New Iran country policy and information note on social media, surveillance and sur place activities

On 15 April 2025, the Home Office published a new version of its country policy and information note (‘CPIN’) on social media, surveillance and sur place activities in Iran. This replaced the previous version of the CPIN published in March 2022. It is a significant update, particularly considering that the Woman, Life, Freedom uprising, prompted by the tragic death of Mahsa (Jina) Amini in September 2022, occurred after the publication of the previous CPIN.

Home Office decision-makers rely on these notes when making asylum decisions. This CPIN, like many others, provides a general assessment of each stage of an asylum claim (Convention reason, risk, protection, internal relocation) based on the country information and caselaw presented. However, decision-makers must “consider all claims on an individual basis, taking into account each case’s specific facts”.

This article will highlight some of the key changes that were made and discuss how they might impact the Home Office’s assessment of certain asylum claims.

Legislative landscape

The introduction of the Chastity and Hijab law has been noted in the new note’s country information on domestic legal framework (at 7.1.11 to 7.1.13). However, despite its seemingly clear significance, it is not mentioned in the CPIN’s general assessment of claims.

According to Amnesty, the Chastity and Hijab law has been approved, but promulgation was temporarily paused in December 2024. As this law advanced rapidly, it may be worth checking on its progress when making relevant representations.

Despite the fact promulgation has been paused, the Chastity and Hijab law is at a developed stage – an indication of the state’s attitude to women and their liberty.

Furthermore, as has been widely reported, Iran’s persecution of women and girls is already severe. The new CPIN’s country information contains some recent examples of human rights abuses perpetrated by the state against women and girls, particularly during the Woman, Life, Freedom movement. Again, this is not clearly reflected in the CPIN’s general assessment of claims.

Practitioners should be alive to the available evidence to support claims that women and girls are at risk of persecution in Iran on the basis of their resistance. Some such evidence is referred to in the country information section of the new CPIN (paragraphs 7.1.11, 8.4.14, 8.6.11, 10.4.1).

Assessment of risk

Throughout the CPIN, there appears to be a sharper focus on the relevance of a person’s social profile when assessing whether dissident activity is likely to be monitored by the state.

At 3.1.2, “the size of audience of their online activity” is added to a list of factors which could be considered when assessing whether a person’s online actions may have brought them to the adverse attention of the authorities.

Amendments made at 3.1.9 (2.4.4 of the previous CPIN) further demonstrate this shift:

2025 version:

Persons who repeatedly post content critical of the government may attract adverse attention, especially if the content goes viral.

2022 version:

Persons posting content critical of the government may attract adverse attention, especially if the content is shared on domestic messaging platforms.

(emphasis added).

This corresponds with updated country information in section 8.4 of the 2025 CPIN. At the same time, the following country information contained within the 2022 CPIN has been removed.

4.4.18 of 2022 version:

“IranWire noted other comments made by cyber security officials:

Prior to Zolghadri’s announcements, on April 14, 2020, Touraj Kazemi, the Head of Tehran’s Cyber Police Force, announced that the force would be monitoring Instagram Live videos and added that any user who used Instagram Live within the country would be monitored…Ramin Pashaei, Deputy for Social Affairs of the Iranian Cyber Police, also said on April 12, 2020, that those who do not wear their hijab when they appear in online videos will be considered to be “violators” of moral standards. Pashaei also said it did not matter whether the individual in question had a popular following on social media or not.

Furthermore, damning statistics about arrests for online activity have been removed.

2.4.5 of 2022 version (emphasis added):

Almost 75,000 people were arrested for online activities between 2010 and 2018, and 3,600 people were arrested between March 2020 and April 2021 for spreading online rumours relating to COVID-19.

3.1.10 of 2025 version (emphasis added):

There is little available data available on the number of arrests made for online activities in recent years, however, according to one NGO, 1,315 people were arrested between January 2011 and the end of August 2023 for content they posted on social media.

Some country information contained within the CPIN itself undermines the finding highlighted in its assessment, for example:

8.4.19 of 2025 version:

A BBC News article, published on 16 September 2024, stated: ‘Women in Iran have told the BBC how their online activity has been spied on by the authorities, leading to arrests, threats and beatings … Iran stepped up surveillance following nationwide women-led anti-establishment protests, after the death … of … Mahsa Amini … The recent wave of protests mainly spread through – and were documented on … [social media] platforms. But as a result of surveillance, tens of thousands of protesters were arrested within the first few months.

