Alphabetical.
Last updated: 2026-07-09
No-Net-Loss Meets Target 15 — How Global Biodiversity Policy Is Reaching Into Mine Design
Mining's biodiversity obligations are shifting from voluntary industry principle to
government-mandated corporate disclosure. ICMM's decade-old no-net-loss commitment now sits
alongside the Kunming-Montreal Global Biodiversity Framework's Target 15, which for the first time
explicitly requires governments to make large companies assess, disclose, and reduce biodiversity impacts.
1. ICMM Mining Principle 7: World Heritage exclusion and the mitigation hierarchy
The International Council on Mining and Metals (ICMM)'s Mining Principles commit member
companies under Principle 7: Conservation of Biodiversity to two specific Performance
Expectations. 7.1 requires members to neither explore nor develop new mines in
UNESCO World Heritage Sites and to respect all legally designated protected areas, while
7.2 requires application of the mitigation hierarchy — avoid,
minimise, restore, offset — to achieve a minimum of no net loss (NNL) or net gain of
biodiversity by the completion of mine closure
(ICMM, Principle 07: Conservation of Biodiversity).
These commitments were developed with extensive input from NGOs, international organisations, and academics,
and establish baseline performance expectations that ICMM audits against as part of member companies'
Mining Principles assurance process. Because the no-net-loss ambition is explicitly tied to the
closure stage of a mine's life, it functionally links ICMM's biodiversity principle
directly to closure planning — a rehabilitated or offset landscape only counts once closure is
substantially achieved, not merely planned.
2. Kunming-Montreal Target 15: corporate biodiversity disclosure becomes a treaty-level ask
The Kunming-Montreal Global Biodiversity Framework (KM-GBF), adopted at COP15 and setting
23 action-oriented targets for the decade to 2030, includes Target 15, which for the first
time within a Convention on Biological Diversity strategic plan explicitly requires governments to take
“legal, administrative or policy measures” ensuring that large and transnational
companies and financial institutions regularly monitor, assess, and transparently disclose their
biodiversity risks, dependencies, and impacts across operations, supply chains, and portfolios
(Convention on Biological Diversity, COP-15 Decision 15/4 — Kunming-Montreal Global Biodiversity Framework).
The Secretariat of the CBD frames Target 15 as the Framework's provision most directly linked to business,
built on three pillars: mandatory monitoring and disclosure, consumer information to support sustainable
consumption, and reporting on compliance with access and benefit-sharing regulations
(Secretariat of the Convention on Biological Diversity, Kunming-Montreal Global Biodiversity Framework and Business).
Analysis from the Capitals Coalition finds that existing corporate disclosure frameworks — including
the Taskforce on Nature-related Financial Disclosures (TNFD) and GRI Standard 304
(renumbered GRI 15 in some mappings) — already show meaningful thematic alignment with Target 15,
positioning mining-sector biodiversity reporting to converge on TNFD-style metrics as national governments
translate Target 15 into domestic law through updated National Biodiversity Strategies and Action Plans
(NBSAPs)
(Capitals Coalition, How Can Corporate Biodiversity Assessment and Reporting Align With the GBF?).
3. Target 2 and Target 3's 30x30 goal versus mining's land-use footprint
Beyond Target 15, the KM-GBF's headline “30x30” commitment — Target 3's
goal of conserving at least 30% of terrestrial, inland water, and coastal/marine areas by 2030 — sits
in direct tension with mineral exploration and development, since Target 1 separately calls for bringing
the loss of areas of high biodiversity importance “close to zero by 2030” through participatory,
biodiversity-inclusive spatial planning
(Convention on Biological Diversity, COP-15 Decision 15/4, Target 1 and Target 3).
For mining specifically, this creates a widening “no-go zone” map as national governments
translate 30x30 into protected-area designations, layering onto ICMM's existing self-imposed World Heritage
Site exclusion under Principle 7.1 and increasing the practical overlap-risk assessment burden on
exploration-stage projects operating near ecologically sensitive land before any mine design work begins.
Current status (July 2026):
ICMM's decade-old no-net-loss commitment now operates alongside a treaty-level corporate disclosure mandate
under KM-GBF Target 15, with national NBSAP updates progressively turning voluntary biodiversity reporting
into statutory obligation. Watch: which jurisdictions convert Target 15 into binding
disclosure law fastest, and whether TNFD-aligned reporting becomes the de facto compliance format.
Last updated: 2026-07-09
Water Inside the Tailings Standard — GISTM's Water-Balance Mandate and IRMA's Closure Rigor
Tailings safety and water stewardship are no longer separate compliance tracks. GISTM
embeds explicit water-balance and water-quality requirements inside its 15 tailings principles, while IRMA's
2018 Standard — now mid-revision toward Version 2.0 — devotes a dedicated chapter to financing
reclamation and closure so costs are not left to communities or the public purse.
