Ten-Year Review: Non-signatory Iran acknowledges the humanitarian concerns raised by cluster munitions, but has not taken any steps to accede to the convention due to various long-held objections. Iran participated in a meeting of the convention once, in 2011. Iran abstained from voting on a key United Nations (UN) resolution promoting the convention in December 2019.

Iran is not known to have used cluster munitions, but it has imported them and may have also produced them. Iran likely stockpiled cluster munitions, but it has not shared information on the types and quantities in its possession.

Policy

The Islamic Republic of Iran has not acceded to the Convention on Cluster Munitions.

Iran has acknowledged the humanitarian concerns raised by cluster munitions, but has not taken any steps to accede to the convention due to various long-standing objections.[1] In October 2019, Iran repeated its criticism of the process that created the convention for “bypassing the United Nations disarmament machinery” which it said showed “disregard” for the interests and concerns of states that did not participate.[2] In order “to be effective” it has said, a convention to regulate cluster munitions must include “the major producers and former users of these munitions.”[3]

Iran has also objected to certain provisions of the convention, such as Article 21 on joint military operations with states not party.[4]

Iran did not participate in the Oslo Process that created the convention.

Iran attended the convention’s Second Meeting of States Parties in Beirut, Lebanon in September 2011 as an observer.[5] This remains its only participation in a meeting of the convention. Iran was invited to, but did not attend, the Ninth Meeting of States Parties in September 2019.

In December 2019, Iran abstained from the vote on a UN General Assembly (UNGA) resolution, which urges states outside the convention to “join as soon as possible.”[6] Iran has abstained from voting on the annual UNGA resolution since it was first introduced in 2015.[7]

Iran is not party to the Mine Ban Treaty nor the Convention on Conventional Weapons.

Use

Iran is not known to have used cluster munitions.

Cluster munitions were used in Iran during the Iran-Iraq War in 1980–1988.[8] According to one source, during the war Iraq used air-dropped cluster bombs in 1984 against Iranian troops.[9] A United States (US) Navy aircraft used 18 Mk-20 Rockeye bombs in attacks on Iranian Revolutionary Guard speedboats and an Iranian Navy ship on 18 April 1988.[10]

Production

There is evidence that Iran may produce cluster munitions.

Several western media outlets have claimed that Iran’s domestically produced rockets and missiles may include a submunition variant, such as the Zolfaghar short-range ballistic missile.[11] Iran has reportedly displayed “a variant of the Fateh missile with 30 submunitions, each weighing approximately 20 pounds” while “other Iranian missiles known to be equipped with submunitions include the long-range Ghadr and the medium-range Qiam.”[12] Iran produces various types of unguided 122mm, 240mm, and 333mm rockets, but it is not known if these include submunition payloads.[13]

Transfer and stockpiling

Iran has imported cluster munitions and likely has a stockpile, but has never shared information on the types and quantities possessed. Jane’s Information Group lists Iran as possessing KMGU dispensers that deploy submunitions, PROSAB-250 cluster bombs, and United Kingdom (UK)-made BL755 cluster bombs.[14] Additionally, Iran possesses Grad 122mm surface-to-surface rockets.[15]

Policy

The Islamic Republic of Iran has not acceded to the Mine Ban Treaty. It has cited its perceived need for antipersonnel mines on its borders as the main reason for not joining the treaty.[1]

In November 2019, Iran repeated its earlier objections to the Mine Ban Treaty, stating, “the Convention focuses mainly on humanitarian concerns and does not adequately take into account the legitimate military requirements of many countries, in particular those with long land borders, for the responsible unlimited use of mines to defend their territories. Because of the difficulties related to monitoring extensive sensitive areas by established and permanent guard posts and effective warning systems, unfortunately, anti-personnel mines continue to be an effective means for those countries to ensure the minimum security requirements of their borders.”[2]

On 2 May 2017, Iran’s Ministry of Defense commemorated International Mine Awareness Day in Tehran. The meeting was addressed by Iran’s Defense Minister. Iran asked for more international assistance in mine clearance.[3]

Iran has not attended any international meetings on the Mine Ban Treaty in the past decade. Iran’s only attendance was at the intersessional meetings held in May 2001.

