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The Third Failure? RevCon 2026, Strikes on Civilian Nuclear Infrastructure, and the Future of the Peaceful Use Regime
Tahir Azad
Analysis Series
Analysis//0014/May/2026/London-Dialogue. 02 May 2026
Introduction
On April 27, 2026, the Eleventh Review Conference of the Treaty on the Non-Proliferation of Nuclear Weapons opened at the United Nations Headquarters in New York under conditions that no previous review cycle has faced. The NPT entered into force in 1970 and was indefinitely extended in 1995. Its three pillars, non-proliferation, disarmament, and the peaceful use of nuclear energy, were designed to operate as a single, mutually reinforcing bargain: non-nuclear-weapon states agreed not to acquire nuclear arms, the five recognised nuclear-weapon states (P5) accepted a legal obligation to negotiate disarmament, and all parties received an inalienable right under Article IV to develop civilian nuclear technology under IAEA safeguards. That bargain is now under acute strain. The 2015 and 2022 Review Conferences both ended without consensus final documents, the first over the unfulfilled 1995 resolution on a Middle East zone free of weapons of mass destruction and the second over the situation at the Zaporizhzhia Nuclear Power Plant in Ukraine. RevCon 2026 inherits both unresolved disputes and adds a third that is, in legal and political terms, more consequential than either of its predecessors.
Between 13 and 24 June 2025, and again from 28 February 2026, Israel and the United States conducted sustained military strikes on Iranian nuclear facilities at Natanz, Fordow, and Isfahan, as well as the Khondab heavy water complex near Arak. All targeted facilities were under IAEA safeguards. The IAEA Director-General, Rafael Mariano Grossi, told the UN Security Council on 20 June 2025 that the Agency had no proof of a systemic Iranian effort to build a nuclear weapon and reiterated the long-standing IAEA principle that armed attacks on nuclear facilities should never take place.
This is the first time in the Treaty’s history that a depositary state, the United States, has conducted kinetic strikes on the safeguarded peaceful nuclear infrastructure of another State Party. The Iranian working paper NPT/CONF.2026/WP.22submitted to the Conference frames the question explicitly: does NPT membership confer any meaningful protection on a non-nuclear-weapon state that complies with safeguards? This article addresses that question by tracing the pattern of failure across the two previous review cycles, examining the legal damage to Article IV, and assessing the strategic consequences for the global nuclear energy industry. It argues that without a substantive reaffirmation of protections for safeguarded peaceful programmes, RevCon 2026 risks becoming the third consecutive failure, with implications that extend well beyond the diplomatic theatre in New York.
A Conference Held Under Fire
The Eleventh Review Conference is in session from 27 April to 22 May 2026, presided over by Ambassador Do Hung Viet of Vietnam. The Preparatory Committee cycle that led to the Conference was unproductive: as the James Martin Center for Nonproliferation Studies notes, none of the three PrepComs in 2023, 2024, or 2025 reached consensus on substantive recommendations, and the 2023 chair’s factual summary was withheld from the official record after objections from Russia and Iran.
That procedural backdrop matters because review conferences operate by consensus. A single objecting State Party can prevent adoption of a final document, as has happened at five of the last seven review cycles. The European Union, in its position paper for the Conference, has acknowledged that major breakthroughs are unlikely and has positioned itself as a bridge-builder seeking at least a procedural outcome. The United Nations Association UK has framed the Conference as a test of whether the NPT can continue to serve as the cornerstone of global nuclear governance.
The new variable that makes RevCon 2026 different is not abstract. It is the live military targeting of safeguarded civilian facilities. The Council on Foreign Relations assessment of the June 2025 strikes catalogues the use of B-2 bombers carrying GBU-57A/B Massive Ordnance Penetrators against Fordow, Tomahawk cruise missiles against Natanz and Isfahan; and the broader campaign against the Khondab heavy water reactor and the Tehran Research Center. The Institute for Science and International Security has produced the most detailed open-source damage assessment, drawing on commercial satellite imagery from the first twelve days of operations.
The Pattern of Failure: 2015 and 2022
The two previous failures of the NPT review cycle were not symmetrical and merit separate diagnosis. In 2015, the Conference collapsed when the United States, the United Kingdom, and Canada blocked the draft final document over disputed language on convening a conference on a Middle East WMD-free zone, a process mandated by the 1995 indefinite extension package but never delivered. Egypt led the criticism on behalf of the Arab Group; Israel, which is not a state party, was a recurring point of contention. The fault line was regional and structural, but the Treaty’s three pillars themselves were not directly contested. In 2022, the dynamics were different. The Russian delegation blocked consensus over references to the situation at the Zaporizhzhia Nuclear Power Plant, then under Russian military control following the February 2022 invasion of Ukraine. For the first time in the Treaty’s history, the proximate cause of failure was an active military operation by a nuclear-weapon state against the civilian nuclear infrastructure of a State Party. The Seven Indispensable Pillars of Nuclear Safety and Security, articulated by the IAEA Director-General at the start of the war, were violated repeatedly. The Vienna Convention on the Law of Treaties offered no meaningful redress.
