Amid the deadliest nationwide protests in Iran since the revolution in 1979, the need to acknowledge suffering by victims and ensure their right to hold perpetrators accountable has never been more critical. In 2025, HRA, with legal support from UpRights, published the “Practitioner’s Guide to Addressing Alleged Serious Human Rights Violations and International Crimes Committed by the IRGC in Iran and Abroad”. Building on the Pasdaran Documentation Project (PDP), the Guide transforms structured documentation into a tool practitioners can actively use in navigating complex accountability landscapes concerning Iran.
Instead of functioning as an overly technical manual, the Guide is designed as a pragmatic roadmap to support victims, lawyers, investigators, civil society and other actors seeking practical ways to pursue accountability for alleged Islamic Revolutionary Guard Corps (IRGC)-linked violations and international crimes. In the absence of effective domestic remedies in Iran, the Guide realistically maps judicial, quasi-judicial and non-judicial pathways available outside Iran, including the limitations and challenges of each pathway. The Guide was presented by Valérie Gabard, Co-Director of UpRights during Asser Institute’s Panel Discussion, “Islamic Revolutionary Guard Corps: human rights violations and international crimes in Iran and beyond” on 5th February 2026.
This blogpost explores the Guide’s role as a practical tool to challenge impunity where domestic remedies are absent or ineffective. It examines the methodological approach used to identify feasible accountability pathways during the development of the Guide and highlights key considerations for practitioners seeking to apply this approach across different contexts.
The PDP, built by HRA with legal support from UpRights, was created with future accountability efforts in mind. The database systematically maps the IRGC’s structure, units, chains of command from its inception to the present day, and links those to documented incidents of serious human rights violations and potential international crimes, including repression within Iran and operations connected to IRGC structures abroad. Today, the PDP Database houses profiles of more than 4,800 IRGC members and 84,700 IRGC units, providing practitioners with solid foundations to advance accountability while also serving as an enduring public record of an institution notorious for its widespread abuses.
Developing an Accountability Strategy
Recognising that accountability could be pursued on multiple fronts, the Guide provides practitioners across the world with a concrete and clear methodology to identify pathways to accountability, gain practical insights and plan effective international strategies as there are no viable domestic remedies in Iran. It adopts a victim-centred and broad approach to accountability encompassing judicial, quasi-judicial and non-judicial pathways, including transitional justice mechanisms, and sets out to assess the viability of different pathways.
Developing an accountability strategy like the one outlined in the guide starts with the documentation and assessment of the human rights violations and/or international crimes committed and the perpetrators that are alleged to be responsible for these acts. Since its establishment in 1979, the IRGC – a parallel military institution created in 1979 to protect the Iranian revolution and who respond directly to Iran’s Supreme Leader – has been allegedly responsible for a wide range of serious human rights violations and international crimes committed both within Iran and abroad. Outside of Iran, allegations of human rights violations or crimes involving IRGC’s members have been reported all over the world for decades and are an integral part of the IRGC modus operandi. These incidents mostly target dissidents or interests of foreign enemies to the Iranian regime such as the 1994 AMIA bombing in Argentina.
In Iran, the IRGC’s involvement in violations or crimes relates inter alia to the targeting of political dissidents, journalists, activists, and any perceived enemy of the regime, including by kidnapping dissidents abroad and running unofficial detention centres across the country. Over the years, the IRGC has been involved in the violent repression of most, if not all, the protests challenging the Iranian Government. Most recent crackdowns like the repression of 2022-2023 “Woman, Life, Freedom”movement, and incidents such as the 2022 “Bloody Friday” in Zahedan not only constitute serious human rights violations but also amount to crimes against humanity, including political and gender persecution, as shown in our submission to the UN Independent International Fact-Finding Mission on Iran (FFMI) from 2023.
The IRGC also appears to bear primary responsibility for the deadly crackdown on protesters between 8 to 10 January 2026. Based on publicly available information to date, the acts committed by the IRGC in this context similarly may meet the threshold of crimes against humanity in light of the verified scale of killings and injured, number of protesters arrested and detained, forced confessions already broadcast, nationwide geographic distribution, and deliberate deployment of military-grade weapons against civilians, as documented in HRA’s latest report.
Based on the human rights violations and/or international crimes documented, the second step is to map the full range of accountability pathways understood broadly as including judicial, quasi-judicial and non-judicial available at the international level. While Iran is the primary duty-bearer for its citizens’ human rights, there are no viable domestic remedies within Iran which makes accountability avenues outside Iran essential for victims seeking justice or redress.
In this context, human rights violations generally refer to violations attributable to the State – thereby engaging State responsibility. International crimes, by contrast, concern individual criminal responsibility under international law. The Guide underscores that accountability pathways for serious human rights violations and international crimes at the international level are fragmented and rarely offer fully satisfactory answers or comprehensive solutions for victims and affected communities.