1. GISTM's water-balance and water-quality requirements inside the tailings lifecycle
The Global Industry Standard on Tailings Management (GISTM), launched August 2020 by
UNEP, the Principles for Responsible Investment (PRI), and ICMM, embeds water governance directly into its
15 principles and 77 requirements rather than treating water as a separate topic
(Global Tailings Review, Global Industry Standard on Tailings Management).
Technical guidance developed around the standard emphasizes better measurement and management of tailings
storage facility (TSF) water balance as a leading indicator of dam stability risk, since uncontrolled water
ingress or poor water-balance modelling is a recurring contributing factor in tailings failures
(SRK Consulting, Global Standard Prioritises Better Measuring, Managing of TSF Water).
For the passive, post-closure phase specifically, GISTM stipulates that tailings storage facilities must
adhere to the most stringent design criteria available — an annual exceedance
probability of 1-in-10,000 — regardless of the facility's operational consequence
classification, reflecting the reality that a failure decades after closure carries the same downstream
human and environmental risk as one during active operation
(Australian Centre for Geomechanics, Retrospectively Applying the Global Industry Standard on Tailings Management).
Closure design under GISTM must be developed through a multi-criteria alternatives analysis weighing
environmental, social, and safety factors to reduce residual risk to “as low as reasonably
practicable” (ALARP), formally reviewed by a tailings review board or senior independent
technical reviewer, and approved by the site's Accountable Executive before implementation.
2. IRMA's Chapter 2.6: financing reclamation so costs don't fall on communities
The Initiative for Responsible Mining Assurance (IRMA) Standard, first released in 2018
following its founding in 2006, devotes Chapter 2.6, Planning and Financing Reclamation and
Closure, explicitly “to protect long-term environmental and social values and ensure that the
costs of site reclamation and closure are not borne by affected communities or the wider public”
(IRMA, Standard for Responsible Mining — Guidance Document).
The chapter requires that stakeholders be able to comment on a mine's reclamation and closure plan and its
financial surety, with additional consultation triggered where long-term water treatment obligations may
arise post-closure — directly tying water governance into the closure-financing chapter rather than
addressing water only as an operational-phase environmental topic
(IRMA, Standard for Responsible Mining — Guidance Document).
IRMA assigns sites one of four achievement levels — IRMA Transparency (independently
audited, results published), IRMA 50, IRMA 75, and IRMA
100 — based on the percentage of requirements met across the Standard's four principles,
with IRMA 100 requiring full compliance across every chapter including closure financing
(Tallgrass Institute, Indigenous Peoples and the Initiative for Responsible Mining Assurance).
A 2023 draft revision toward IRMA Standard 2.0 proposes consolidating the reclamation and
closure chapter from 28 requirements in the 2018 Standard down to 13, removing duplicative
post-closure financial-surety language while preserving the core financial-assurance requirement that
operators secure funding mechanisms guaranteeing rehabilitation, closure, and post-closure management plans
will actually be paid for and carried out
(IRMA, Draft Standard 2.0: Planning and Financing Reclamation and Closure, Live Consultation).
3. Regional GISTM conformance patterns and disclosure practice in Chile and Peru
Regional GISTM conformance deadlines required all ICMM member companies to bring
“extreme- and very high-consequence” tailings facilities into conformance by August
2023, with all other facilities required to conform by August 2025
(GISTM Blog, Understanding the Global Industry Standard on Tailings Management — Complete Overview).
In practice, Chilean operators including BHP, Teck, and Antofagasta report high alignment
with GISTM, integrating seismic-resistant design codes and filtered (dry-stack) tailings systems suited to
the country's high seismic-hazard profile, while in Peru, companies such as Gold Fields and
Antamina publish facility-level disclosure reports demonstrating conformance and documenting
community engagement at high-altitude tailings sites
(GISTM Blog, Understanding GISTM).
Independent third-party conformance verification is now a standard annual deliverable: South Africa's
Sibanye-Stillwater, for example, published a formal limited-assurance conformance
verification report against all 15 GISTM principles for the 2023 reporting year, illustrating how the
standard's disclosure requirements have moved from self-reported checklists to externally assured
statements comparable to financial audits
(Sibanye-Stillwater, Independent GISTM Conformance Verification 2023).
Current status (July 2026):
GISTM's August 2025 deadline for all non-extreme-consequence facilities has passed, pushing water-balance
and closure-design rigor into routine practice across major mining jurisdictions, while IRMA's Standard 2.0
revision continues to streamline — without weakening — closure-financing requirements.