Iran is not party to the Convention on Cluster Munitions. It is also not party to the Convention on Conventional Weapons (CCW). However, in April 2016, a representative of Iran told the Monitor that legislation to join the CCW and its Amended Protocols I and V was before the Iranian parliament.[4]

Production, transfer, stockpiling, and use

The Monitor has not reported any new use of antipersonnel landmines by Iranian forces since 1999.

In October 2015, several newspapers published a report that alleged new use of antipersonnel landmines by the Iranian Revolutionary Guards Corps (IRGC) on Iran’s border with northern Iraq. Eyewitnesses reportedly observed the mine-laying operation, and media reports stated that the Kurdish authorities warned inhabitants of the Penjwen area of Sulaymaniyah governorate not to approach the border due to new mine use. The allegation stated that the mines were laid to prevent incursion by Kurdish militants and smugglers.[5] The Monitor has been unable to verify this allegation.

The director of the Islamic Republic of Iran Mine Action Center (IRMAC) told the Monitor in 2005 that Iran neither uses nor produces landmines.[6] In September 2002, the Ministry of Defense declared, “The Islamic Republic of Iran, since the termination of its war [1988], has not produced anti-personnel mines.”[7] The Monitor received information in 2002, 2003, and 2004 that demining organizations in Afghanistan were removing and destroying many hundreds of Iranian YM-I and YM-I-B antipersonnel mines, date-stamped 1999 and 2000, from abandoned Northern Alliance frontlines.[8]

Iran is thought to possess a large stockpile of antipersonnel landmines, but no official information is available on its size and composition.

Iran exported a significant number of antipersonnel mines in the 1990s and earlier. An export moratorium was instituted in 1997, but it is not known if it is still formally in effect. In February 2006, the Ministry of Foreign Affairs stated, “It has been several years since Iran voluntarily halted export of anti-personnel mines.”[9]

There is evidence that Iran has both produced and exported antipersonnel mines in the past decade. Iranian antipersonnel mines have been seized in Afghanistan in 2008,[10] Tajikistan in 2007,[11] and Somalia in 2006.[12] The Monitor addressed a letter to the Ministry of Foreign Affairs on 27 April 2011 to inquire on these matters, but did not receive a response. In October 2014, the Monitor received a copy of an English-language foreign sales brochure of Iran Ammunition Industries Group that included two types of antipersonnel landmines among other weapons.[13] As of August 2020, Iran’s Ministry of Defence Export Center advertises the availability of the YM-IV, a bounding, fragmentation antipersonnel mine, and the YM-I-S, a self-neutralizing antipersonnel blast mine.[14]

In previous years, seven Iranian Kurdish armed groups have pledged not to use antipersonnel mines by signing the Geneva Call Deed of Commitment. These include the Democratic Party of Iranian Kurdistan (PDKI), three factions of the Komala Party, the Kurdistan Democratic Party-Iran (KDP), the Kurdistan Free Life Party (PJAK), and the Kurdistan Freedom Party. The three factions of the Komala Party stated that they had used antipersonnel mines sporadically in the past.[15]

Note: ERW = explosive remnants of war.

Mine Contamination

The Islamic Republic of Iran is contaminated by antipersonnel and antivehicle mines, mainly as a result of the 1980–1988 war with Iraq. Mine contamination is concentrated in five western provinces bordering Iraq, although the extent of the remaining threat is unknown.

Minister of Defense Hossein Dehghan said in 2014 that the 4,500km² of mine and ERW contamination left by the Iran-Iraq war in the five western provinces had been reduced to 280km².[1] In February 2014, the Iran Mine Action Center (IRMAC) reported that the five Western provinces had remaining contamination totaling 250km².[2]

However, two antivehicle mine incidents occurred in early 2014 in the Lut desert spanning central and eastern Iran where police reportedly placed mines as a measure against drug traffickers, pointing to contamination outside the five most affected provinces.[3] Sources report that security forces continue to emplace mines in areas close to Iran’s borders in order to deter cross-border smugglers and infiltration by anti-regime groups. A further complication for contamination estimates are reports of continuing casualties in areas that were supposed to have been cleared.

