New IAEA Toolkit Could Help African Regulators Cooperate on SMR Reviews

A new international regulatory toolkit could help African nuclear authorities cooperate when reviewing small modular reactors and other advanced nuclear technologies without transferring their legal responsibilities to foreign regulators.

The Regulatory Cooperation Toolkit was developed through the Regulatory Track of the International Atomic Energy Agency’s Nuclear Harmonization and Standardization Initiative, in partnership with the Small Modular Reactor Regulators’ Forum.

Made available in 2026, the toolkit contains guidance documents, templates, tables, questionnaires, examples and case studies intended to support joint reviews, collaborative assessments and the use of regulatory work already completed in another country.

The initiative responds to a practical challenge facing nuclear regulators.

Several countries may be considering the same reactor design, but each national authority has traditionally had to examine extensive quantities of similar technical information. Differences in laws, regulatory expectations, assessment methods and licensing procedures can also force reactor developers to produce separate safety cases or modify designs for each jurisdiction.

The toolkit is intended to reduce unnecessary duplication while preserving nuclear safety, regulatory independence and national sovereignty.

For African countries considering SMRs, the toolkit could provide an important mechanism for pooling scarce expertise. But it must not become a shortcut through which foreign licensing decisions are accepted without adequate national scrutiny.

Two Complementary Toolkits

The Regulatory Cooperation Toolkit is divided into two main components.

The first addresses differences between national regulatory frameworks. It helps authorities identify why regulators may reach different conclusions when assessing the same reactor design and provides approaches for managing those differences.

The second provides practical resources for a national regulator seeking to use information from a review previously conducted by another authority.

Together, the two components are intended to support three broad forms of regulatory cooperation:

• Collaborative reviews, in which regulators conduct separate assessments under their national requirements while exchanging information;
• Joint reviews, in which regulators examine defined aspects of a design together against an agreed scope; and
• Regulatory leveraging, in which one authority uses relevant information from an assessment completed by another regulator while making its own national decision.

These approaches can improve efficiency, but they do not necessarily produce identical licensing outcomes.

A design considered acceptable in one jurisdiction may still require additional analysis, modifications or conditions before it can satisfy the legal and regulatory requirements of another country.

What Regulatory Leveraging Means

A regulator considering an SMR may discover that an experienced foreign authority has already assessed much of the same design.

The earlier review might contain useful conclusions on reactor physics, thermal hydraulics, structural integrity, passive safety systems, severe-accident behaviour, digital instrumentation or other technical matters.

Rather than repeating every calculation and document review from the beginning, the receiving regulator may use parts of the earlier assessment as evidence.

Under the toolkit, the authority that originally conducted the assessment is described as the Source Regulator. The authority seeking to use that information is the Recipient Regulator.

Leveraging does not mean automatically accepting the source country’s licensing decision.

The Recipient Regulator must still determine whether:

• the Source Regulator is relevant to the proposed review;
• the assessment was conducted under a credible legal and regulatory framework;
• the information is sufficiently detailed and reliable;
• national laws and regulatory requirements differ;
• the design configuration being proposed is the same as the design previously reviewed;
• the earlier conclusions remain technically applicable;
• country-specific safety objectives are satisfied;
• site-specific hazards have been adequately addressed; and
• additional information, analysis or design modifications are required.

The final decision remains with the national regulator responsible for the country in which the reactor would be constructed and operated.

A Six-Step Process

The toolkit provides a six-step approach for regulators seeking to use information from completed reviews.

1. Identify relevant source regulators

The Recipient Regulator first determines which foreign authorities have reviewed the reactor design and whether their experience, legal framework and technical work are relevant.

Not every foreign approval will be equally useful.

A preliminary vendor assessment, pre-licensing engagement, generic design review, construction licence and operating licence may involve very different levels of regulatory examination.

2. Understand differences between regulatory frameworks

The Recipient Regulator then compares its national laws, safety objectives, regulations, standards, licensing procedures and assessment expectations with those of the Source Regulator.

This comparison is essential because two regulators may use similar language while applying different technical criteria.

3. Assess the effect of those differences

The authority evaluates whether the identified differences affect the relevance of the foreign assessment.

Some differences may be primarily procedural. Others may directly affect the reactor design, safety case, operating conditions or required protective measures.

4. Evaluate the quality of the source information

The Recipient Regulator assesses whether the information supplied by the Source Regulator is complete, traceable, transparent and technically credible.

