Iran’s parliamentary National Security and Foreign Policy Commission approved Articles 13, 14 and 15 of the proposed “Strategic Action to Ensure Security and Development of the Strait of Hormuz” bill on Tuesday, 22 September 2026. Commission spokesman Hassan Qashqavi, also rendered Ghashghavi in Iranian state media, said the panel had signed off on penalties for vessels that pass the strait outside the regulations set by the draft law. Iran International, Press TV and IRNA carried the readout the same day. The bill is not law. Committee text still has to clear the full Majlis and the Guardian Council, which Iranian outlets also call the Constitutional Council.
Article 13 is the provision that matters first for owners. Qashqavi said a vessel that transits outside the proposed rules would face penalties under Iran’s Islamic Penal Code and the seizure of 20 percent of its cargo, or an equivalent amount based on the cargo’s value. The ship could be detained until the penalty is paid. Press TV’s account said the cargo measure sits alongside Article 5 of the Penal Code and that Iranian maritime forces would temporarily impound the offending ship. That is a cargo-and-hull hold, not a published tariff and not a fine that can be settled from the office. A laden VLCC, a products tanker or a bulk carrier stopped on that basis would be a commercial total-loss risk even if the crew were unharmed.
The same article package would require Iran’s judiciary to stand up specialised court branches staffed by judges and experts in maritime law and the international law of the sea. Qashqavi presented those benches as the forum for cases arising from the legislation. Operators should read that as a domestic Iranian process, not as an IMO tribunal and not as an arbitration clause they have agreed. There is no published appeal route, no named registry and no indication that a foreign P&I club or flag state would have standing in those branches.
Article 14 is aimed at people and companies inside the Iranian system as much as at foreign ships. It would impose Grade 5 criminal penalties, under Article 19 of the Islamic Penal Code, on individuals or legal entities whose acts or omissions prevent the law from being implemented fully or on time, unless a heavier punishment applies. A note attached to the article says any future bilateral or multilateral agreement or binding document on the Strait of Hormuz must comply with Articles 77, 125, 176 and 57 of Iran’s constitution. Press TV described that note as an assertion of legal sovereignty over the strait and as a bar on external navigation frameworks that lack Tehran’s constitutional consent. For operators, the practical reading is narrower: even if Oman, the GCC or mediators later table a route or fee arrangement, this draft would try to keep the last word in Tehran.
Article 15 would put implementation oversight with the Armed Forces General Staff, reporting every three months to the National Security and Foreign Policy Commission, either directly or through the Ministry of Defence. That is a military reporting line, not a civilian port-state inspectorate. Combined with Article 13’s detention power, it would place the day-to-day hold on a ship closer to the forces already running wartime traffic controls than to a customs desk.
The three articles sit on earlier committee work. Last month the same commission approved language that would let Tehran charge authorised vessels for navigation, environmental, insurance and security services, and in special cases for refuelling, with fees collected in rials or another currency Iran designates. Iran has described those payments as service charges. The International Maritime Organization has opposed mandatory tolls for passage through straits used for international navigation, saying there is no legal basis to charge simply for transit. IMO Secretary-General Arsenio Dominguez has also said Iran is a party to SOLAS, that the 1968 Hormuz traffic-separation scheme already exists, and that introducing a toll would set a dangerous precedent. International law does allow charges for specific services actually provided to a ship. That distinction is the ground Tehran has tried to occupy. Oman has floated a regional arrangement under which companies could make voluntary contributions for navigation, environmental protection and search and rescue. Tehran has resisted formulas that would limit its oversight of inbound and outbound traffic.
Earlier drafts discussed by lawmakers also included restrictions on vessels linked to the United States, Israel and other states Tehran treats as hostile, and requirements that ships obtain Iranian authorisation or coordinate movements with Iranian authorities. Those ideas are background to Articles 13–15. They are not, on Tuesday’s readout, the text that was approved. The Persian Gulf Strait Authority’s Non-Compliance List, which stood at 77 vessels on 14 September, is a separate wartime product already in force as an Iranian administrative list. The new bill would try to turn wartime practice into a standing statute. It does not, by itself, add names to that list.
Nothing in Tuesday’s vote reopens the strait or creates a lawful sailing window. Hormuz remains a conflict waterway: AIS-visible commodity traffic is still a fraction of the pre-war ~125 ships a day, the US blockade of Iranian ports is still being enforced, and commercial ships are still being hit. A committee-approved penalty clause does not replace UKMTO warnings, NAVAREA IX or the existing PGSA process. It also does not authorise owners to pay a 20 percent cargo levy as if that were a published due. Until the full Majlis and the Guardian Council act, the articles are a legislative signal of where Tehran wants the law to go, not a rule that a master can apply on the bridge.
What Operators Should Note
- This is committee text, not an in-force statute. Articles 13, 14 and 15 were approved on Tuesday, 22 September, by the National Security and Foreign Policy Commission. Qashqavi’s readout, carried by Iran International, Press TV and IRNA, is not a Majlis statute and not a Guardian Council confirmation. Do not rewrite SMS, charter recap or crew briefings as if a 20 percent cargo seizure law is already in effect.
- Article 13 is a cargo-and-hull hold, not a tariff. The draft would allow seizure of 20 percent of cargo or its value, Penal Code penalties, and temporary detention until payment. There is no published rate card, no designated receiving account that operators should use, and no IMO circular behind it. Treat any demand framed as this article as a detention risk and a possible scam vector until flag, P&I and owners have seen the instrument.
- Specialised Iranian maritime courts would be a domestic forum. The judiciary would be told to create branches with maritime and law-of-the-sea expertise. That is not an agreed dispute clause. Flag states and clubs should assume they will not have automatic standing and should preserve evidence, protests and class records if a ship is held.
- Article 14 tries to lock future route deals to Iran’s constitution. Grade 5 penalties for obstructing implementation sit next to a note that future Hormuz agreements must comply with constitutional Articles 77, 125, 176 and 57. A later Oman or GCC briefing should not be treated as a substitute for Iranian consent under this draft.
- Do not confuse the bill with the PGSA list or with a transit toll already collected. The 77-vessel Non-Compliance List of 14 September remains the wartime administrative product. Last month’s committee fee language and IMO opposition to mandatory strait tolls are unchanged. Charges for services actually rendered are the only fee category the IMO has left open; a 20 percent cargo grab is not that category.
- Passage planning does not change on this vote. Keep using UKMTO, NCAGS, NAVAREA IX and the existing PGSA/authorisation process. Do not pay an unsolicited “Article 13” invoice. Do not assume a US redirection or a mediator proposal overrides Iranian detention risk if the bill later becomes law.
- Watch the next two gates, not social-media summaries. The live questions are whether the commission finalises the rest of the bill, whether the full Majlis votes, and whether the Guardian Council approves. Until those steps happen, the operational file is still the wartime control system already in place, not a new statutory levy.
Regulas Shipping will keep following the Hormuz bill through the full Majlis and the Guardian Council and will report if the 20 percent cargo measure moves from committee text to law.
