Iran

National Biodiversity Strategy and Action Plan

Southern AsiaApplies 2024–2030Source: Iran NBSAP

1. Overview

Iran's third National Biodiversity Strategy and Action Plan, NBSAP3 (2024–2030), sets out 23 national commitments* organised under four national goals aligned with the Kunming-Montreal Global Biodiversity Framework's Goals A–D (Iran's National Goals A–D mirror GBF Goals A–D). The strategy covers terrestrial, inland water, marine, and coastal biodiversity across Iran's 1,648,000 km² territory, spanning conservation, sustainable use, benefit-sharing, and implementation means.

The 23 national commitments address all 23 GBF Targets, with each NT mapped to a corresponding Target. The NBSAP anchors multiple commitments to Iran's 7th Five-Year Development Plan (2024–2029),† the principal national planning instrument, and references the Modern Forestry Plan and the HADI Master Plan‡ as additional delivery frameworks. The document contains no budget allocations, cost estimates, or indicator framework. Six national commitments (NT-9, NT-12, NT-13, NT-19, NT-21, NT-23) contain actions marked "to be completed later," and the strategy includes no implementation timeline or phasing between now and 2030 [§6][§35][§38][§40][§48][§50][§52].

†Iran's 7th Five-Year Development Plan (2024–2029) is the principal national planning instrument; the NBSAP anchors multiple commitments to it. ‡HADI is Iran's comprehensive rural development plan, referenced as the framework for sustainable industry zoning [§45].

Structurally, the NBSAP treats villagers, pastoralists, and nomadic tribes as a named stakeholder category throughout — appearing in at least 15 of 23 national commitments — rather than using the CBD's "Indigenous peoples and local communities" framing. Two absolute prohibitions distinguish the strategy: a ban on transgenic crop cultivation and a ban on natural forest logging, both anchored to the 7th FYDP. The Preface acknowledges international sanctions as a binding constraint on environmental finance [§6].

Iran's NBSAP commits to 30% conservation and 30% restoration targets by 2030, addresses all 23 GBF Targets, and treats pastoralists and nomadic tribes as a distinct governance category across most national commitments — while acknowledging that six commitments remain incomplete and no finance architecture exists.

Sources:

§6 — Preface
§35 — NT-9
§38 — NT-12
§40 — NT-13
§45 — NT-15 > Actions, Plans, and Aims
§48 — NT-19
§50 — NT-21
§52 — NT-23

2. Ecological Context

Iran occupies 1,648,000 km² of the Iranian Plateau, functioning as a biogeographic bridge between Europe and Asia [§13]. Dramatic altitudinal variation — from sea level at the Persian Gulf coast to peaks exceeding 3,000 metres — produces sharp climatic gradients over short distances, with the NBSAP citing the example of a half-hour drive near Ardabil Province descending over 3,000 metres from the summit of Sablan Mountain to the warm Moghan plain [§12].

This topographic complexity supports 54,509 recorded species, including 11,900 plant species, 1,323 fish species, 580 bird species, 270 reptile species, and 230 mammal species [§14][§15]. Iran is a centre of plant genetic diversity, home to over 8,300 species of agricultural and garden plants — exceeding the genetic diversity of the entire continent of Europe [§16]. The plant genera Astragalus (800 species), Cousinia (210), and Acantholimon (83) are particularly abundant [§16]. Domestic animal breed diversity encompasses approximately 120 million livestock units across native cattle, buffalo, sheep, goat, horse, chicken, and camel breeds [§16].

Despite an arid climate, Iran's wetlands host globally significant populations of migratory birds [§13]. Mountain forests supply over 47% of fresh water [§14]. The marine and coastal zones encompass 25 ecological types and units, with coral reefs, bays, and small islands identified as the most significant habitats [§14]. Key pressures include land-use change, overexploitation of wild species (including indiscriminate harvesting of medicinal plants), water resource depletion, and invasive alien species [§26][§35].