The toolkit includes a checklist and scoring matrix to help authorities evaluate the quality of information obtained from another review.

5. Categorise the information

Information may be divided according to the extent to which it can be used directly, requires additional review or is unsuitable for the national assessment.

This helps the regulator concentrate its limited resources on areas where national conditions or regulatory differences are most significant.

6. Document how the information was used

The Recipient Regulator records what information was leveraged, what independent verification was conducted and how the foreign assessment contributed to the national conclusion.

Proper documentation is necessary for transparency, accountability and future regulatory oversight.

Addressing Regulatory Differences

The toolkit also helps regulators categorise differences identified between national systems.

These may arise from:

• different regulatory practices or review methods;
• different legally binding requirements that nevertheless pursue similar safety objectives;
• fundamentally incompatible legal requirements; or
• non-nuclear rules affecting matters such as construction, environmental protection or industrial standards.

Once differences are identified, regulators assess their safety significance.

Minor procedural differences may be documented without requiring substantial action. More significant differences may require harmonised interpretations, additional analysis, licence conditions or changes to the proposed reactor design.

The objective is not to force every country to adopt identical nuclear laws.

Instead, the process is intended to distinguish differences that are genuinely necessary for safety from those that create additional licensing work without producing a clear safety benefit.

Why It Matters for Africa

The toolkit could be particularly valuable for African regulatory authorities.

Many regulators on the continent operate with limited numbers of specialist staff and restricted technical budgets. Yet reviewing an advanced reactor may require expertise across a wide range of disciplines, including:

• reactor physics;
• thermal hydraulics;
• probabilistic safety assessment;
• severe-accident analysis;
• structural engineering;
• advanced nuclear fuels;
• digital instrumentation and control;
• cybersecurity;
• human factors;
• manufacturing oversight;
• emergency preparedness; and
• radioactive-waste and decommissioning arrangements.

It may be difficult for every country to maintain large teams of specialists in all these fields, particularly before a nuclear power project has entered formal licensing.

Regional and international cooperation could allow African regulators to share technical work, exchange experience and gain access to expertise that may not be available within a single national institution.

The potential benefit would be greatest where several countries are considering the same reactor technology.

Instead of commissioning several disconnected reviews, participating regulators could establish an agreed scope for cooperation, jointly question the vendor and share technical findings. Each authority would then apply the resulting evidence within its own legal system.

A Possible Role for FNRBA

The Forum of Nuclear Regulatory Bodies in Africa could provide an institutional platform for structured regional cooperation.

FNRBA was established in 2009 to support the strengthening and harmonisation of radiation protection, nuclear safety and nuclear-security regulation in Africa and to facilitate the exchange of experience among national regulatory bodies.

It has previously supported regional activities relating to SMR safety and licensing, including an IAEA workshop organised with the United States Nuclear Regulatory Commission.

This makes FNRBA a logical potential platform through which African regulators could:

• establish an SMR regulatory cooperation working group;
• identify designs of common interest;
• develop secure procedures for sharing regulatory information;
• organise regional technical review teams;
• maintain a roster of African regulatory specialists;
• coordinate access to technical-support organisations;
• conduct joint training and simulation exercises; and
• develop African guidance for applying the IAEA toolkit.

Such an arrangement would require formal agreement among participating authorities. No official decision to establish an Africa-wide review mechanism under the new toolkit has been announced.

FNRBA cooperation should therefore be understood as a practical opportunity rather than an existing licensing arrangement.

Africa Was Represented in the Toolkit’s Development

The toolkit was developed with contributions from regulators, government organisations, technical-support organisations and industry representatives from 25 IAEA Member States.

South Africa was among the participating countries.

This participation is important because South Africa operates the continent’s only commercial nuclear power station and has an established nuclear regulator with experience in reactor licensing and oversight.

However, one African country’s participation does not automatically make the toolkit responsive to every condition found across the continent.

African newcomer states will still need to consider issues such as:

• limited national technical-support capacity;
• dependence on foreign vendors and consultants;
• weaker electricity grids;
• coastal and inland siting constraints;
• high temperatures and water scarcity;
• emergency-response capability;
• cross-border transport routes;
• security conditions;
• public confidence; and
• long-term arrangements for spent fuel and radioactive waste.

Regional implementation should therefore adapt the toolkit to African institutional and infrastructural realities.

Site-Specific Reviews Cannot Be Imported

Even where another regulator has completed a detailed reactor-design assessment, many parts of a nuclear licensing review remain country- and site-specific.

