Journal Of Researches Energy Law Studies

Journal Of Researches Energy Law Studies

The Capacity of Iran's Legal System to Prevent the Environmental Impacts of High Energy Consumption in Cryptocurrency Mining

Document Type : ISI

Authors
1 PhD Candidate, Department of Environmental Management, Science and Research Branch, Islamic Azad University, Tehran, Iran.
2 Assistant Professor, Department of Environmental Management, Science and Research Branch, Islamic Azad University, Tehran, Iran .
3 Professor at the Faculty of Law and Political Science, University of Tehran, Tehran, Iran.
4 Professor, Faculty of Agriculture, Water, Food and Processes, Science and Research Branch, Islamic Azad University, Tehran, Iran. ,
10.22059/jrels.2026.402515.605
Abstract
Introduction
Proof-of-work cryptocurrency mining has become an important legal and environmental issue because network security depends on continuous computational competition and, consequently, substantial electricity consumption. When electricity is mainly generated from fossil fuels, mining may increase greenhouse-gas emissions, place additional pressure on electricity generation and transmission systems, and indirectly increase water consumption and thermal discharges associated with power production and cooling. These concerns are particularly significant in Iran, where electricity-supply shortages, a carbon-intensive energy mix, regional water stress, and fragmented administrative responsibilities create additional environmental and regulatory challenges.
This situation raises a central question: can the environmental impacts of cryptocurrency mining be effectively controlled through a coordinated interpretation and enforcement of existing Iranian laws and regulations, or is the immediate adoption of a new comprehensive statute necessary?
This study evaluates the capacity of Iran's legal system to align cryptocurrency mining with environmental-protection requirements. It focuses on four interconnected areas: the use of renewable and clean electricity; electricity tariffs and energy-efficiency obligations; investment in efficient technologies; and the prevention of water-related and thermal pollution. It also examines how licensing, monitoring, and financial mechanisms can convert general legal duties into measurable and enforceable obligations for individual mining facilities.

Method
The research uses a descriptive-analytical and library-based method. It is based on documentary analysis of the Constitution of the Islamic Republic of Iran, energy and environmental laws, national development plans, executive regulations, ministerial resolutions, and licensing rules relating to cryptocurrency mining. Particular attention is given to the constitutional duty to protect the environment, the Energy Consumption Pattern Reform Act, the Clean Air Act, the Sixth and Seventh Development Plans, Article 12 of the Law on Removing Barriers to Competitive Production, renewable-energy regulations, electricity tariffs for mining centers, environmental-impact assessment rules, and legislation protecting aquatic resources.
The relevant legal rules are examined as parts of an interconnected regulatory chain rather than as isolated provisions. For each area, the study identifies the competent authority, the legal obligation, the available economic or administrative instrument, the monitoring requirement, and the applicable enforcement mechanism. International experience is also used comparatively to identify practical regulatory options, including low-energy consensus mechanisms, renewable-energy supply, demand-response participation, conditional use of associated gas, immersion cooling, waste-heat recovery, environmental disclosure, and measurement, reporting, and verification systems. These experiences are evaluated in light of Iran's energy structure, climate, water limitations, and administrative framework.

Conclusions
The findings show that Iranian law already contains significant, although dispersed, legal capacities for reducing the environmental impacts of cryptocurrency mining. The main weakness is not the absence of legal authority but insufficient coordination among licensing, electricity supply, tariff setting, environmental approval, technical standards, and data verification.
Mining licenses should therefore be issued or renewed only when operators provide verifiable evidence of the lawful source and agreed share of clean electricity, environmental approval appropriate to the facility's scale and location, and an operational agreement defining maximum electricity load, curtailment duties, and continuous reporting. A coordinated procedure should connect the Ministry of Industry, Mine and Trade, the Ministry of Energy and its affiliated bodies, and the Department of Environment while preserving their respective legal powers.
Electricity tariffs should also be based on environmental and technical performance rather than total consumption alone. Incentives and penalties may be linked to energy efficiency, carbon intensity, renewable-electricity share, compliance with peak-load restrictions, water consumption, and heat management. Facilities investing in renewable generation, verified efficiency improvements, or grid-support services should benefit from existing financial mechanisms, particularly those available under Article 12 of the Law on Removing Barriers to Competitive Production.
The environmental framework should further establish measurable standards for water withdrawal, water footprint, and thermal discharge. Permissible temperature changes in receiving waters should be numerically defined, and environmental approvals should require worst-case climatic and hydrological modelling, closed-loop or low-water cooling where necessary, and periodic monitoring. These obligations should be incorporated into operating and grid-connection permits.
Finally, major mining facilities should be subject to a uniform measurement, reporting, and verification system covering electricity consumption, energy source, carbon intensity, water use, cooling performance, and waste-heat management. Reliable and auditable data are essential for differentiated tariffs, inspections, accountability, and enforcement. Therefore, the immediate priority is not necessarily new legislation but coordinated enforcement of existing legal capacities through supplementary regulations, numerical standards, integrated licensing, and credible monitoring. New legislation would become necessary only if these measures fail to resolve persistent regulatory and enforcement gaps.
Keywords

