If your business touches Iran’s energy, shipping, insurance, banking or metals sectors, the Iran (Sanctions) (Amendment) Regulations 2026 tighten the rules you must follow from 29th September 2026 under the law of England and Wales. The Regulations add nine new schedules covering trade in oil, gas, petrochemicals, gold, metals, and maritime goods; restrict access to the UK financial system; bar most Iranian aircraft from landing here; and introduce a specified-ships licensing regime. You can fall within these prohibitions even without a direct link to Iran’s nuclear programme, so review your counterparties and transaction chains before that date.
Summary
- You must screen counterparties across the energy, shipping, insurance, banking, and metals sectors before 29th September 2026, when the new Regulations take effect.
- Nine new schedules extend UK export controls to oil, gas, petrochemicals, gold, precious metals, graphite, and maritime goods, including third-country trade.
- Financial institutions face restrictions on financial services and brokering connected to Iran, covering indirect and third-country dealings rather than direct transactions alone.
- Most Iranian aircraft are barred from landing in the UK from 29th September 2026, alongside a new specified-ships licensing regime.
- Existing relationships with designated parties receive no automatic protection, so you should commission a case-by-case legal review now.
Your compliance team has until 29th September 2026 to work through counterparties across Iran’s energy, shipping, insurance, banking, and metals sectors before the Iran (Sanctions) (Amendment) Regulations 2026 take effect. The challenge facing you is scope. The Regulations reach third-country trade, brokering, insurance and ancillary financial services, so a transaction chain with no direct link to Iran’s nuclear programme can still fall within the new prohibitions. If your organisation sits several removes from any Iranian counterparty but trades in oil, gas, metals, gold, or shipping services, you carry the same exposure as a business dealing with Iran directly. Here we explain what changes under the new Regulations, how the financial and aircraft restrictions work, and what you should check in your own arrangements before the deadline.
What do the new regulations change for you?
The Iran (Sanctions) (Amendment) Regulations 2026 add nine new schedules, Schedules 1A to 1I, to the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019, and these take effect on 29th September 2026. You now face expanded prohibitions on energy-related goods and technology, gold, precious metals and diamonds, graphite and relevant metals, maritime goods and technology, natural gas, oil and petroleum products, petrochemicals, and sectoral software.
The Department for Business and Trade’s Notice to Exporters 2026/18 confirms these sector prohibitions and extends them to third-country trade, technology transfers, and ancillary services such as insurance, brokering, and financial services. If your organisation sits several removes from a direct export to Iran, you remain within scope wherever these ancillary or third-country dealings are present.
How is access to the UK financial system restricted?
The written ministerial statement laid on 8th September 2026 confirms that the new financial measures are designed to reduce the Government of Iran’s ability to access the UK financial system and to raise funds for its nuclear programme. You must now assess exposure beyond your immediate counterparty on any transaction because the Regulations prohibit financial services and brokering that involve indirect or third-country activity.
If your institution provides financial services connected to Iran through an intermediary jurisdiction, you fall within these prohibitions even where you have no direct Iranian counterparty on the transaction.
Can Iranian aircraft still land in the UK?
Most Iranian aircraft will be barred from landing in the UK from 29th September 2026, subject to a specific exemption where one applies. This measure reinforces existing designations and follows the 2024 termination of bilateral air services arrangements with Iran. It operates alongside expanded ship sanctions powers targeting vessels that enable Iran’s nuclear programme or other destabilising activity.
What does the new ships licensing framework require?
The Regulations insert a specified-ships regime into the Iran (Sanctions) Regulations 2023, prohibiting you from chartering or operating a specified ship and setting rules on UK ship registration, ship specification, and a dedicated ships licences regime with associated licensing offences. If you provide technical assistance or services connected to a specified ship, even indirectly, you fall within the scope of these prohibitions.
If you hold shipping, chartering or marine insurance interests connected to Iran, you should review your arrangements against this framework before 29th September 2026.
What should you do about existing relationships?
You should assess each existing relationship with a designated party on its own facts since pre-existing arrangements receive no automatic protection once the new measures take effect on 29th September 2026. We are currently reviewing how the new Regulations affect ongoing transactions and relationships involving already-designated parties, particularly where those relationships pre-date the new measures.
You do not have to work through this alone. Our sanctions law team can review your specific transactions and supply chains and tell you, within a defined timeframe, whether your existing arrangements need to change before the deadline.
Frequently asked questions
When do the new Iran sanctions rules take effect?
The Iran (Sanctions) (Amendment) Regulations 2026 were laid on 8th September 2026 and enter into force on 29th September 2026. If you have exposure to Iran’s energy, shipping, metals or financial sectors, complete your counterparty and transaction risk review before that date.
Do the new rules apply only to Iran’s nuclear programme?
No. The prohibitions apply across energy, software, metals, gold, shipping, insurance and banking, not just nuclear-related activity. You remain within scope of the Regulations wherever you operate in these designated sectors, even without any connection to Iran’s nuclear programme.
What should you do about an existing relationship with a designated party?
You should promptly review any existing relationship with a designated party, as pre-existing arrangements receive no automatic protection once the new measures take effect. Commission a case-by-case legal assessment given the breadth of the new prohibitions and the risk of collateral exposure to your organisation.
Getting legal advice
If you have concerns about how these changes affect your organisation, its transactions, or its counterparties, we would welcome the opportunity to help. Our sanctions law team can review your existing arrangements and advise on your position under the new Regulations.
Author: Freya Zaiwalla SRA number 413383
Freya is a qualified solicitor admitted to the Roll in 2009. She trained at Shadbolt & Co, a specialist construction firm which later merged with Clyde & Co, before spending six months on secondment at AKO Law in Dar es Salaam, gaining early exposure to international and cross-border commercial work. On qualification, she joined Zaiwalla & Co, where she worked on several high-profile matters including the landmark Bank Mellat v HM Treasury sanctions case, which reached the Supreme Court and featured twice in The Lawyer’s annual list of the Top Cases in the UK Courts, sanctions challenges in the Courts of the EU and South Korea, and a multi-million-dollar High Court trade mark dispute against Red Bull.
Freya holds a BA from the University of Manchester and completed her legal training at BPP Law School.
Last reviewed: September 2026
