'The Consolidated Mining Standard Must Keep Digging' 26 November 2025

[...] NRGI recognizes that the second and final consultation draft of the CMSI represents an improvement on the first draft produced in 2024. However, several significant issues remain that will undermine the CMSI’s ability to serve as a credible global benchmark for responsible mining practices [...]

On governance

• Second consultation. The decision not to open the governance model to a second round of consultation limits transparency and meaningful participation on arguably the most important aspect of the CMSI [...]
• Multi-stakeholder participation. The August 2025 governance model is not genuinely multi-stakeholder [...]
• Limiting public discussion on the CMSI. The requirement that board members "speak with a unified voice when representing the Legal Entity to the community" [...] limits their ability to engage openly about concerns they have with the standard and its implementation [...]
• National Panels. [...] there is a risk that, without the necessary safeguards, national panels could become the means to dilute CMSI requirements in specific geographies. We are particularly alarmed by the suggestion that national mining associations could convene National Panels.

On the assurance process

• Statement of findings. A credible assurance process must provide clear, consistent and detailed information at the level of specific requirements, including explanations for why specific requirements do not apply. Without this, communities, civil society, investors and consumer companies cannot understand how conclusions were reached and whether the standard is being applied consistently [...]
• Corrective actions. The assurance process does not clearly state whether the corrective actions identified by assurance providers will be made public [...]
• Level of assurance required. The assurance process does not specify the level of assurance that assurance providers are expected to meet in carrying out their role [...]

On the claims policy

• A stronger path to leading practice. The standard does not include sufficient measures to encourage leading practice. Attainment of leading practice will not be acknowledged in the most visible parts of the standard, such as the aggregate scores, and will instead be buried in each site’s assured claims report [...]

On the standard [...]

Contract transparency

• The CMSI should reflect the reality that publication of contracts entered into prior to 1 January 2021 is now common practice [...] By not specifying a date, the CMSI undermines the 1 January 2021 reference established by the EITI requirement and the ICMM commitment [...]