RevCon 2026 inherits both unresolved disputes and adds a third. The Iran case has made the Zaporizhzhia precedent look almost contained. There, the strikes were carried out by a state that controlled the territory in question; here, they are external, expeditionary, and conducted by a Treaty depositary against the safeguarded facilities of a State Party that the IAEA has not declared to be developing nuclear weapons. As former IAEA official Tariq Rauf has noted, the NPT itself does not prohibit uranium enrichment, provided it is declared to the IAEA, placed under safeguards, and used for peaceful purposes. The legal architecture has no comfortable place for the present facts, and the political consequences are now being negotiated in real time.
The Iran Strikes and the Erosion of Article IV
Article IV of the NPT recognises the inalienable right of all States Parties to develop, research, produce, and use nuclear energy for peaceful purposes, in conformity with their non-proliferation obligations. It is not a permission granted by the nuclear-weapon states; it is a foundational right framed in absolute terms. Two IAEA General Conference resolutions, GC(XXIX)/RES/444 (1985) and GC(XXXIV)/RES/533 (1990), explicitly state that any armed attack on, or threat against, peaceful nuclear facilities constitutes a violation of the principles of the UN Charter, of international law, and of the Statute of the Agency. Grossi reiterated this principle at the Board of Governors on 13 June 2025 and again on 2 March 2026.
The June 2025 strikes hit facilities that were all under IAEA safeguards. The US Defense Intelligence Agency’s classified initial assessment reportedly concluded that the strikes had set Iran’s programme back by months rather than years, although the Trump administration publicly contested this finding. The Arms Control Association has assessed that Iran retained its 400-kilogram stockpile of uranium enriched to 60 per cent U-235, an undeclared third underground enrichment site, and most of its centrifuge manufacturing capacity. The PIR Center reached a similar conclusion using open-source imagery, noting that the GBU-57’s maximum penetration depth of approximately 22 metres falls well short of the 80-to-90-metre depth at which key Natanz halls are buried.
The legal upshot is that Iran’s safeguarded status under the NPT did not protect it from kinetic action by another State Party. Tehran has responded by submitting working paper NPT/CONF.2026/WP.22 and national report NPT/CONF.2026/23 to the Conference, calling for a binding prohibition on attacks against nuclear facilities and tying its argument explicitly to Article IV. Iranian legislators are simultaneously pressing for an NPT exit under Article X, a debate that until recently was confined to the hard right of Iranian politics. The point that should concentrate attention at RevCon 2026 is not whether Iran is a difficult State Party. It is that the Article IV right, as currently framed, carries no enforceable protection against the very behaviour that the IAEA’s own resolutions have for forty years declared unlawful.
Implications for the Nuclear Energy Industry
The strategic implications for the global nuclear energy industry are considerable and have been understated in wider commentary on the Iran war. Civilian nuclear expansion is now substantially a developing-world story. The United Arab Emirates operates four APR-1400 reactors at Barakah, supplied by a Korean-led consortium under a contract valued at approximately USD 20 billion. Egypt is constructing four VVER-1200 units at El Dabaa with Rosatom. Bangladesh’s Rooppur plant is in commissioning. Turkey’s Akkuyu plant is partially operational. Saudi Arabia, Indonesia, the Philippines, Vietnam, and several African states have all moved towards declared programmes. Almost without exception, these projects depend on three assumptions: that safeguarded status under the NPT confers political and physical protection, that supplier-state involvement, whether Russian, Chinese, Korean, French, or American, brings reciprocal security guarantees, and that insurance and finance markets will continue to price civilian nuclear assets as long-life, low-physical-risk infrastructure.
The Iran strikes have called all three assumptions into question. The targeting of Fordow and Natanz demonstrates that ‘safeguarded’ does not mean ‘protected’ and that no member of the P5 has been willing to invoke meaningful consequences for kinetic action against safeguarded facilities. The reported Israeli mistake about Bushehr in June 2025, retracted within hours but taken seriously enough by the IAEA to warrant a public correction, illustrates how easily a major reactor could be drawn into a conflict that it has no part in. Russia’s Rosatom holds the operating contract for Bushehr and, in September 2025, signed a USD 25 billion contract for four further reactors at the Iran-Hormoz site. Were any of these to be hit, even by accident, the contractual, insurance, and reputational implications for the wider Russian nuclear export business, a pillar of Moscow’s industrial diplomacy, would be severe.
For supplier states and newcomer states alike, the demonstration effect of the Iran case is corrosive. If a non-nuclear-weapon State Party with declared, inspected facilities can be bombed by another State Party without recourse, the political cost of pursuing peaceful nuclear power rises, and the perceived premium on hedging or breakout falls. That is the inverse of what the NPT was designed to achieve. The Nuclear Suppliers Group guidelines, the IAEA Additional Protocol, and the Comprehensive Safeguards Agreements all assume an underlying political consensus that compliance brings protection. That consensus is now visibly fraying.