Reference to targeting those who spread ‘rumours’ about COVID-19 has been removed from the CPIN entirely, although that may still be relevant to some claims.

Since the collation of country information for the 2025 version concluded on 28 February 2025, there have been reports of new surveillance tactics used to control women. These include the use of drones and app technology to monitor compliance with repressive rules. Such surveillance is not dependent on whether a woman has a large online following or is a protest organiser.

It may be crucial to provide evidence showing the extent of Iran’s surveillance in legal representations, to demonstrate that it is widespread and not wholly limited to high-profile individuals.

Sur place activities

The 2022 CPIN’s assessment stated that the extent to which the Iranian authorities monitored demonstrations against the Iranian government was ‘unclear’. The assessment of sur place activities in the 2025 CPIN is clearer.

3.2.1 of 2025 CPIN:

A person who participates ‘sur place’ in demonstrations which are deemed critical of the Iranian state may be subject to treatment on return to Iran, including harassment, arrest, ill-treatment, torture and criminal charges, that is sufficiently serious, by its nature or repetition, to amount to persecution.

3.3.1 of 2025 CPIN:

A person who is ‘sur place’ openly critical of the Iranian regime online may be subject to treatment on return to Iran, including harassment, arrest, ill-treatment, torture and criminal charges, that is sufficiently serious, by its nature or repetition, to amount to persecution.

The country information contained in section 10.3 of the new CPIN supports these assessments. There is evidence that sur place activities, including conducted from within the UK, are monitored by the state.

The focus on the prominence of an individual’s role in events and activities is continued.

3.2.3 of 2025 CPIN:

A person who participates in demonstrations infrequently, who plays no particular role in demonstrations, and whose participation is not highlighted in the media is not at real risk of identification. Such persons are therefore, in general, unlikely to be subjected to treatment, including harassment, arrest, ill-treatment, torture and criminal charges, that is sufficiently serious, by its nature or repetition, to amount to persecution on return to Iran.

The new CPIN also refers to the Court of Appeal case of S v Secretary of State for the Home Department [2024] EWCA Civ 1482. For example, at 3.3.16 and 3.3.17:

The Court of Appeal found in S that where a person has carried out sur-place activities for reason(s) other than a genuinely held political belief, and where it is unlikely that the person has already come to the attention of the Iranian authorities, the person, on return to Iran, would not be required to volunteer information about their activities in the UK (see paragraph 3.2.7).

The Court of Appeal in S also held that: ‘… [T]here was no reason why the appellant could not close his Facebook accounts prior to the first pinch-point, when he applied for his emergency travel document, nor why he should disclose the existence of them, which would not have previously been known to the authorities, as like his attendance at demonstrations, their apparent contents did not reflect any genuinely held belief by the appellant …’(paragraph 49).

Decisions prior to the publication of the 2025 CPIN have already been referring to this recent case. The case has been relied on by the Home Office when assessing risk arising from sur place activities in Iran and in other countries.

The new CPIN is helpful in suggesting that partaking in sur place activities could put an individual at risk of persecution. Yet, there is a clear emphasis on whether an individual is high-profile or played a key role in activities.

Internal relocation

The assessment of internal relocation has been helpfully updated.

2.6.1 of 2022 version:

Where the person has a well-founded fear of persecution or serious harm from the state, they are unlikely to be able to relocate to escape that risk.

5.1.1 of 2025 version:

Where the person has a well-founded fear of persecution or serious harm from the state, they will not, in general, be able to internally relocate to escape that risk.

Perhaps the Home Office will rely less frequently on internal relocation as a reason for refusal in these claims.

Conclusion

The new CPIN contains some useful updates. For example, it provides evidence of appalling persecution of women, particularly that which occurred during the Woman, Life, Freedom movement. It also suggests that sur place activities can give rise to a well-founded fear of persecution.

However, the new note guides decision-makers to scrutinise an individual’s profile and prominence in opposition. This potentially undermines evidence about the pervasive nature of Iran’s surveillance. The true impact of this shift will be seen in how Home Office decision-makers use the CPIN in decisions. 

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