An approval issued in Canada, the United States, Russia, China, France, South Korea or another supplier country cannot determine whether a proposed African site is suitable.

The national regulator must independently assess hazards such as:

• earthquakes and geological conditions;
• flooding and extreme rainfall;
• drought and cooling-water availability;
• extreme temperatures;
• coastal erosion and sea-level conditions;
• external fires;
• nearby industrial and transport activities;
• aircraft hazards;
• grid instability; and
• the reliability of emergency infrastructure.

The authority must also examine the capability of the proposed owner-operator, the competence of national institutions and the arrangements for construction oversight, physical protection and emergency response.

A foreign design review may inform these assessments. It cannot replace them.

Security and Safeguards Remain National Responsibilities

The Regulatory Cooperation Toolkit is principally intended to improve cooperation in regulatory reviews of advanced reactor designs.

It should not be interpreted as resolving every issue related to nuclear security or safeguards.

African authorities must still develop national arrangements for:

• nuclear-material accountancy and control;
• implementation of IAEA safeguards obligations;
• physical protection;
• cybersecurity;
• transport security;
• insider-threat mitigation;
• nuclear and radiological emergency response; and
• strategic trade and export controls.

These requirements may become particularly complex for transportable or remotely located reactors.

A reactor reviewed favourably for deployment at an established nuclear site may present different security and emergency-planning challenges when proposed for a mine, industrial complex or isolated electricity system.

Cooperation Cannot Replace Competence

The principal risk is that regulatory leveraging could be treated as a substitute for developing a competent national regulator.

A country might be tempted to accept a vendor’s claim that the reactor has already been “approved” elsewhere and therefore requires only a limited domestic review.

That approach would undermine regulatory independence.

African regulators still need sufficient staff and expertise to:

• understand the foreign assessment;
• identify gaps in the information provided;
• compare regulatory requirements;
• question the source regulator where necessary;
• challenge the applicant’s interpretation;
• commission independent calculations;
• determine the applicability of foreign conclusions; and
• defend the final national decision.

A regulator that lacks the expertise to evaluate a foreign review also lacks the expertise to rely on it responsibly.

International cooperation should therefore be accompanied by sustained investment in national personnel, regulatory infrastructure, information systems and technical-support organisations.

Protecting Regulatory Independence

Collaborative reviews must also be protected from commercial and political pressure.

Reactor vendors have a legitimate interest in avoiding repeated and inconsistent licensing processes. Standardisation may reduce unnecessary design changes and improve manufacturing efficiency.

But the desire for faster deployment must not determine the regulator’s conclusions.

African regulatory authorities should establish clear rules governing:

• contact with reactor vendors;
• participation in multinational reviews;
• treatment of proprietary information;
• conflicts of interest;
• publication of regulatory findings;
• reliance on vendor-funded studies;
• access to foreign regulatory documentation; and
• the separation of promotional and regulatory functions.

Governments should not pressure regulators to accept another country’s conclusions merely to preserve a diplomatic agreement, vendor relationship or project schedule.

The regulator’s statutory duty is to protect people and the environment, not to facilitate a predetermined technology choice.

A Practical Opportunity for Newcomer Countries

Used properly, the IAEA toolkit could provide African regulators with a structured way to avoid repeating work that has already been competently performed elsewhere.

It could help national authorities focus their resources on:

• differences between legal systems;
• unresolved safety questions;
• country-specific requirements;
• the proposed operator’s competence;
• site conditions; and
• areas where the foreign assessment is incomplete or inapplicable.

It could also support greater consistency in the questions African regulators ask vendors.

This would be particularly valuable if several countries are approached with similar reactor proposals and would otherwise negotiate separately with companies possessing substantially greater technical and financial resources.

Collective technical engagement could reduce information asymmetry without creating a supranational African licensing authority.

Efficiency Without Regulatory Surrender

The new toolkit represents a practical step towards greater international cooperation in the regulation of SMRs and advanced reactors.

For African nuclear-newcomer countries, it could improve access to expertise, reduce unnecessary duplication and strengthen regional exchange.

But the value of regulatory cooperation will depend on how it is implemented.

The toolkit must not become a mechanism for importing approvals, outsourcing judgement or weakening national standards.

Each country remains responsible for its legal framework, regulatory decisions, site assessment, operator oversight and protection of the public and environment.

The central principle should therefore be clear:

African regulators can share evidence, technical work and experience.

They cannot share away their responsibility.