Cluster Munition Contamination

The extent of cluster munition contamination in Iran is not known. Some contamination is believed to remain from the Iran-Iraq war when cluster munitions were widely used in Khuzestan and to a lesser extent in Kermanshah. Iraqi forces used mostly French- and Russian-made submunitions in attacks on oil facilities at Abadan and Mah-Shahr, and Spanish munitions in attacks on troop positions at Dasht-e-Azadegan. Air Force explosive ordnance disposal (EOD) teams cleared many unexploded submunitions after attacks but contamination remains around Mah-Shahr and the port of Bandar Imam Khomeini, according to a retired Iranian Air Force colonel.[4]

Program Management

IRMAC was established as the national mine action center in 2005 and made responsible for planning, data managing, survey, procurement, and the accreditation of demining operators. IRMAC’s director is General Mohammad Hussein Amir Ahmadi and many staff are believed to be serving or former military personnel.

IRMAC issues clearance contracts to private companies, army engineers, and the Iranian Revolutionary Guard Corps. It also coordinates mine action with the General Staff of the Armed Forces, the Ministry of Interior, the Management and Planning Organization of Iran, and other relevant ministries and organizations, and handles international relations.[5]

Information management

IRMAC maintains a mine action database but it is not known if it is comprehensive, actively maintained, and up to date.

The National Iranian Oil Company (NIOC) also maintains a mine action database recording the results of its own clearance contracts.[6]

Operators

Mine clearance in Iran is mainly conducted by the Iranian Army and Iranian Revolutionary Guard Corps.

IRMAC combines the roles of regulator and operator, with demining teams and support staff employing around 250 personnel deployed in five affected provinces.[7]

Commercial operators include AOM Co., Immen Sazan Omran Pars International Co., Immen Zamin Espadana, and Solh Afarinan-e Bedoun-e Marz (SABMco). Two other companies, Moshaver Omran Iranand ZPP International Co., undertake quality assurance (QA)/quality control (QC).[8]

Petroleum Engineering and Development Company (PEDEC), the development arm of the NIOC, contracts and supervises commercial operators conducting clearance of Iran’s oil and gas producing areas, which are concentrated in mine-affected areas of south western Iran bordering Iraq.[9]

International operators are not believed to have been active in Iran since 2008.

Land Release

Iran has not published details of mine or cluster munition survey or clearance in recent years. In 2017, President Hassan Rouhani observed that countries that had supplied Iraq with mines during the Iran-Iraq war had not provided Iran with the technology to clear them.[10]

The Monitor acknowledges the contributions of the Mine Action Review (www.mineactionreview.org), which has conducted the primary mine action research in 2018 and shared all its country-level landmine reports (from“Clearing the Mines 2018”) and country-level cluster munition reports (from “Clearing Cluster Munition Remnants 2018”) with the Monitor. The Monitor is responsible for the findings presented online and in its print publications.

Casualties in 2017—details

Monitor data for the Islamic Republic of Iran for 2017 was compiled from media scanning and other sources, including the Geneva International Centre for Humanitarian Demining (GICHD)- Stockholm International Peace Research Institute (SIPRI) antivehicle mine database. As in in past years, it may not capture the full extent of casualties occurring during the year.

The Monitor identified a total of 9,925 casualties (2,823 killed; 7,095 injured; five unknown) from landmines and ERW in Iran between 1988 and 2017, based on updates to casualty information for previous years. As of 2006, the United Nations (UN) had reported that there had been approximately 10,000 casualties in Iran.[2] 

The Islamic Republic of Iran has a significant number of landmine and explosive remnants of war (ERW) survivors who are in need of assistance.

Casualties

Casualties Overview

In 2014, the Monitor identified 77 casualties from landmines and ERW in Iran.[1] Landmine casualties occurred in the five western border provinces of West Azarbaijan, Kurdistan, Kermanshah, Ilam, and Khuzestan, and also in South Khorassan[2] and Kerman[3] provinces. Incidents caused by unknown explosive devices killed two civilians and another injured five in Sistan and Baluchestan[4] and East Azarbaijan[5] provinces. ERW casualties occurred in all five western border provinces and also in Mazandaran.[6]

Men constituted the vast majority of casualties for whom sex and age were known (53 of 64, or 83%).[7] There were five casualties among women. The sex of 11 civilian casualties remain unknown. At least seven casualties were children, including six boys and one child of unknown sex. This constitutes 18% of the 40 civilian casualties for whom the age was known, which shows a decrease in comparison with 2013. The age of 12 civilian casualties remains unknown.

In 2014, 68% of all known casualties were civilians (52: 14 killed, 38 injured), a larger share of total casualties compared to known civilian casualties in 2013 (60, 56%).The 77 casualties identified in 2014 is a decrease compared to the 107 identified for 2013 and is the lowest number of recorded casualties since 1988, the first year for which data is available.[8] The highest number of recorded annual civilian casualties, 918, was recorded in 1995 and civilian casualties has decreased steadily since then.