Sources:

§12 — Iran Biodiversity in Brief
§13 — National Level Values of Biodiversity and Ecosystem Services
§14 — Ecosystem Diversity
§15 — Species Diversity
§16 — Genetic Diversity
§26 — NT-1
§35 — NT-9

3. National Commitments and GBF Alignment

Iran's 23 national commitments are grouped below by the NBSAP's four national goals.

National Goal A: Protection and Restoration of Ecosystems (NT-1 through NT-8)

NT-1 (GBF Targets 1, 2, 4) commits to halting anthropogenic extinction caused by land- and sea-use changes by 2030 "through a participatory approach incorporating traditional knowledge of native, pastoralists, and nomadic tribes" [§26]. It includes 26 sub-actions spanning: a national biodiversity data warehouse with Spatial Data Infrastructure by 2030; Red Data Books for plants, fungi, invertebrates, and vertebrates; an invasive alien species inventory; captive breeding for the Persian Wild Ass and Persian Fallow Deer; designation of highland glaciers as new protected areas; Transboundary Biosphere Reserves; and habitat corridors for the Iranian leopard. A restoration sub-target sets 30% of degraded terrestrial, inland water, marine, and coastal ecosystems under effective restoration by 2030 [§26]. Measurability: the 30% restoration figure is a measurable commitment; the extinction-halt pledge is a directional aspiration (no baseline extinction rate or measurement protocol defined).

NT-3 (GBF Target 3) sets a 30% conservation target: by 2030, at least 30% of Iran's terrestrial, inland water, marine, and coastal areas are to be effectively conserved through ecologically representative, well-connected, and equitably governed systems of protected areas and OECMs [§28]. The strategy specifies expanding coverage by designating non-hunting prohibited areas near current protected sites based on the IUCN Matrix, and establishing Urban Protected Areas (UPAs) and Private Protected Areas (PPAs). Iran's 309 protected sites (approximately 189,693 km²) — see Target 3 in Section 7 — provide the current baseline. Pastoralists' and nomadic tribes' lands are explicitly included within the conservation target [§28]. Measurability: measurable commitment — clear area threshold and deadline.

NT-5 (GBF Targets 5, 6, 7) addresses sustainable use of wild species, invasive alien species, and pollution. It commits to reducing IAS introduction and establishment rates by at least 50% by 2030; reducing excess nutrients by at least half; reducing pesticide and hazardous chemical risk by at least half; and "preventing, reducing, and working towards eliminating plastic pollution" [§30]. Measurability: the IAS, nutrient, and pesticide sub-targets are measurable commitments; sustainable harvest and plastic elimination language is directional.

NT-8 (GBF Target 8) commits to minimising Iran's contribution to climate change and ocean acidification impacts on biodiversity through mitigation, adaptation, and ecosystem-based approaches [§32]. Actions include gender-responsive climate adaptation for pastoralist and rural women, climate resilience indicators based on scientific and traditional knowledge, and conservation of traditional seed varieties through Evolutionary Plant Breeding [§32]. Measurability: directional aspiration — no quantified thresholds.

National Goal B: Sustainable Use and Development (NT-9 through NT-13)

NT-9 (GBF Target 9) and NT-10 (GBF Target 10) address wild species management and sustainable agriculture/forestry. NT-9 commits to sustainable management providing benefits "especially for those in vulnerable situations and most dependent on biodiversity" [§35]. NT-10 commits to increasing biodiversity-friendly practices across agriculture, aquaculture, fisheries, and forestry, and includes the prohibition on wood harvesting from natural forests under the 7th FYDP [§43]. Measurability: both are directional aspirations. NT-9's action list is incomplete.

NT-11 (GBF Target 11) commits to restoring and enhancing nature's contributions to people through nature-based solutions, including a national wetland action plan with provisions against unauthorised water harvesting and a market for exchanging non-conventional waters [§37]. Measurability: directional aspiration.

NT-12 (GBF Target 12) commits to "significantly increase the area, quality, and connectivity of green and blue spaces" in urban areas [§38]. Actions include water-use restrictions for urban green spaces and a national climate change management plan. Measurability: directional aspiration — no baseline or target area specified. Action list incomplete.

