joined by HRA’s Skylar Thompson and Jennifer Connet, and by Iranian human rights lawyer Sina Yousefi, former Vice Chairman of the Human Rights Commission of the East Azerbaijan Bar Association. Before an audience of German policymakers, lawyers, and civil society representatives, the panel discussed HRA’s investigation, the critical role of victims and witnesses, the importance of sustained documentation, and opportunities to pursue accountability beyond Iran’s borders. In particular, UpRights’ Co-Director argued that Germany’s own experience prosecuting crimes committed in Syria and Ukraine by relying on structural investigation gives it both the legal tools and the experience to do the same for Iran.  

Read the executive summary below:

Read HRA’s press release below:

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