There were 17 deminer casualties (one killed, 16 injured) recorded in 2014. This is by far the lowest number of deminer casualties recorded since 2006, the first year for which comprehensive deminer casualty data is available,[9] and constitutes a decrease compared to 28 deminer casualties in 2013. Since 2006, the high number of deminer casualties reported has partially offset the decrease in civilian casualties to maintain a high rate of annual casualties in Iran. The number of casualties among deminers surpassed civilian casualties in both 2011 and 2012. Casualties reported among deminers reached a peak in 2009, with 169 casualties recorded.

In 2014 there were eight casualties among security forces (two killed, six injured), which constitutes a decrease compared to 19 known military casualties in 2013.

Monitor data for 2014 was compiled from media scanning and other sources and therefore may not capture the full extent of casualties occurring during the year.

The Monitor identified a total of 9,764 casualties (2,768 killed; 6,995 injured; one unknown) from landmines and ERW in Iran between 1988 and 2014, based on the data gathered in 2015 that updated casualty information for previous years.[10] As of 2006, the UN had reported that there had been approximately 10,000 casualties in Iran.[11] No data is available on casualties among security forces in years prior to 2008.

Mine/ERW casualties recorded in Iran, by civilian status*

* Note: status is unknown for one casualty.

Victim Assistance

Between 1988 and the end of 2014, there were 6,995 people injured by landmines and ERW in Iran, the vast majority of which (more than 80%) are civilians (5,691).

Victim assistance since 1999

Since 1999, comprehensive victim assistance has been available for military casualties. The same assistance became available to deminers beginning in 2010. Civilians who were recognized as war victims could also access some services through government agencies, although psychological support and economic inclusion programs were extremely limited. However, many civilians and deminers who were not recognized as war victims received minimal assistance that was insufficient to meet their needs. Few services were available in the remote regions where many survivors are based.

There is no comprehensive plan or central coordinating body in charge of assistance to all victims of landmines. The result is that the assistance that victims have received varies widely in accordance with the victim status they are assigned and with the legal framework that happens to govern their cases.

Military survivors and their families, whether they had their mine incident while demining or in another context, receive support through their respective military units.[12]

In 2006, the Iranian Mine Action Center (IRMAC) began providing life and disability insurance coverage for deminers working for private subcontractors, although not the more complete coverage deminers were granted in 2010.[13]

Civilian mine/ERW victims who were recognized as martyrs or disabled “veterans”[14] were entitled to comprehensive assistance provided by Foundation of Martyrs and Veterans Affairs (FMVA). Other civilian mine/ERW victims who were not recognized as such were only entitled to negligible allowances accorded by Imam Khomeini Relief Foundation (IKRF) or the State Welfare Organization (SWO).[15]

For 17 years (1993–2010), the law and regulation governing the eligibility of civilian mine/ERW victims[16] as martyrs or disabled veterans expressly excluded the victims who were known to be “morally corrupt” or “counter-revolutionary” as well as those who had “recklessly,” or “intentionally,” caused the incident.[17] Provincial commissions (referred to as “Article 2 Commissions”) in the five war-affected provinces determined the eligibility of individual victims and were criticized for excluding many individuals from the benefits that the law assigned to survivors and families.[18] Victims could appeal to the Court of Administrative Justice against the decisions of the Article 2 Commissions. In several cases, the court overturned those decisions,[19] emphasizing the authorities’ failure in fulfilling their duty of clearing the area where the incident had occurred, and lack of evidence upholding the claim that the appellant had caused the incident intentionally or recklessly. In such cases, the court ordered the respondent governorate to recognize the status of the victim as a veteran or martyr.

Following protests by the victims and civil activists and at the initiative of a number of members of parliament from the affected provinces, both the 1993 law establishing the process for registering as a mine/ERW victim and its 1994 regulation were amended in August 2010.[20] References to “moral corruption” and “recklessness” were removed and other changes were made in order to make the procedure more accessible to victims.[21] The amendment was retroactive, enabling all past victims, including those who were excluded by the decision of previous commissions for “recklessness” or “corruption,” to submit their case under the new law. Despite these favorable legislative amendments, through 2014 bureaucratic hurdles continued to prevent many victims from successfully registering for assistance.

