"Business and Human Rights Centre’s comments on the second and final draft of the Consolidated Mining Standard Initiative", 11 December 2025

BHRC acknowledges progress in the second and final draft of the Consolidated Mining Standard Initiative (CMSI) documents, following the first consultation in 2024 (see our comments here). However, flaws in the design of the Governance Model – announced in August 2025; and shortcomings in the proposed Consolidated Standard – including lack of alignment with reference standards and norms of Responsible Business Conduct, as well as in the Assurance Process and Claims Policy, risk undermining the CMSI’s stated objective to set high-bar expectations of responsible practices for the sector. The Consolidated Standard states the good practice level “in line with industry standards and international norms, frameworks and guidelines” but it does not say specifically how performance areas align with these standards, norms and frameworks and guidelines. This risks leading to minimal or absent public accountability on any equivalency claim.

We raised the concerns detailed here, among others, as part of our submission to the second consultation held by the CMSI on the Governance Model, the Consolidated Standard, and the Assurance Process.