"Risks Posed by the Consolidated Mining Standard Initiative: A Brief for Investors", 25 June 2025

A newly released investor brief, co-developed by a coalition of civil society organisations, highlights key risks of the proposed Consolidated Mining Standard Initiative (CMSI) for investors.

Key observations

Critical gaps in the proposed draft

• # 1 Standard requirements lack sufficient detail, guidance, and consistency to enable trustworthy assurance on environmental and social performance at mine sites.
• # 2 Non-conformance with fundamental international laws, principles, and already agreed upon norms of responsible business conduct that are already used by the mining industry.
• #3 A governance model that gives mining companies too much control over the development and application of the standard, undermining trust in the initiative, as well as accountability and scrutiny.

Risks to Investors

• Risk #1: The CMSI standard will create uncertainties for investors when screening new or existing investments in the mining sector for exposure to ESG-related risks, and may undermine the foundations of meaningful investor-company engagement.
• Risk #2: Particularly concerning is the lack of a clear and enforceable requirement for the Free, Prior and Informed Consent (FPIC) of Indigenous Peoples in the proposed draft standard.
• Risk #3: The CMSI exposes investors to the risks of improper mine waste disposal and tailings dam failures.
• Risk #4: The mining sector faces high exposure to corruption, which will only increase as the global demand for critical minerals continues to rise.
• Risk #5: Beyond direct investments in the mining sector, investors are exposed to systemic supply chain risks through their investments in the renewable energy and automotive sectors, among other sectors that are significant end-users of transition minerals.

Recommendations to investors

• Engage with investors on the Stakeholder Advisory Group and the Executives on core concerns with the proposed CMSI. In particular, this must include embedding FPIC as a non-negotiable requirement at all compliance levels. Submit these concerns and additional areas of improvement that support sustainable returns on investments in the mining sector and in mineral dependent sectors during the second public consultation.
• Raise expectations for voluntary standards to contribute to minerals supply chain stability, rather than undermine it, by issuing clear statements of support for alignment of voluntary standards in the mining sector with international law, standards and norms of responsible business conduct.
• Adopt clear requirements for the mining sector and other sectors that depend on mineral supplies, particularly for energy transition needs as part of your stewardship and investment policies, aligned with international standards and laws.
• Make clear in investor stewardship and engagement policies that investor due diligence systems will not rely on certification by voluntary standards like the CMSI that do not require compliance with international human rights norms and responsibilities, and expect their investee companies to adopt similar due diligence requirements.