NT-13 (GBF Target 13) commits to fair and equitable benefit-sharing from genetic resources, DSI, and associated traditional knowledge, with benefits to "significantly increase" by 2030 [§40]. The NBSAP devotes multiple sections to DSI governance — spanning data management standards, ownership policies, benefit-sharing via royalty payments, IPR dispute resolution, and national data repositories — while acknowledging that Iran currently relies on general data-protection and cybersecurity laws rather than specific DSI legislation [§45][§50]. Measurability: directional aspiration — "significantly" not quantified. Action list incomplete.

National Goal C: Mainstreaming and Benefit-Sharing (NT-14 through NT-18)

NT-14 (GBF Target 14) requires full integration of biodiversity into policies, regulations, planning, environmental impact assessments, and national accounting at all levels of government [§42]. All new large-scale development plans must be evaluated against environmental standards approved by the Presidential Supreme Council of Environmental Protection [§43]. Measurability: directional aspiration.

NT-15 (GBF Target 15) commits to measures encouraging business disclosure of biodiversity risks, dependencies, and impacts across operations, supply chains, and portfolios [§44]. Actions include the proposed Energy Optimisation and Strategic Management Organisation and mineral substitution for polymer materials in the petrochemical value chain [§45]. Measurability: directional aspiration — no compliance targets or timelines.

NT-16 (GBF Target 16) commits to sustainable consumption choices, including halving food waste by 2030. Specialised industrial zones are to be created within the HADI Master Plan framework [§45]. Measurability: food waste halving is a measurable commitment; broader consumption footprint language is directional.

NT-17 (GBF Target 17) commits to biosafety and synthetic biology regulation, including a regulatory framework for synthetic biology with specific gene drive provisions and ethical guidelines addressing "creation of artificial life" [§45]. The 7th FYDP legally prohibits cultivation of any transgenic products on Iranian lands. Measurability: directional aspiration on regulatory outcomes; the transgenic ban is an absolute prohibition (measurable as compliance: yes/no).

NT-18 (GBF Target 18) commits to identifying subsidies harmful to biodiversity by 2025 and substantially reducing them by 2030 [§45]. No specific implementation actions are listed. Measurability: the 2025 identification deadline is a measurable commitment; "substantially reduce" by 2030 is directional.

National Goal D: Implementation Means (NT-19 through NT-23)

NT-19 (GBF Target 19) commits to "substantially and progressively increase" financial resources from all sources [§48]. The Preface acknowledges that international sanctions constrain environmental finance [§6]. Measurability: directional aspiration — no quantified targets. Action list incomplete.

NT-20 (GBF Target 20) commits to capacity building through South-South, North-South, and triangular cooperation, and to implementing a National Programme for the Development of Artificial Intelligence in compliance with the 7th FYDP, approved by the Supreme Council of the Cultural Revolution [§49]. Measurability: directional aspiration.

NT-21 (GBF Target 21) commits to accessible data and knowledge for decision-makers, with a Spatial Data Infrastructure by 2030, and conditions access to traditional knowledge of villagers, pastoralists, and nomadic tribes on their prior and informed consent [§50]. Measurability: the SDI by 2030 is a measurable commitment (deliverable with deadline); broader data accessibility is directional. Action list incomplete.

NT-22 and NT-23 (GBF Targets 22, 23) address inclusive participation and gender equality, committing to equitable representation of women and girls, children and youth, and villagers, pastoralists, and nomadic tribes in biodiversity decision-making [§50][§52]. NT-23 prioritises girls' education per the 7th FYDP. Measurability: both are directional aspirations. NT-23's action list is incomplete.

