The Last Five Eyes Exception

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The United Kingdom’s decision this week to proscribe Iran’s Islamic Revolutionary Guard Corps (IRGC)1 marks more than another awakening to the malfeasance of Tehran.

It leaves New Zealand as the only member of the Five Eyes intelligence partnership yet to designate the organisation.

The United States designated the IRGC as a Foreign Terrorist Organization in 2019. Canada followed in 2024. Australia designated the organisation in 2025 after investigations concluded that the IRGC had directed attacks against Jewish targets on Australian soil. Now the United Kingdom has acted, citing an escalating campaign of Iranian-linked threats, intimidation and violence directed at Jewish communities, dissidents and journalists.

New Zealand is now, once again, a clear outlier.

That does not mean Wellington is wrong. Different countries apply different statutory tests, and no government is obliged to mirror another nation’s terrorism designations.

But it does shift the burden of explanation.

The Government’s position has itself evolved.

In 2024, responding to a public petition, Ministers stated that New Zealand was not considering designating the IRGC. By June 2026, Deputy Prime Minister David Seymour confirmed that the Government was actively considering doing so.2 His explanation for the continued hesitation was not a lack of evidence, but diplomacy: New Zealand continues to maintain diplomatic relations with Tehran, including the presence of an Iranian ambassador in Wellington and a New Zealand embassy in the Iranian capital.

That is a legitimate consideration.

Designation under the Terrorism Suppression Act is not just a symbolic act. It carries significant legal consequences and should be based on evidence and statutory criteria rather than political pressure.

Yet the Government’s explanation has become considerably harder to sustain.

For years, the United Kingdom advanced essentially the same argument. British governments resisted proscribing the IRGC because they wished to preserve diplomatic channels with Tehran. Ministers argued that maintaining dialogue remained important even while condemning Iranian behaviour abroad.

This week, they changed course.

Following repeated Iranian-linked assassination plots, intimidation campaigns and attacks targeting people within the United Kingdom, London concluded that preserving diplomatic access no longer outweighed the security threat posed by the IRGC.

New Zealand is therefore relying on precisely the argument that one of its closest allies has just abandoned.

The question is not whether the Government accepts the nature of the threat.

Successive New Zealand governments have repeatedly joined international statements condemning Iranian intimidation campaigns against dissidents, journalists and Jewish communities. They have criticised Tehran’s support for armed proxy organisations and its destabilising activities throughout the Middle East.

Nor is the issue simply one of distant geopolitics.

New Zealand’s own intelligence service has publicly identified Iran as a source of hostile state activity within this country. Both the 2023 and 2025 New Zealand’s Security Threat Environment reports identify Iranian intelligence activity, foreign interference, surveillance and intimidation directed at diaspora communities in New Zealand.3,4 

Unlike the United Kingdom and Australia, New Zealand has not experienced a publicly attributed IRGC-directed terrorist attack on its own soil. But New Zealand’s intelligence service has already concluded that Iranian state activity presents a domestic security concern.

Taken together, these positions are significant.

The Government accepts that Iran engages in destabilising activity abroad. New Zealand’s own security agencies have identified Iranian hostile activity at home. Wellington has repeatedly aligned itself diplomatically with partners confronting those threats.

The remaining question is therefore not the nature of the threat.

It is why New Zealand believes those accepted facts do not yet satisfy the statutory threshold for designation.

That is where the Five Eyes comparison becomes important.

For many years, critics of designation could argue that the United States had adopted an unusually expansive approach to counter-terrorism.

That argument no longer reflects reality.

Today, every other member of the Five Eyes intelligence partnership has concluded that the IRGC warrants designation under its domestic legal framework.

New Zealand alone has reached a different conclusion.

Governments are entitled to reach different legal conclusions on the same evidence. But when four of New Zealand’s closest intelligence partners have independently arrived at broadly the same result, the Government should be prepared to explain why Wellington has not.

What evidence has New Zealand assessed differently?

What statutory threshold has not been met?

What legal or factual assessment distinguishes Wellington’s position from those of London, Canberra, Ottawa and Washington?

Those are reasonable questions. They are questions that become more pressing — not less — as New Zealand’s allies continue to harden their approach.

More broadly, this episode illustrates a recurring feature of New Zealand’s foreign policy.

Successive governments have often aligned with allies rhetorically while hesitating to match that rhetoric with policy. Wellington condemns Iranian-sponsored violence, joins allied statements criticising the IRGC and publicly supports efforts to counter hostile state activity. Yet when those same partners conclude that stronger legal measures are justified, New Zealand frequently pauses at the threshold.

Sometimes that caution is entirely appropriate. Smaller states should think carefully before adopting measures with significant diplomatic consequences.

But caution should not become an end in itself.

The Government has already moved from not considering designation to actively examining it. The United Kingdom’s decision removes one of the principal arguments that has historically justified delay.

If ministers believe the IRGC does not satisfy New Zealand’s statutory threshold, they should explain why.

If the hesitation remains primarily diplomatic, they should explain why maintaining relations with Tehran outweighs joining every other Five Eyes partner in designating an organisation they have all concluded poses a terrorist threat.

New Zealand has long described itself as a principled middle power committed to the rules-based international order. Principles carry the greatest weight when they are applied consistently.

The question is no longer whether New Zealand should begin the conversation.

It is how much longer it can remain the only Five Eyes nation that has yet to reach the same conclusion as every one of its closest intelligence partners.

References

  1. United Kingdom Government announcement and accompanying legislation introducing the proscription of the Islamic Revolutionary Guard Corps (IRGC), July 2026. https://www.reuters.com/world/uk/uk-proscribes-irans-irgc-terrorist-organisation-sky-news-reports-2026-07-13/
  2. David Seymour interview with Iran International, June 15, 2026. https://www.iranintl.com/en/202606159426
  3. NZSIS. New Zealand’s Security Threat Environment 2023. Wellington: New Zealand Security Intelligence Service, 2023. https://www.nzsis.govt.nz/assets/NZSIS-Documents/New-Zealands-Security-Threat-Environment-2023.pdf
  4. NZSIS. New Zealand’s Security Threat Environment 2025. Wellington: New Zealand Security Intelligence Service, 2025. https://www.nzsis.govt.nz/assets/NZSIS-Documents/New-Zealands-Security-Threat-Environment-2025.pdf