E-commerce group urges lawmakers to scrap overlapping regulators in Iran’s cyberspace bill

The Tehran E-Commerce Association has urged Iranian lawmakers to remove overlapping regulatory and enforcement structures from a proposed cyberspace governance bill, warning that they would leave digital businesses facing greater legal uncertainty.

In a statement setting out five sets of proposed changes, the trade group said the first version of the bill would create new regulators, additional obligations and parallel penalties without clarifying the powers of existing institutions.

The association supports efforts to improve cyberspace governance, but said clearer jurisdiction and stable, predictable rules should be the priority. Its objections also cover requirements for human review of content before publication, exact age verification and broadly defined security duties.

Put businesses’ obligations in the law

The association’s first objection concerns provisions that leave details of identity verification, security requirements and procedures for handling violations to decisions by the Supreme Council of Cyberspace and its commissions.

It said basic rights and duties that create binding legal responsibilities for businesses should be defined clearly in the legislation itself. Leaving those matters to bodies outside the legislative process would undermine legal certainty and investment, the group said.

Its second objection targets Article 4, which, according to the association, places numerous regulators alongside one another without defining how their powers relate to existing laws. Businesses would be left uncertain about which authority they must answer to for a particular activity, it said.

The association wants the table in Article 4 removed entirely and each institution’s jurisdiction determined by the existing laws governing its sector. A service being provided online should not, by itself, give another body overlapping authority, it said.

Challenge to a new enforcement panel

The third set of objections concerns a proposed three-member, nonjudicial enforcement panel that would include only one judge.

The association said a parallel system for imposing penalties would increase businesses’ legal exposure when courts, the Governmental Discretionary Punishments Organization, trade bodies and the Competition Council already handle relevant disputes or violations. It also criticized unclear definitions of violations and potential overlap with existing laws.

It called for the provision establishing the new body to be removed and replaced with safeguards for fair proceedings: violations defined in law, protection against duplicate punishment, proportionate penalties and the right to a defense.

Content review, age checks and internet restrictions

The association said requirements to classify all content, with final human oversight before it is displayed, and to verify users’ exact ages would be practically impossible to meet at the scale of platforms built around user-generated content. It warned that enforcing those duties could force such businesses to close.

It pointed to Article 751 of Iran’s Islamic Penal Code, saying existing law already sets out hosting providers’ responsibilities for criminal content.

The group also objected to a broadly worded obligation to ensure security in all respects without specifying technical standards. It wants those duties redesigned around proportionality, feasibility and data minimization.

On internet access, the association called for an explicit safeguard: a provision allowing access to be cut or restricted under an order from a legally competent authority should not authorize nationwide or regional internet shutdowns.

A 30-day minimum for public comment

The association welcomed Article 7, which would require public bodies to publish draft regulations and seek stakeholders’ views, as a step toward reducing abrupt decisions.

It wants that process strengthened through a public consultation period of at least 30 days, publication of regulatory impact assessments and effective enforcement. Regulations adopted without following those procedures should be open to annulment, it said.

In its concluding recommendations, the association asked lawmakers to remove the overlapping structures and tables in Articles 4 and 5 and focus on reducing conflicts between regulators and improving conditions for the digital economy.

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