Unprecedented levels of interest in JORC Code updates - final version due end 2025

Following on from our previous post, the Australasian Joint Ore Reserve Committee (Committee) recently disclosed that it received over 8,200 comments on the draft suite of updates to the JORC Code (Code). Written feedback was sought over a three-month consultation period (August to October 2024), in parallel with a series of in-person and online consultation events.  

This level of stakeholder engagement demonstrates the importance of the Code to the Australian mining industry and the potential significant impacts for industry participants.

The Committee’s review of the consultation feedback is ongoing, and has not yet responded to the feedback as at the date of this article.

The Code was last updated in 2012, and the update process is intended to align the Code with comparable international jurisdictions and the contemporary requirements for mine development and investment, particularly ESG considerations. The consultation draft incorporated ASIC’s and ASX’s comments in relation to these matters.

Revisions to the consultation draft of the Code updates will require further ASIC and ASX review, and ultimately Ministerial approval.

In this article, we outline the key themes arising and what comes next.

What were the focus areas?

While the feedback has not been disclosed, based on our participation in the consultation events and public commentary around that time, we expect the feedback to focus on the following key areas:

1. ESG considerations: the proposed ESG reporting requirements at all stages of estimation / reporting (including exploration results and exploration targets) and enhanced ESG disclosure requirements for reporting mineral resource and ore reserve estimates.
2. Proposed use of technical specialists: the proposal to allow a competent person to rely on an appropriately qualified technical expert to cover modifying factors outside of the core areas of geology and mining engineering (e.g. metallurgy or ESG factors).
3. Reasonable prospects of [eventual] economic extraction: clarifying the significance of removing ‘eventual’ from the ‘reasonable prospects’ test (aligning the Code with comparable overseas jurisdictions). 
4. Competency and CV requirements: a need for further guidance on self-assessed competency (including the 5-year minimum experience requirement) and the practicality and content of proposed online CVs.
5. Reconciliation reporting: the practicalities of operating mines complying with the proposed requirement to reconcile production against previously reported resource and reserve estimates (via the annual mineral resource and ore reserve statement).

Importantly, the implications for the proposed Code updates are likely to have differing impacts at each stage of mining exploration, development, and production. 

Final release still targeted for 2025

The Committee reaffirmed its targeted 2025 release date for the updated Code - but clarified that this would occur by the end of 2025. 

The Committee’s previous timeline referenced a final approval process with ASX, ASIC and the Minister in early 2025. However, we expect this timeline was pushed out due to the extensive industry feedback. 

Once the Code updates are finalised, there should be a transition period of at least 12 months. 

ASX-listed companies should be able to voluntarily report under the updated Code during the transition period (but must report under the updated Code when the transition period ends). 

We will continue to monitor the Code update process, as well as regulatory updates and enforcement activity in relation to reserves and resources reporting – please see our previous updates, New guidance on reporting exploration results; and Your quick guide to the 'imminent' JORC Code update.

If you'd like to discuss how you might be affected by the above, please reach out to a member of our team.

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