A Comparative Study of the Legal Framework for Combating Cyberterrorism in Iranian and EU Law

Document Type : Original Article

Author

Master of Criminal Law and Criminology, Islamic Azad University, Lahijan Branch, Gilan, Iran

zenodo.org/ajmhss.2026.604323.1116
Abstract
Cyberterrorism is not synonymous with serious hacking, ideologically motivated disruption, terrorist propaganda, or state-sponsored cyber operations. This article compares how Iranian law and European Union law address digitally enabled violence and interference that may meet a terrorism threshold, while also assessing ordinary cybercrime, critical-infrastructure security, electronic evidence and procedural safeguards. Employing a qualitative doctrinal and functional comparative method, it reads Iran’s Computer Crimes Act against the EU Counter-Terrorism Directive, the attacks-against-information-systems framework and the layered cybersecurity acquis, with developments through 24 September 2026. It finds a shared capacity to prosecute harmful interference with essential systems but significant differences in the express legal link between cyber interference and terrorist purpose, the distribution of preventive duties and the architecture of cross-border evidence. The comparison also demonstrates that resilience laws cannot replace criminal-law proof of intent and that cybersecurity incident datasets must not be treated as estimates of terrorist offending. The article proposes tightly defined offence criteria, interoperable evidence safeguards and risk-based infrastructure protection without conflating political expression, cybercrime and terrorism. [R01-R17, R20]

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Articles in Press, Accepted Manuscript
Available Online from 25 September 2026