The former deputy director-general of the International Atomic Energy Agency has criticized the agency for “reduc[ing] the level of transparency and details in its reporting” on Iran’s nuclear program, making it “practically impossible” to confirm that Iran is complying with the terms of the nuclear deal.

Olli Heinonen, who worked for the nuclear watchdog agency for 27 years, made his criticisms in a research memo (.pdf) published Monday by the Foundation for Defense of Democracies.

Heinonen’s first concern was that the IAEA report doesn’t list the amount of enriched uranium produced at the Natanz site. The deal, formally known as the Joint Comprehensive Plan of Action (JCPOA), caps Iran’s stockpile of uranium hexafluoride (UF6) at 300 kilograms. Given that Natanz has a capacity to produce 100 kilograms of UF6 per month, it’s unclear how, during the eight months covered by the report, the total UF6 stockpile stayed below the JCPOA’s cap.

It also does not provide an inventory of uranium ore concentrate, also known as yellowcake, that has been produced from Iranian mines. “This is an important parameter in confirming the absence of undeclared nuclear activities,” Heinonen noted. The report fails to provide specific numbers for either the IAEA’s or Iran’s inventory of nuclear material at the Esfahan plant; a potential discrepancy between the two “could indicate that there might be undeclared nuclear material in Iran.”

Iran was allowed to continue to testing advanced centrifuges, but no details are provided about the nature of the testing. Knowing how the testing has progressed is essential to knowing if Iran’s advances in enriching matches the enrichment plan Iran submitted to the IAEA under the terms of the JCPOA. If Iran’s progress in enriching technology has significantly advanced, it could have “an impact on breakout times”—how quickly Iran could weaponize its nuclear material.

The IAEA report also does not indicate whether agency is conducting short-notice inspections or how frequently they are conducting them, which are standard according the IAEA safeguards standards. “Such information is essential to determine the IAEA’s capability to detect at an early stage any deviation from the agreed implementation parameters of the JCPOA,” Heinonen wrote.

Given the doubts raised by the IAEA’s omissions, statements made by Iranian officials about nuclear issues became even more troubling to Heinonen. He cited a statement made in August by an advisor to Supreme Leader Ayatollah Ali Khamenei who called for setting up a “massive institute for nuclear research” which “can be overt and only 30 percent covert.” That advisor, Mohammad-Javad Larijani, also said that Iran is not “afraid” to violate its commitments, and that Iran must be able to convince the world that it can build a nuclear weapon within 48 hours. “This is not and should not be the language of a country that wants to build nuclear reactors simply to generate electricity,” Heinonen wrote.

Heinonen also noted that Iran had admitted for the second time to exceeding the deal’s threshold on “heavy water,” which can be used to make a nuclear bomb. Iran announced plans to export the excess heavy water, but given that this was the country’s second violation, Heinonen wrote, it “shows disrespect for the nuclear terms of the agreement.”

In light of all this, Heinonen recommended that “there should be detailed reporting to ensure a robust and transparent execution of the JCPOA in letter and in spirit.”

Heinonen’s concern about the IAEA’s lack of details have been expressed by others.

An analysis published in November by the Institute for Science and International Security assessed that “the continued lack of information in the IAEA reports combined with the ongoing secrecy surrounding the decision-making of the Joint Commission is a serious shortcoming in the implementation of the JCPOA and raises legitimate questions about the adequacy of Iran’s compliance.”

In July, 15 Democratic senators who supported the nuclear deal questioned whether the IAEA’s reporting requirements on Iran’s nuclear program were specific enough to be effective.

“Providing additional situational awareness of Iran’s nuclear program is vital for the long-term health of this agreement,” the senators, led by Sen. Gary Peters (D – Mich.), wrote in a letter to President Barack Obama. “We urge [the Obama] administration to ensure that the IAEA releases all relevant technical information so that we may continue to make our own judgments about the status of Iran’s nuclear program.”

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