Under August 2010 legislative amendment the FMVA must register deminer casualties of mines/ ERW as martyrs or disabled veterans (for those killed or survivors, respectively) and provide for the medical care for survivors.[22] In 2013, FMVA reportedly readapted its policy in order to accept applications from deminer survivors and the families of deminers killed in incidents prior to August 2010.[23]

City governorates convene the Article 2 Commission to decide on victims’ cases on an ad hoc basis, once they consider there to be a sufficient number of cases. In some small cities with survivors the commission had not been convened. In some cases very long delays in administrative proceedings were reported (in one case almost two decades),[24] during which time no financial assistance was available. Costs were not reimbursed retroactively even if survivors were found to be eligible.[25] In response, in 2013, IRMAC dedicated resources to cover the costs of deminer survivors and the families of those killed while the proceedings of registration for FMVA assistance are pending.[26] However, no equivalent assistance was available for civilian victims.

Civilian victims often lacked the financial resources to pay for emergency medical care, rehabilitation and other services, as well as insurance coverage.[27]

Some survivors injured in border areas and treated in neighboring Iraq were unable to receive assistance because their medical documentation was not issued in Iran,[28] and/or their movements in the border area were judged to be unlawful.[29]

Victim assistance in 2014

Through 2014, bureaucratic barriers continued to prevent many mine/ERW survivors and family members of those killed from registering for assistance. The FMVA, the organ that would provide services to survivors and victims’ families in case of favorable decision of the Article 2 Commission, is itself in charge of filing applications and transmitting them to city governorates. Reportedly, in certain cases, FMVA blocks the registration of applications by requiring documents that victims cannot provide.[30] Support for child victims was minimal as the FMVA did not provide allowances to minors who are supported by their parents or legal guardians.[31] Families of child survivors often struggle to provide for their needs, as they often live in remote areas and in poor economic conditions.

Assessing victim assistance needs

IRMAC, with partial sponsorship from ICRC, launched a pilot project in 2013 to identify civilian mine/ERW survivors with the greatest needs for physical rehabilitation. This also strengthened IRMAC’s data collection capacities.[32] Following the identification phase, in 2014 the ICRC signed an agreement with the Iranian Red Crescent Society (IRCS) to provide its physical rehabilitation services. Subsequently, the IRMAC referred victims to the IRCS. Out of 100 referrals, 41 were eligible and received physical rehabilitation services through the IRCS, with costs covered by the ICRC. In 2015 the ICRC and the IRCS were exploring the possibility to continue the joint project.[33]

Janbazan Medical and Engineering Research Center (JMERC) collected data for the second phase of an epidemiological study of trauma caused by landmine accidents as an update to a 2006 study on survivors who applied to the FMVA between 1988 and 2003 (3,713 people).[34] The new study, covering the period from 2003 to 2013, was not yet published as of October 2015.

In 2015 JMERC published two studies on child casualties.[35]

In June 2011, IRMAC reported working to develop a single, comprehensive database of mine/ERW casualties, compiling information available from a variety of national ministries and foundations, such as the Ministry of Interior, FMVA, and the IKRF, as well as from local authorities and NGOs working in mine-affected provinces.[36] No further update on the database was available through October 2015. The Comprehensive Law on Provision of Services to War Veterans, adopted in December 2012, required the FMVA to develop a comprehensive database on the state of health of the persons under its coverage.[37]

Victim assistance coordination

The Ministry of Interior is responsible for coordinating and monitoring victim assistance for all civilian survivors and the families of those killed. Survivors or their family members must report the mine incident to the FMVA office in their district to register and to have their case submitted to the local commissions as detailed above. If the Article 2 Commission grants martyr or disabled-veteran status to the victim, they are referred to the FMVA for assistance. Victims whose applications are rejected by the local commission are referred to SWO in urban areas and to the IKRF in rural areas.[38]

The Department of Martyrs and Veterans within IRMAC is responsible for the coordination of assistance to deminers that are injured or killed as a result of a demining accident. The Ministry of Defense monitors the provision of victim assistance to deminers.[39]

Inclusion and participation in victim assistance

The War Veterans’ Parliamentary Group, with 130 members, is one of the largest groups within the Iranian parliament.[40] The parliamentary group worked to ensure the allocation of sufficient resources for provision of services to veterans in annual budget laws.[41] In 2013, a Commission of Enquiry into the activities of FMVA was established at the initiative of the War Veterans’ Parliamentary Group in reaction to serious claims of corruption. The results of the Commission of Enquiry were pending as of August 2015.[42]

