Iran Nuclear Agreement Review Act of 2015: Review, Sanctions, JCPOA

The Iran Nuclear Agreement Review Act of 2015, often shortened to INARA, is the federal law that gives Congress a formal role in reviewing any nuclear deal the United States reaches with Iran before the President can lift related sanctions. Signed as Public Law 114-17, it amended the Atomic Energy Act of 1954 by adding a new Section 135, now codified at 42 U.S.C. § 2160e.¹ The statute requires the President to hand over the full text of any qualifying agreement, freezes sanctions relief during a defined review window, and sets up a recurring compliance check every 90 days for the life of the deal.

What Counts as an Agreement Under the Law

INARA’s definition of “agreement” is deliberately broad. It covers any arrangement related to Iran’s nuclear program that involves the United States, commits the country to action, or provides significant nuclear-related sanctions relief. The deal does not have to be a treaty, and it does not have to be legally binding. Political commitments, joint plans of action, and informal understandings all qualify, and so do every annex, appendix, side agreement, implementing document, and technical guidance connected to them.²

That scope was a deliberate design choice. Congress wanted to prevent the executive branch from structuring a deal as something other than a treaty in order to escape legislative review.

What the President Must Submit, and When

Within five calendar days of reaching a qualifying agreement, the President has to send Congress a complete package. That package has three pieces:²

The full agreement, with every annex, appendix, side agreement, and technical understanding attached.
A verification assessment from the Secretary of State evaluating whether the International Atomic Energy Agency can adequately monitor Iran’s compliance, including inspection access and safeguards at Iranian facilities.
A presidential certification that the agreement includes appropriate limits on Iran’s nuclear activities, that any sanctions relief is spelled out, and that the deal meets U.S. nonproliferation objectives without jeopardizing national security.

The review clock does not begin until every piece of the package is in Congress’s hands. An incomplete submission simply stalls the process, and the freeze on sanctions relief stays in place until it’s fixed.

The Review Period and the Sanctions Freeze

Once Congress receives a complete submission, a 30-calendar-day review period begins. The Senate Foreign Relations Committee and the House Foreign Affairs Committee hold hearings, receive briefings, and evaluate the deal.² The statute carved out one exception: agreements transmitted between July 10, 2015, and September 7, 2015, got a 60-day review period. That window was written for the Joint Comprehensive Plan of Action (JCPOA), finalized on July 14, 2015.¹

Throughout the review period, the President cannot waive, suspend, reduce, or otherwise limit any statutory sanctions on Iran. Executive orders cannot override sanctions Congress wrote into law. The freeze reaches across the full range of Iran-related economic penalties, including banking, energy, and trade.²

The freeze can also stretch past the basic window. If both chambers pass a joint resolution of disapproval, it continues for another 12 days. If the President vetoes that resolution, it holds for 10 more days while Congress considers an override.³

How Congress Can Respond

Once the review period begins, Congress has three basic paths, each leading to a different outcome.

Joint Resolution of Approval

If both the House and Senate pass a joint resolution stating that Congress favors the agreement, the President may immediately begin implementing sanctions relief consistent with the deal’s terms.²

Inaction

If Congress passes nothing during the review period, the President regains authority to proceed with sanctions relief when the clock expires. Under the statute’s framework, inaction functions as passive consent.²

Joint Resolution of Disapproval

If both chambers pass a resolution stating that Congress does not favor the agreement, the President is legally barred from providing any sanctions relief tied to Iran’s nuclear program. That effectively kills the financial side of a deal without requiring the United States to formally withdraw from the agreement itself.² If the President vetoes a disapproval resolution, a two-thirds majority in both chambers is required to override, and the sanctions freeze remains in force during the fight.

The 90-Day Compliance Certification

Congressional oversight does not end when a deal takes effect. Every 90 days, the President has to certify to Congress that four conditions still hold:²

Iran is transparently, verifiably, and fully carrying out every aspect of the agreement, including all related technical arrangements.
Iran has not committed a material breach, or if it has, the breach has been cured.
Iran has not taken any action, including covert activities, that could significantly advance a nuclear weapons capability.
The suspension of sanctions remains appropriate and proportionate to Iran’s verified steps, and vital to U.S. national security interests.

The first three items are largely factual. The fourth is a policy judgment, and a new administration may see it differently than its predecessor. That distinction turned out to matter.

Fast-Track Sanctions Restoration

If the President declines to certify, or if Iran is found to have materially breached the agreement, INARA unlocks an expedited legislative track for reimposing sanctions. Congressional leaders can introduce sanctions-restoration legislation within 60 days of the triggering event under accelerated rules that bypass the usual committee timeline.¹ If committees do not act within 10 days, the bill is automatically discharged; floor consideration follows three days later. Senate debate is time-limited, and a motion to proceed is guaranteed a vote, which prevents a single senator from stalling the legislation indefinitely.

How the Law Played Out With the JCPOA

The JCPOA was the agreement INARA was built for. Because it fell inside the July–September 2015 window, the 60-day review period applied. Opponents in the Senate introduced a resolution of disapproval, but supporters blocked it procedurally. A September 2015 cloture vote fell short of the 60 needed to advance, 58–42. With no joint resolution enacted, the President kept the authority to begin lifting sanctions.

The 90-day certification requirement then became the ongoing oversight mechanism. The Obama administration certified compliance in each cycle. The Trump administration initially continued certifying, then in October 2017 declined to do so, specifically refusing to affirm that continued sanctions suspension remained vital to U.S. national security interests. That was a policy call, not a finding that Iran had breached the technical terms of the deal.

Decertification under INARA did not by itself reimpose sanctions or pull the United States out of the agreement. It opened the 60-day fast-track window, and Congress chose not to pass sanctions-restoration legislation. The actual withdrawal came separately on May 8, 2018, when President Trump announced the United States would stop participating in the JCPOA. The Treasury Department’s Office of Foreign Assets Control then reimposed the full range of previously lifted sanctions, completing the process on November 5, 2018, after a 180-day wind-down period.⁴

Why the Law Still Matters

INARA remains codified at 42 U.S.C. § 2160e and applies to any future nuclear agreement with Iran, not just the JCPOA.² If the United States enters a new nuclear deal with Iran, the same submission requirements, review periods, sanctions freeze, and certification obligations kick in. The broad definition of “agreement” means the law captures political commitments and informal frameworks, not just formal treaties, so the executive branch cannot easily structure around it. For businesses and financial institutions, this means any sanctions relief tied to an Iran nuclear agreement carries built-in uncertainty: Congress retains the power to block relief by disapproval, and the recurring 90-day certification means relief can be challenged again and again regardless of which party holds the White House.

1
Congress.gov. Public Law 114-17 – Iran Nuclear Agreement Review Act of 2015
2
Office of the Law Revision Counsel. 42 USC 2160e – Congressional Review and Oversight of Agreements With Iran
3
Congress.gov. 114th Congress – Iran Nuclear Agreement Review Act of 2015
4
U.S. Department of the Treasury. Re-Imposition of the Sanctions on Iran That Had Been Lifted or Waived Under the JCPOA