The standard with no mine to audit

The short version

A responsible-mining standard is an audit instrument: it turns a claim into a finding by measuring a site against written requirements. That design carries an awkward consequence for projects that have not been built. The most demanding of the multi-stakeholder schemes states plainly that its current version applies to industrial mines in operation — so a company at exploration stage has nothing to be audited against. Two attempts have been made to fix that since 2021, and at the last public record the second was still awaiting board consensus.

Why the gap exists at all

Audit standards measure performance. That is what distinguishes them from policies: a policy states an intention, while a standard states a requirement and an assessor records whether it is met at a particular site on a particular date.

Everything about that design assumes something to look at. Water quality has to be sampled, grievance records have to be counted, worker exposures have to be measured, a tailings facility has to be reviewed. A project without operations has no such record — not because it is behaving badly, but because none of the measurable things exist yet. What it has instead are baseline studies, a proposed design, commitments and an engagement process.

Assurance of an operating site and assurance of a pre-operational project are therefore different products, and the second is much closer to auditing management systems than outcomes — the criticism most often made of certification generally. That framing is this hub's, not any cited source's, but the structural problem it describes is why the gap has proved hard to close.

The scope sentence

IRMA's own statement of applicability is short and decides the question. Its current standard, the initiative says, is "applicable to all industrial mines in operation, as well as mineral processing when it is conducted at the site of the mine (i.e., co-located on-site mineral processing)"↗(opens in a new tab), and is "not applicable to mineral exploration or stand-alone mineral processing"↗(opens in a new tab); it serves as "the basis of a voluntary assurance system offering independent third-party assessment and verification of environmental and social performance measures at industrial mine sites around the world"↗(opens in a new tab).

Read those two together and the position of a project at exploration stage is unambiguous. There is a voluntary assurance system available; it is not available to them. Not "not yet eligible" as a matter of queueing — outside the scope of the instrument.

A standard that measures operations cannot be failed by a project that has none. It also cannot be passed.

The first attempt: a separate standard

The obvious remedy is a second standard for the earlier stages, and that is what was drafted. The IRMA-Ready Standard was released in December 2021 for public consultation, with the comment period closing on 15 April 2022, and it was structured across six stages — three phases of exploration and three of development, covering pre-permitting, permitting and construction.

Its stated relationship to the main standard is worth quoting because it is carefully hedged. An "exploration or proposed mining project that meets the requirements in this pre-operational Standard should be well prepared to meet requirements in the IRMA Standard for Responsible Mining if the project is developed and a mine becomes operational"↗(opens in a new tab). Not "will comply", not "will be certified" — should be well prepared, conditional on the project proceeding at all. That is an accurate description of what a pre-operational assessment can honestly deliver, and it is also, read commercially, a modest offer.

The draft did not become a standard. IRMA's own page records that the "IRMA Board of Directors has not endorsed this first draft"↗(opens in a new tab), while agreeing to release it for stakeholder input.

The second attempt: fold it in

The approach then changed from a companion standard to a single wider one. IRMA describes its version 2.0 as new in its approach in that it "now covers more phases of the mining and mineral supply chain, from exploration and development, through mining, closure, and mineral processing"↗(opens in a new tab), and states that the draft builds on the content drafted for the 2021 IRMA-Ready document.

That is a genuine change of design, not a relabelling. A single standard covering the lifecycle means the requirements a project meets before construction are the early clauses of the same instrument it will be audited against later, rather than a separate scheme with its own currency.

It is also not finished. A second public consultation ran from 22 July to 22 October 2025, and a revision update — undated in the page body, though its URL path carries 12 November 2025 — recorded that "82 organizations have engaged in the revision process, covering all regions of the world"↗(opens in a new tab), with the qualification that the "IRMA Standard v2.0 won't be approved until the IRMA Board has had time to review such final version, discuss the changes and the recommendations of their constituencies, and has reached consensus"↗(opens in a new tab). No publication date was given. What has happened since that update was not established for this article, and nothing here should be read as a statement that the standard has or has not been approved.

What a reader should take from it

Three things, none of which is a verdict on the scheme.

First, the phrase "certified against a responsible mining standard" carries a scope inside it. Asking which standard, which version, and whether the site in question falls within its applicability is not pedantry; for a pre-operational project it is the whole answer.

Second, the difficulty is structural rather than administrative. Four years and two drafting approaches have gone into the question of what to assess when there is nothing operating, in a scheme that does not approve a standard until its board has reached consensus across its constituencies — which is exactly the kind of question such governance is slow at.

Third, the absence of an applicable standard is not the same as an absence of obligations. Permitting law, environmental assessment, heritage law and the disclosure requirements that reach exploration companies all apply well before an audit scheme does. A project with nothing to be certified against still has a great deal to comply with.

Related

• ESG — how disclosure requirements handle a company with no operations to report
• Community Engagement — the practice these standards specify, and how it is judged
• Regulation — the legal floor beneath every voluntary scheme
• Industry Associations — the bodies that write most of these codes