The Center for Blind Veterans’ Affairs “Khaneye Noor-e-Iran” provides a platform for those veterans who have lost their vision—some of whom landmine survivors—to have a voice in the process of the adoption of rules and standards governing provision of services to them. The center also aims at full accessibility in urban planning to ensure that the needs of the blind are taken into consideration.[43] Other groups of disabled veterans that include mine victims, such as double-limb amputees,[44] have also formed associations and social networks at the initiative of FMVA. The “Association of Upstanding Veterans” representing double-limb amputees advocates for improvement of access to and quality of physical rehabilitation services.[45]

No information was available on any independent, non-governmental, active NGO, association or network representing landmine and ERW survivors not registered with FMVA.

Service accessibility and effectiveness

Victim assistance activities

Laws and Policy

In December 2012, the Expediency Council enacted the Comprehensive Law on Provision of Services to War Veterans.[46] The legislation stipulates all the services and benefits to be provided to disabled veterans and families of martyrs.[47] Mine victims and their families would be eligible for those services if successful in applying for the required status.[48] However, shortage in financial resources has since hindered the full implementation of this law. On 25 December 2013 the vice-president of legal affairs addressed a directive to all ministries, governmental and non-governmental public institutions in which she noted that the law had entered into force, but its implementation required the adoption of executive regulations, which would be postponed until the relevant regulations were adopted and the necessary resources were allocated in the national budget.[49] In an interview published on 5 August 2014, the director general of the legal department of FMVA stated that the department had drafted and communicated to the government 17 regulations relative to the implementation of the Law and 13 more were pending drafting.[50]

Services listed in the 2012 Comprehensive Law on Provision of Services to War Veterans include: adequate housing; complete coverage of healthcare expenses; and the provision of all necessary medical services, including physical and psychological rehabilitation by FMVA. The law establishes 25% employment quotas in the public sector for eligible persons as well as tax and compensation benefits for private enterprises that hire them. The law also foresees the provision of legal aid for covered persons by the Ministry of Justice whenever necessary. The law requires the FMVA to cover school fees for eligible persons and their children who study in private higher education institutions and establishes quotas in public universities.

In 2013, the FMVA attempted to address physical barriers to access services for beneficiaries with disabilities, including registered landmine survivors, by paying the transportation fees for those living outside major cities or by sending medical teams to conduct outreach visits.[51] Despite these efforts, disparities in access to services remained even among those who are entitled to receive services from FMVA, based on their physical distance from services.[52]

In contrast to the comprehensive assistance system for veterans, mine survivors not granted the status of disabled veterans are not eligible for any assistance beyond minimal allowances available through SWO or IKRF. Despite high inflation these allowances remained unchanged in the decade between 2004 and 2013. As a result, survivors relying on allowances were reported to be living in extreme poverty.[53]

Discrimination against persons with disabilities is prohibited by law in Iran. The Comprehensive Law on the Protection of Rights of Persons with Disabilities[54] requires the government to set out and implement standards of public accessibility in public spaces and government buildings (Article 2) so that all new buildings and spaces are constructed in accordance with them. The regulation on the implementation of this provision[55] requires the progressive adaptation of all existing government buildings to make them accessible to persons with disabilities (Article 3). A National Coordination Committee for Accessibility was created and held its first meeting in September 2014.[56] In 2014, newly-built government-funded buildings were seen to comply with the standards laid out in Article 2. There were also efforts made to increase access to historical sites for persons with disabilities. However, non-government buildings or government buildings predating the accessibility standards remained inaccessible, for the most part.[57]

Iran ratified the Convention on the Rights of Persons with Disabilities (CRPD) on 23 October 2009. The Iranian parliament designated the Ministry of Welfare and Social Security (State Welfare Organization) and the FMVA as focal points for matters relating to the implementation of the convention.[58] In June 2015, the government adopted the Comprehensive Plan for Protection of Rights of Persons with Disabilities, parts of which will be included in a draft law that will be communicated to the parliament for adoption. The Plan provides for the constitution of a Coordination Council composed of relevant government authorities, as well as five representatives of persons with disabilities elected by networks of NGOs.[59]