The 109-page submission is the result of months of intensive investigation by dedicated HRA teams. It draws on more than 60 interviews with victims, witnesses, and family members inside Iran, in Turkey, and across Europe and North America, together with extensive documentary and digital evidence. HRA also conducted a detailed analysis of weapons used, injury analysis, suspected perpetrators, relevant institutions, and the command structures allegedly involved in the crackdown.

The submission also identifies suspected perpetrators, mapping their roles, institutional affiliations, connections to documented incidents, and positions within the command structures that HRA alleges were responsible for the crackdown.

The filing presents selected incidents that HRA argues indicate that crimes against humanity were committed in Iran between December 2025 and January 2026. It also addresses specific suspected perpetrators and sets out HRA’s analysis of what it describes as a widespread or systematic attack against the civilian population, a contextual element required for crimes against humanity.

Why Germany

HRA recognizes that calls for German prosecutors to investigate international crimes committed in Iran have been made before. This submission builds on those efforts with substantial new evidence concerning the December 2025–January 2026 crackdown and a detailed legal and factual case for why Germany is particularly well placed to act now.

Germany is not removed from the consequences of repression in Iran. It is home to a significant Iranian diaspora, including victims, witnesses, human rights defenders, journalists, and others who have fled persecution. The effects of repression can extend beyond Iran’s borders, as Iranian authorities seek to intimidate, threaten, or otherwise exert pressure on critics and diaspora communities abroad.

The complaint specifically sets out connections between the documented crimes and Germany and the wider European Union, including witnesses and injured persons with whom HRA is in contact.

The filing asks the Federal Prosecutor General to assess both the opening of a structural investigation and the potential initiation of proceedings against individual suspects. A structural investigation does not depend on having a particular suspect immediately available for prosecution. It can enable German authorities to systematically collect, preserve, and analyze evidence concerning alleged international crimes, identify responsible structures and individuals, and prepare for future individual proceedings when jurisdictional opportunities arise.

The filing therefore asks the Federal Prosecutor General to assess both the opening of a structural investigation and the potential initiation of proceedings against individual suspects. German counsel states that the Federal Prosecutor General has jurisdiction under the VStGB in conjunction with the relevant provisions of Germany’s Courts Constitution Act.

A structural investigation does not depend on having a particular suspect immediately available for prosecution. It can enable German authorities to systematically collect, preserve, and analyze evidence concerning alleged international crimes, identify responsible structures and individuals, and prepare for future individual proceedings when jurisdictional opportunities arise.

Germany’s experience demonstrates the practical importance of this approach. Structural investigations into crimes committed in Syria laid important groundwork for subsequent German cases against individual perpetrators ongoing today. Similar investigative mechanisms have also been used in relation to international crimes committed in Ukraine. For Iran, opening such an investigation now would provide a mechanism for preserving evidence, engaging witnesses who are already in Europe, and building cases that can be acted upon should suspected perpetrators come within reach of German authorities.

For victims and witnesses, the significance is equally concrete: evidence gathered today may determine whether accountability becomes possible tomorrow.

Building on Months of Investigation

What HRA is making public today is a heavily redacted, illustrative overview of its findings, intended to provide an accessible account of the evidence and analysis contained in the criminal complaint while protecting witnesses, investigative methods, and other sensitive information.

HRA would like to acknowledge that this work would not have been possible without the extraordinary courage and trust of the victims, witnesses, family members, and experts—including those inside Iran—who shared their experiences, evidence, and expertise with HRA over the past six months.

Their testimony and cooperation form the foundation of this effort to preserve evidence, identify those who may bear responsibility, and pursue accountability through available international and domestic legal mechanisms.

For media inquiries on the action taken, please contact Jennifer Connet, HRA Legal Advisor, at jennifer @ hramail.com