Sources:

§6 — Preface
§26 — NT-1
§28 — NT-3
§30 — NT-5
§32 — NT-8
§35 — NT-9
§37 — NT-11
§38 — NT-12
§40 — NT-13
§42 — NT-14
§43 — NT-14 > Actions, Plans, and Aims
§44 — NT-15
§45 — NT-15 > Actions, Plans, and Aims
§48 — NT-19
§49 — NT-19 > Actions, Plans, and Aims
§50 — NT-21
§52 — NT-23

4. Delivery Architecture

Legislation and Planning Instruments

The 7th Five-Year Development Plan (2024–2029) is the principal delivery framework, anchoring multiple national commitments including the natural forest logging prohibition, the transgenic crop cultivation ban, and the National AI Programme [§43][§45][§49]. The Modern Forestry Plan, operating within the 7th FYDP, governs Sustainable Forest Management. The HADI Master Plan provides the framework for sustainable industry zoning in rural and urban areas [§45].

All new large-scale development plans by executive bodies, private sectors, cooperatives, and NGOs must be evaluated against environmental standards approved by the Presidential Supreme Council of Environmental Protection, as assessed by the Department of Environment (DoE) [§43].

Conservation Programmes

Iran's protected area network of 309 sites is managed by the DoE. Ten international conservation programmes are active, including the Conservation of the Asiatic Cheetah, Conservation of Iranian Wetlands, Conservation of Biodiversity in Central Zagros Mountains, and Conservation of Caspian Hyrcanian Forest Biodiversity [§14]. The NBSAP proposes two new protected area categories — Urban Protected Areas (UPAs) and Private Protected Areas (PPAs) — to extend the ecological network [§28].

Regulatory Frameworks Under Development

A comprehensive regulatory framework for synthetic biology is to be established, aligned with the Cartagena Protocol on Biosafety, with specific gene drive provisions [§45]. A national DSI strategy is to address data management, ownership, benefit-sharing, and intellectual property dispute resolution [§45][§50]. The proposed Energy Optimisation and Strategic Management Organisation is to diversify the fuel basket and develop the energy optimisation market [§45].

Institutional Gaps

The NBSAP does not describe the overall governance structure, coordination between the DoE and line ministries, or national-subnational coordination. AREEO and NRWMO appear in specific actions but their cross-cutting roles are undefined [§43][§45].

Sources:

§14 — Ecosystem Diversity
§28 — NT-3
§43 — NT-14 > Actions, Plans, and Aims
§45 — NT-15 > Actions, Plans, and Aims
§49 — NT-19 > Actions, Plans, and Aims
§50 — NT-21

Pastoralist and Nomadic Tribe Governance

Villagers, pastoralists, and nomadic tribes appear as a named stakeholder category in at least 15 of Iran's 23 national commitments — a structurally distinctive feature. The NBSAP uses this national category rather than the CBD's "Indigenous peoples and local communities" framing.

The governance architecture for pastoralist participation draws on two international frameworks. Co-management models follow the World Conservation Union approach, with pastoralist and nomadic communities involved in the identification, governance, and management of protected areas [§28]. Capacity building for intersectional management follows UNESCO Man and Biosphere (MaB) criteria [§50].

Pastoralists' and nomadic tribes' traditional lands are explicitly included within the 30% conservation target (NT-3), with a community-based approach specified for expanding protected areas and OECMs [§28]. Access to traditional knowledge, innovations, and practices of these communities is conditioned on their prior and informed consent, in accordance with Iranian legislation [§50].

Across the NBSAP, pastoralist engagement spans: restoration of degraded grazing lands (NT-2); IAS monitoring using traditional knowledge (NT-6); community-based pollution monitoring (NT-7); climate resilience indicators incorporating traditional knowledge (NT-8); targeted training on sustainable use tailored to regional climatic characteristics and traditions (NT-9); and empowerment of herders, hunters, and local beneficiary groups to enhance protected area resilience (NT-22) [§26][§28][§30][§32][§35][§50].

Traditional land management practices — rotational grazing, fire management, sustainable agriculture, and transhumance — are affirmed as tools for biodiversity conservation and IAS prevention throughout the strategy [§30].