References
Bruno, A., Weber, P., & Yates, A. J. (2023). Can Bitcoin Mining Increase Renewable Electricity Capacity? Resource and Energy Economics, 74, Article 101376. https://doi.org/10.1016/j.reseneeco.2023.101376
Chamanara, S., Ghaffarizadeh, S. A., & Madani, K. (2023). The  Environmental Footprint of Bitcoin Mining across the Globe: Call for Urgent Action. Earth’s Future, 11(10), Article e2023EF003871.
Council of Ministers of the Islamic Republic of Iran. (2011). Environmental Impact Assessment By-law for Major Production, Service, and Development Projects. Approved 20 November 2011 [29 Aban 1390]. https://qavanin.ir/Law/TreeText/?IDS=5796680998973514441 (Accessed 22 July 2026). [in Persian]
Council of Ministers of the Islamic Republic of Iran. (2015). Executive By-law of Article 12 of the Law on Removing Barriers to Competitive Production and Improving the National Financial System. Approved 12 July 2015 [12 July 2015].
     https://qavanin.ir/Law/TreeText/?IDS=77228989880917037 (Accessed 22 July 2026). [in Persian]
Council of Ministers of the Islamic Republic of Iran. (2024). By-law on Removing Barriers to the Construction of Renewable Power Plants. Approved 14 February 2024 [14 February 2024].
     https://qavanin.ir/Law/TreeText/?IDS=2087747374539460599 (Accessed 22 July 2026). [in Persian]
de Vries, A. (2023). Cryptocurrencies on the Road to Sustainability: Ethereum Paving the Way for Bitcoin. Patterns, 4(1), Article 100633. https://doi.org/10.1016/j.patter.2022.100633
 de Vries, A. (2024). Bitcoin’s Growing Water Footprint. Cell Reports Sustainability, 1(1), Article 100004. https://doi.org/10.1016/j.crsus.2023.100004
Gallersdörfer, U., Klaaßen, L., & Stoll, C. (2020). Energy Consumption of Cryptocurrencies beyond Bitcoin. Joule, 4(9), 1843–1846.
Haghshenas, K., Setz, B., Blosch, Y., & Aiello, M. (2023). Enough Hot Air:  The Role of Immersion Cooling. Energy Informatics, 6(1), Article 14.
Islamic Consultative Assembly. (1995). Law on the Conservation and Exploitation of Aquatic Resources of the Islamic Republic of Iran.
     https://qavanin.ir/Law/TreeText/?IDS=5232863487203754909 (Accessed 22 July 2026). [in Persian]
Islamic Consultative Assembly. (2011). Energy Consumption Pattern Reform Act. Article 6, approved 23 February 2011 [5 March 2011]. https://qavanin.ir/Law/TreeText/?IDS=5108236226208858804 (Accessed 22 July 2026). [in Persian]
Islamic Consultative Assembly. (2017). Law on the Sixth Five-Year Economic, Social, and Cultural Development Plan of the Islamic Republic of Iran. Approved 4 March 2017 [4 March 2017].
     https://qavanin.ir/Law/TreeText/?IDS=6692614242613958019 (Accessed 22 July 2026). [in Persian]
Islamic Consultative Assembly. (2017). Clean Air Act. Article 19.
     https://qavanin.ir/Law/TreeText/?IDS=1319491017286243401 (Accessed 22 July 2026). [in Persian]
Islamic Consultative Assembly. (2024). Law on the Seventh Five-Year Development Plan of the Islamic Republic of Iran. https://qavanin.ir/Law/TreeText/?IDS=15033449572675229448 (Accessed 22 July 2026). [in Persian]
Islamic Republic of Iran. (1979, revised 1989). Constitution of the Islamic Republic of Iran.
     https://qavanin.ir/Law/TreeText/?IDS=6623702055317218729 (Accessed 22 July 2026). [in Persian]
Islamic Republic of Iran. (1974, amended 1992). Law on the Protection and Improvement of the Environment.