As a result, the mapping contained in the Guide emphasises the strategic use of combined/mixed pathways such as criminal prosecution in third States under universal or extraterritorial jurisdiction, targeted sanctions under Magnitsky-style and global human rights sanctions regimes, and engagement with relevant UN mechanisms. Rather than presenting any single pathway as a solution, the Guide highlights the need for a coordinated, long-term strategy as well as the importance to have realistic expectations about each pathway’s viability and potential outcomes.
The mapping of accountability pathways is often undertaken in a theoretical manner – this fails to provide direct support to practitioners. Accordingly, the Guide incorporates a feasibility analysis. For each pathway, consideration is taken to outline in concrete and accessible terms:
- its legal requirements;
- the evidentiary thresholds needed;
- Iran’s limited treaty ratification, reservation or declaration;
- current contextual risks, challenges and political constrains; and
- lessons from past Iran-related or other comparable efforts.
Because the alleged violations may amount to crimes against humanity and therefore attract criminal responsibility under international law, the Guide evaluates accountability options for both States responsibility and individual criminal liability. For example, it examines potential pathways at the International Criminal Court (ICC), International Court of Justice (ICJ), and third States proceedings under universal or extraterritorial jurisdiction and their feasibility.
For instance, because Iran is not a State Party to the ICC, the ICC’s ability to exercise jurisdiction over crimes committed in Iran or by Iranian nationals, such as IRGC members, is extremely limited and currently unrealistic. The ICJ also has its own legal and political obstacles which make this pathway particularly challenging in the context of Iran. Recognising these limitations, the Guide places greater emphasis on feasible domestic forums outside Iran, notably third States proceedings under universal or extraterritorial jurisdiction, as the more realistic pathway to advancing criminal accountability,
In addition, States’ responsibility for human rights violations can be pursued in parallel through different forums, including strategic engagement with relevant UN mechanisms such as the FFMI, and using Magnitsky-style and EU sanctions regimes. While these tools have their limitations, including the lack of formal victim participation in the sanction’s designation process, they still serve as an important accountability tool especially when available avenues are otherwise limited. The Guide also recommends that any strategy on accountability related to Iran be framed under broader transitional justice principles to ensure on the long term that Iranian society can come to terms with its legacy of States’ abuses.
Key Considerations for Practitioners Applying This Approach Across Different Contexts
The approach underpinning the Guide offers a structured framework that practitioners can adapt across different contexts to pursue accountability, including incorporating transitional justice principles and pursuing non-judicial pathways for serious human rights violations and international crimes.
First, an effective accountability strategy begins with clearly identifying the types of violations, the scale of harm and the individuals or entities responsible. Tools like the PDP Database are especially valuable as they enable practitioners to transform fragmented information into connected, verifiable patterns of violation backed by structured, evidence-based documentation.
Second, practitioners must have clear objectives related to the accountability efforts they wish to pursue. Different accountability pathways serve different purposes. Practitioners need to decide whether they want to pursue short-term outcomes such as engaging with UN mechanisms or securing sanctions designations, or longer-term goals such as third States universal jurisdiction, or support to potential transitional justice initiatives. Each pathway comes with its own legal and jurisdictional requirements, evidentiary standards, risks, challenges and limitations. Clearly defining the objectives pursued is what can make accountability efforts move from abstract goals to actionable, effective strategies.
Third, context specificity is crucial in understanding different nuances and shaping accountability strategies. A pathway that worked in one country or case may not be viable in another. Effective strategies must therefore be tailored to the specific jurisdictional and legal requirements, evidentiary standards, political willingness and situational realities of each context. By conducting careful legal and contextual analysis together with a rigorous feasibility assessment, practitioners will be able to determine which pathways are most realistic and effective given the context.
Fourth, practitioners must keep in mind that accountability efforts can expose victims, witnesses, their families, and organisations involved in documentation or advocacy, to reprisals, intimidation or legal risks. Aiming to pursue accountability can also easily create unrealistic expectations for victims and communities that should be properly understood and managed from inception. This is why risk assessment must sit at the centre of planning and practitioners must always prioritise a “Do No Harm” approach.
Conclusion
Judicial, quasi-judicial and non-judicial pathways together form a broader accountability ecosystem and when used strategically, each pathway can reinforce and strengthen one another. The most effective approach at the international level is rarely a single, isolated effort but mixed, long-term accountability strategies that combines multiple pathways conducted by one or several actors. For practitioners facing difficulties in navigating complex international accountability landscapes, the Guide serves as a practical tool in helping to map viable pathways, set realistic expectations, and design both advocacy and accountability strategies that can best deliver tangible results for victims pursuing recognition and some form of redress for their suffering.