Sources:

§26 — NT-1
§28 — NT-3
§30 — NT-5
§32 — NT-8
§35 — NT-9
§50 — NT-21

5. Monitoring and Accountability

The NBSAP contains no cross-cutting monitoring and evaluation framework, no indicator framework, no baselines, and no reporting cycle [§45][§50]. The strategy sets no indicators for any national commitment. Iran does not describe how it will measure progress toward 2030 targets.

Rather than a unified accountability architecture, the NBSAP embeds monitoring provisions within individual programme areas. A monitoring and evaluation system for DSI strategy implementation is to collect data on DSI activities, research outcomes, and policy impacts [§45]. A parallel system for synthetic biology is to assess regulatory effectiveness with regular reviews [§45].

The Department of Environment and the Presidential Supreme Council of Environmental Protection are the only governance bodies referenced in the context of oversight, but the NBSAP does not describe their monitoring roles, reporting audiences, or adaptive management provisions [§43].

Public participation in accountability is addressed through mechanisms for public input in synthetic biology governance and a broader commitment to equitable representation of women and girls, children and youth, and villagers, pastoralists, and nomadic tribes in biodiversity decision-making [§45][§50].

Six national commitments (NT-9, NT-12, NT-13, NT-19, NT-21, NT-23) contain actions marked "to be completed later," indicating the accountability architecture is not yet fully elaborated [§35][§38][§40][§48][§50][§52].

Sources:

§35 — NT-9
§38 — NT-12
§40 — NT-13
§43 — NT-14 > Actions, Plans, and Aims
§45 — NT-15 > Actions, Plans, and Aims
§48 — NT-19
§50 — NT-21
§52 — NT-23

6. Finance and Resource Mobilisation

Iran's NBSAP contains no dedicated finance section, no budget allocations, no cost estimates, no financing gaps, and no quantified resource mobilisation targets. GBF Target 19 (finance mobilisation) receives a national commitment (NT-19) but no implementation actions with budgets or timelines [§48].

The Preface acknowledges that conservation efforts by the Department of Environment, AREEO, and other agencies are "progressing successfully, despite limited funds" and frames international sanctions as a binding constraint on environmental finance, expressing hope that "lifting sanctions, ensuring equitable allocation of financial resources, and fostering technical cooperation" will support progress [§6]. Iran's improvement in the Environmental Performance Index from 134th to 112th in 2024 is cited as evidence of commitment despite resource constraints [§49].

Two action items reference financial instruments without quantification: economic valuation of environmental resources with cost-of-damage assessments coordinated by DoE [§45], and identification of harmful subsidies by 2025 with substantial reduction by 2030 [§45]. The GEF is referenced as an international financing mechanism [§7]. The 7th FYDP is positioned as a domestic framework, but no FYDP budget lines dedicated to biodiversity are detailed [§6].

Sources:

§6 — Preface
§7 — Abbreviations
§45 — NT-15 > Actions, Plans, and Aims
§48 — NT-19
§49 — NT-19 > Actions, Plans, and Aims

7. GBF Target Coverage

Target 1: Spatial planning — Addressed

NT-1 commits to halting anthropogenic extinction from land- and sea-use changes by 2030 through participatory approaches incorporating traditional knowledge of villagers, pastoralists, and nomadic tribes. The principal spatial planning mechanism is a national biodiversity data warehouse with Spatial Data Infrastructure by 2030. Actions include Red Data Books compilation, an IAS inventory, designation of highland glaciers as new protected areas, expanded natural-national monument coverage to lower altitudes, and protection of habitat corridors for species including the Iranian leopard. No indicators are cited.

Target 2: Ecosystem restoration — Addressed

NT-1 includes a sub-target committing to at least 30% of degraded terrestrial, inland water, marine, and coastal ecosystems under effective restoration by 2030. Restoration actions centre on community-based approaches: incorporating traditional land management and sustainable grazing practices, rehabilitating degraded grazing lands for nomadic livelihoods, and establishing community-based monitoring of restoration projects. Both national and international funding are referenced but not quantified.

