Background and Objectives: Achieving an appropriate policy needs an in-depth and comprehensive understanding of policy-making process. This study aimed to analyze HIV/AIDS policy-making process in Iran.

Material and Methods: This is a qualitative/exploratory study. Data were collected through document review and semi-structured interview. Non-probability sampling was used for selecting documents and research participants. We used framework analysis approach assisted by MAXQDA for analyzing qualitative data.

Results: AIDS policy is formulated in two specific ways within national work group in the format of national strategic plan and drug damage reduction committee. The main problem of the policy process is fragmentation and lack of comprehensiveness. Country approach of the policy implementation is top-down. The main duty of country committee and its sub-committees facing with some challenges is generating interaction between the relevant organizations. Despite the specific structure of evaluation process, it suffers from challenges such as lack of required implementation power, lack of resource anticipation, weakness in systematic and comprehensiveness evaluation and not-enough cooperation among plan’s stakeholders.

Conclusion: It is obvious that policy-making in this area is completely governmental and the role of non-governmental organizations and civil servants is neglected. It seems that reform in AIDS policy-making structure and process can solve most of the problems of implementation, monitoring and evaluation.