Bushehr, Safety, and the Industry’s Reckoning
The most acute risk during the current war is at Bushehr. The plant sits at the intersection of three tectonic plates and houses Iran’s only operational commercial reactor under safeguards, as the World Nuclear Association country profiledetails. Grossi has repeatedly warned that any strike at or near Bushehr could trigger a radiological release of regional consequence. In March 2026 the IAEA reported a projectile impact within 350 metres of the reactor, an incident that produced no damage but underlined the fragility of safety margins in this conflict.
Beyond Iran, the broader regional implications are uncomfortable. The UAE’s four operational reactors at Barakah lie within range of regional missile arcs. Jordan and Syria operate research reactors. Saudi Arabia’s anticipated programme will face new questions from regulators and insurers. The IAEA’s Seven Indispensable Pillars, originally articulated for the Ukraine context but increasingly cited in the Iran case, will need to be elevated from guidance to something closer to an enforceable norm if civilian programmes in conflict-prone regions are to remain financeable.
Industry bodies have so far been quiet. The World Nuclear Association notes the IAEA’s June 2025 finding of Iranian non-compliance and the subsequent military operation in clinical terms. There has been no equivalent comprehensive statement from major suppliers, Rosatom, KEPCO, EDF, or Westinghouse, or from the Lloyd’s of London market on the precedent set. RevCon 2026 will be the first multilateral forum in which industry interests, articulated through state delegations, can either demand enhanced protection for safeguarded peaceful programmes or accept by default that the Article IV right has been quietly downgraded.
A Critical Analysis: Three Scenarios for RevCon 2026
On the evidence so far, the most likely outcome of RevCon 2026 is a third consecutive collapse, but the modalities matter and merit careful disaggregation. There are three plausible scenarios.
The first is a procedural failure of the type seen in 2015, in which the Conference adjourns without a final document over irreconcilable language on the Iran strikes, the Israeli nuclear arsenal, and the Middle East zone. This is the baseline expectation. The Non-Aligned Movement, the Group of 77, and a substantial portion of the Arab Group are likely to insist on language condemning attacks on safeguarded facilities. The United States, supported by the United Kingdom, will resist. France’s recent positioning on extended deterrence in Europe and the United Kingdom’s increased warhead ceilinghave already eroded P5 credibility on Article VI. Consensus is unattainable.
The second is a more damaging walkout, in which Iran formally suspends its participation or signals an intention to invoke Article X withdrawal. Iranian parliamentary discussions through March and April 2026 indicate that this is no longer a fringe option. Hardliners have previously demanded an NPT exit in response to outside pressure. A walkout during the Conference itself would be a political earthquake whose aftershocks would extend across the Middle East and into the calculations of every threshold state, from Saudi Arabia to South Korea and Japan.
The third, and most unlikely, is a partial substantive outcome in which the Conference adopts a stand-alone declaration reaffirming the inviolability of safeguarded peaceful nuclear facilities, even without consensus on a full final document. This would be a meaningful achievement for the industry and for the Treaty’s third pillar and would partially restore the bargain. The BASIC Nuclear for Good initiative and similar civil-society platforms have laid some of the groundwork; whether enough states are willing to lend their political capital to it is another question.
The deeper diagnostic is that the NPT’s grand bargain, weapons restraint by the non-nuclear-weapon states in exchange for disarmament progress and unimpeded peaceful use, is no longer being honoured by either side. Strikes on safeguarded facilities, by states with strategic arsenals that they are openly modernising, mark a shift from selective non-compliance to structural renegotiation by force. The Treaty on the Prohibition of Nuclear Weapons, whose own first review conference is scheduled later in 2026, offers an alternative framework for the non-nuclear-weapon states that reach the conclusion the original bargain has broken.
Summary and Assessment
RevCon 2026 will be measured against modest benchmarks. The Vietnamese Presidency has set realistic expectations, and the European Union’s bridge-building approach offers some prospect of procedural recovery. But the political conditions for substantive renewal are absent, as the UNA-UK has already warned. What is at stake, however, is not merely another communiqué. The peaceful use regime is the part of the NPT bargain that has, until 2025, largely worked. Forty-eight states operate civilian nuclear programmes, and several dozen more are planning to. If RevCon 2026 cannot reaffirm the basic protection that safeguarded peaceful facilities enjoy, the financial and political assumptions that underpin the next generation of civilian nuclear expansion will quietly degrade.
The third failure, if it comes, will not announce itself. It will look like a procedural impasse and a closing statement of regret. Its consequences will play out over the next decade in cancelled reactor contracts, withdrawn insurance cover, accelerated proliferation hedging by middle powers, and a steady erosion of the assumption that the NPT confers any meaningful protection on those who choose to remain inside it. The nuclear energy industry, and the states that depend on it, should be paying close attention. The next four weeks in New York will determine whether the Treaty’s third pillar is reaffirmed, renegotiated, or quietly abandoned.
Dr Tahir Mahmood Azad is Executive Director of London Dialogue, an independent UK-based research and policy institute. He can be reached at [email protected]
Tahir Azad
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