Target 3: Protected areas (30x30) — Addressed

NT-3 commits to 30% conservation of terrestrial, inland water, marine, and coastal areas by 2030 through ecologically representative systems of protected areas and OECMs. Iran manages 309 protected sites (approximately 189,693 km²): 32 national parks, 56 wildlife refuges, 40 national natural monuments, 181 protected areas, 13 UNESCO Biosphere Reserves, and 1 UNESCO Geopark. Expansion mechanisms include designation of non-hunting prohibited areas based on the IUCN Matrix and new Urban Protected Areas and Private Protected Areas categories. Pastoralists' traditional lands are explicitly included.

Target 4: Species recovery — Addressed

The NBSAP commits to halting anthropogenic extinction and reducing extinction risk tenfold by 2050. Named species recovery actions include captive breeding for the Persian Wild Ass and Persian Fallow Deer, habitat corridor protection for the Iranian leopard, and a de-extinction programme. Red Data Books for plants, fungi, invertebrates, and vertebrates are to be compiled with community involvement. Iran has catalogued 54,509 species.

Target 5: Sustainable harvest — Addressed

NT-5 commits to sustainable, safe, and legal use, harvesting, and trade of wild species, preventing overexploitation and reducing pathogen spillover risk while protecting customary sustainable use. Actions include community-based monitoring of species populations, wildlife corridor and migratory route protection, and fair trade systems ensuring equitable benefits for local communities. Transhumance and pastoralism are affirmed as sustainable practices.

Target 6: Invasive alien species — Addressed

The NBSAP sets a target of reducing IAS introduction and establishment rates by at least 50% by 2030, with eradication or control of IAS across Iran. A national IAS inventory is to be completed with pastoralist participation. Traditional land management practices — rotational grazing, fire management, sustainable agriculture — are cited as IAS prevention tools. Development project impact assessments are to include IAS risk analysis.

Target 7: Pollution reduction — Addressed

Quantified sub-targets include halving excess nutrient losses, halving pesticide and hazardous chemical risk, and "working towards eliminating" plastic pollution, all by 2030. Actions include evaluation of agricultural pesticide residues, nitrates, heavy metals, and livestock drug residues, and a tracking, packaging, and branding system for agricultural products. Community-based waste management in rural and pastoralist areas is specified.

Target 8: Climate and biodiversity — Addressed

NT-8 commits to minimising Iran's contribution to climate change and ocean acidification impacts on biodiversity through ecosystem-based approaches. Actions include gender-responsive climate adaptation for pastoralist and rural women, climate resilience indicators based on scientific and traditional knowledge, traditional seed conservation through Evolutionary Plant Breeding, and restoration of grasslands, wetlands, forests, and traditional grazing lands.

Target 9: Wild species use — Addressed

NT-9 commits to sustainable wild species management providing benefits especially for those most dependent on biodiversity. Actions include public education on unsustainable exploitation (citing medicinal plant harvesting and fishing), targeted training for villagers and pastoralists, and school curricula revision. The action list is incomplete.

Target 10: Agriculture / forestry — Addressed

A national commitment addresses sustainable management of agriculture, aquaculture, fisheries, and forestry with biodiversity-friendly practices. The NBSAP prohibits exploitation and harvesting of wood from natural forests, framed within Sustainable Forest Management and the Modern Forestry Plan under the 7th FYDP. Environmental risk assessments are required before new resource exploitation projects.

Target 11: Ecosystem services (NbS) — Addressed

NT-11 commits to restoring and enhancing nature's contributions including air, water, and climate regulation, soil health, pollination, and disease risk reduction through nature-based solutions. Key mechanisms include a national wetland action plan with anti-unauthorised water harvesting provisions, a non-conventional water exchange market, and operational guidelines requiring pollinator protection statements.

Target 12: Urban biodiversity — Addressed

NT-12 commits to increasing green and blue space area, quality, and connectivity in urban areas through biodiversity-inclusive planning. Actions include water-use restrictions for urban green spaces (well counters, ban on drinkable water for irrigation where alternatives exist) and a national climate change management plan linked to green economy goals. The action list is incomplete.