      https://qavanin.ir/Law/TreeText/?IDS=6697071490203326533 (Accessed 22 July 2026). [in Persian]
Jiang, S., Li, Y., Lu, Q., Hong, Y., Guan, D., Xiong, Y., & Wang, S. (2021). Policy Assessments for the Carbon Emission Flows and Sustainability of Bitcoin Blockchain Operation in China. Nature Communications, 12(1), Article 1938. https://doi.org/10.1038/s41467-021-22256-3
Jones, B. A., Goodkind, A. L., & Berrens, R. P. (2022). Economic Estimation of Bitcoin Mining’s Climate Damages Demonstrates Closer Resemblance to Digital Crude than Digital Gold. Scientific Reports, 12(1), Article 14512. https://doi.org/10.1038/s41598-022-18686-8
Ministry of Energy. (2021). Resolution Amending the Regulations on Electricity Supply to Cryptocurrency-Mining Centers. Resolution No. 1400/10786/20/100, issued 5 April 2021 [5 April 2021]. https://davoudabadi.ir/page/93964725 (Accessed 22 July 2026). [in Persian]
Ministry of Energy. (2021b). Regulations on Supplying Electricity to Cryptocurrency-Mining Centers from Renewable and Clean Energy Sources. Issued 20 December 2021 [20 December 2021]. https://irrea.ir/blog/ (Accessed 22 July 2026). [in Persian]
Ministry of Industry, Mine and Trade. (2019). Instructions for Issuing Establishment and Operating Licenses for Cryptocurrency-Mining Activities. Approved 13 November 2019 [13 November 2019]. https://w2pshop.ir/wp-content/uploads/2020/08/8.-dastoamal-tasis-baraye-faaliat-estekhraj-ramzarzh.pdf (Accessed 22 July 2026). [in Persian]
Náñez Alonso, S. L., Jorge-Vázquez, J., Echarte Fernández, M. Á., & Reier Forradellas, R. F. (2021). Cryptocurrency Mining from an Economic and Environmental Perspective: Analysis of the Most and Least Sustainable Countries. Energies, 14(14), Article 4254.
Ramezani Ghavamabadi, M. H. (2013). The Preservation of the Environment in Iran’s Constitution. The Quarterly Journal of Judicial Law Views, 18(63), 93–140. https://jlviews.ujsas.ac.ir/article_703419.html (Accessed 3 March 2026). [in Persian]
Shahbazi, A., & Heidari Torkabad, F. (2024). Cryptocurrency Mining and International Environmental Law: Requirements and Challenges. Public Law Studies Quarterly, 54(4), 2717–2746.
Swain, S. (2023). Design Options for Pollution Tax on Mining of Crypto Assets. SSRN Electronic Journal, 1–12. https://doi.org/10.2139/ssrn.4531983
Truby, J., Brown, R. D., Dahdal, A., & Ibrahim, I. (2022). Blockchain, Climate Damage, and Death: Policy Interventions to Reduce the Carbon Emissions, Mortality, and Net-Zero Implications of Non-Fungible Tokens and Bitcoin. Energy Research & Social Science, 88, Article 102499. https://doi.org/10.1016/j.erss.2022.102499
Vazquez, J., & Crumbley, D. L. (2022). Flared Gas Can Reduce Some Risks in Crypto Mining as Well as Oil and Gas Operations. Risks, 10(6), Article 127. https://doi.org/10.3390/risks10060127
Wahlroos, M., Pärssinen, M., Manner, J., & Syri, S. (2017). Utilizing Data Center Waste Heat in District Heating—Impacts on Energy Efficiency and Prospects for Low-Temperature District Heating Networks. Energy, 140, 1228–1238. https://doi.org/10.1016/j.energy.2017.08.078
Woo, J.-W., Fatima, R., Kibert, C. J., Newman, R. E., Tian, Y., & Srinivasan, R. S. (2021). Applying Blockchain Technology for Building Energy Performance Measurement, Reporting, and Verification (MRV) and the Carbon Credit Market: A Review of the Literature. Building and Environment, 205, Article 108199.