Target 13: Genetic resources / ABS — Addressed

NT-13 commits to fair and equitable benefit-sharing from genetic resources, DSI, and traditional knowledge, with benefits to increase by 2030. The NBSAP outlines an extensive DSI governance architecture: data management standards, ownership policies, benefit-sharing through royalty payments, IPR dispute resolution, and national data repositories — while acknowledging no specific DSI legislation currently exists. GBIF participation is noted. The action list is incomplete.

Target 14: Mainstreaming — Addressed

NT-14 requires full integration of biodiversity into policies, regulations, planning, EIAs, and national accounting. All large-scale development plans must be evaluated against environmental standards approved by the Presidential Supreme Council of Environmental Protection. The national wetland action plan and natural forest logging prohibition are mainstreaming instruments (see Targets 10 and 11).

Target 15: Business disclosure — Addressed

NT-15 commits to legal, administrative, or policy measures encouraging business disclosure of biodiversity risks, dependencies, and impacts across operations and supply chains. Actions include binding waste management guidelines, the proposed Energy Optimisation and Strategic Management Organisation, and mineral substitution for polymer materials in the petrochemical value chain. A DSI monitoring and evaluation system is integrated into the business disclosure framework.

Target 16: Sustainable consumption — Addressed

A national commitment addresses sustainable consumption choices, including halving food waste by 2030. Specialised industrial zones for clean industries and waste management are to be created within the HADI Master Plan framework. The action list is incomplete.

Target 17: Biosafety — Addressed

The NBSAP commits to a comprehensive synthetic biology regulatory framework aligned with the Cartagena Protocol, with specific gene drive provisions and ethical guidelines addressing "creation of artificial life." The 7th FYDP legally prohibits cultivation of any transgenic products — domestic or imported — on Iranian lands. Risk assessments are required before field trials or environmental release of synthetic organisms. Iran acknowledges it currently lacks specific synthetic biology regulations.

Target 18: Harmful subsidies — Addressed

A national commitment sets a 2025 deadline to identify subsidies harmful to biodiversity and calls for substantial reduction by 2030, with scaling up of positive incentives. The target statement mirrors KMGBF language. No specific implementation actions are listed.

Target 19: Finance mobilisation — Addressed

NT-19 commits to substantially and progressively increasing financial resources from all sources. The NBSAP contains no quantified finance targets, budget allocations, or costed implementation plans. International sanctions are acknowledged as constraining resource mobilisation. The 7th FYDP is positioned as the domestic financing framework. The action list is incomplete.

Target 20: Capacity and technology — Addressed

A national commitment addresses capacity building through South-South, North-South, and triangular cooperation. The NBSAP commits to implementing a National Programme for the Development of Artificial Intelligence, approved by the Supreme Council of the Cultural Revolution, as a biodiversity implementation tool — a distinctive institutional linkage. DSI capacity building through training, international knowledge exchange, and university education programmes is specified.

Target 21: Data and information — Addressed

NT-21 commits to accessible data and knowledge for decision-makers, with a Spatial Data Infrastructure and online biodiversity portal by 2030. Open data principles and data licensing are referenced. Traditional knowledge of villagers, pastoralists, and nomadic tribes is subject to prior and informed consent requirements under Iranian legislation. A national DSI strategy is to be established. The action list is incomplete.

Target 22: Inclusive participation — Addressed

A national commitment ensures equitable representation of women and girls, children and youth, and villagers, pastoralists, and nomadic tribes in biodiversity decision-making. Co-management governance models follow the World Conservation Union approach. Capacity building for intersectional management follows UNESCO MaB criteria. Pastoralists and nomadic tribes are referenced as distinct stakeholder categories throughout the NBSAP.

Target 23: Gender equality — Addressed

NT-23 commits to equitable participation of women and girls, recognising their access to land and natural resources. The primary action prioritises girls' education: recruiting education survivors in elementary schools, developing flexible curricula approved by the Supreme Council of Education, and providing educational resources per the 7th FYDP. NT-8 separately addresses vulnerabilities of women and girls in pastoralist and rural communities to climate change. The action list is incomplete.