Watch: IRMA 2.0's final publication timeline and post-August-2025 GISTM conformance audit
results for facilities that missed the deadline.
Last updated: 2026-07-09
Who Pays When a Mine Shuts Down — Closure Bonds in Chile, Peru, and Australia
Closure financial assurance has become the practical enforcement mechanism behind every
biodiversity and water commitment discussed above. Without a bond or bank guarantee sized to the
true cost of rehabilitation, no-net-loss and water-treatment obligations are unenforceable once a company
becomes insolvent or simply walks away.
1. Chile and Peru: Latin America's only comprehensive national closure-bond regimes
According to the International Institute for Sustainable Development's Intergovernmental Forum on Mining
(IGF), Chile and Peru are, to date, the only Latin American countries with comprehensive national
mine closure legislation requiring mining operations to provide financial assurance covering
closure liabilities — Chile under its Mine Closure Law (Ley de Cierre de Faenas e
Instalaciones Mineras) and Peru under its own national mine closure regulatory framework
(IISD, IGF Case Study: Mine Closure Policies in South America).
This regional leadership stands in contrast to jurisdictions such as Argentina, where the IGF and other
legal commentators note that only the Province of San Luis has enacted binding financial-guarantee
legislation — a one-time 7% investment-value payment into an Environmental Guaranty Fund under
Provincial Law No. IX-0634-2008 — leaving most Argentine mining jurisdictions without a mandatory
closure-bond mechanism at all
(Marval O'Farrell Mairal, Closure of Mines: Guarantees).
Both Chile and Peru's systems require site-specific closure plans to include upfront cost estimation and a
corresponding financial-assurance instrument, though the precise bond-calculation formula and permitted
guarantee instruments (cash deposit, bank letter of credit, or insurance bond) are set at the
implementing-regulation level rather than in the primary closure statute itself.
2. Australia: state-by-state divergence in acceptable financial-assurance instruments
Australian mine-closure financial assurance is regulated at the state level with materially different
accepted instruments. Queensland's Mineral and Energy Resources (Financial Provisioning) Act
2018 replaced the prior bond system with a pooled Financial Provisioning Scheme (FPS)
and introduced a mandatory Progressive Rehabilitation and Closure Plan (PRC plan)
requirement for all site-specific environmental authorities relating to mining activities, effective from
1 November 2019
(Queensland Government, Financial Assurance, Provisioning and Rehabilitation for Resource Activities).
Victoria currently accepts only an unconditional bank guarantee as its
sole financial-assurance mechanism, with rehabilitation bonds set at 100% of the estimated
rehabilitation cost, standard exploration-licence bonds fixed at AUD 10,000, and
cash bonds permitted only up to AUD 50,000
(Resources Victoria, Rehabilitation Bonds — Minerals Exploration, Mines and Quarries).
Western Australia continues to rely primarily on surety (performance)
bonds, while New South Wales permits bank guarantees, insurance bonds, cash, or
combinations thereof, and South Australia accepts either a bank guarantee or a
rehabilitation bond
(IISD, Global Review: Financial Assurance Governance for the Post-Mining Transition).
Queensland separately layered on “chain of responsibility” legislation via the
Environmental Protection (Chain of Responsibility) Act 2016 (Qld), extending
rehabilitation liability to any individual or related entity connected to the company that caused the
environmental degradation — a mechanism designed specifically to prevent shell-company insolvency
from letting mining rehabilitation obligations go unfunded
(Australasian Legal Information Institute, Examination of Mining Site Rehabilitation).
3. Why bond design matters: full-cost coverage versus underfunded legacy liabilities
The core policy tension across all three jurisdictions is whether bonds are sized to actual
full closure cost or merely to a discounted estimate that leaves a funding gap if the operator
defaults. Victoria's rule that a rehabilitation bond must reflect 100 per cent of the estimated
rehabilitation cost, with the state explicitly empowered to complete the rehabilitation itself
using bond proceeds if an operator cannot meet its obligations, represents one of the more conservative
full-cost models
(Resources Victoria, Rehabilitation Bonds).
This full-cost design logic mirrors IRMA's Chapter 2.6 principle that closure costs must not fall on
communities or the public purse, and increasingly informs how GISTM-conforming operators size their own
post-closure water-treatment financial-assurance provisions where perpetual or long-duration water
treatment is anticipated after a tailings facility's active life ends.
Current status (July 2026):
Chile and Peru remain the only Latin American jurisdictions with comprehensive national closure-bond law,
while Australian states continue to operate divergent financial-assurance regimes rather than a harmonised
national standard. Watch: whether other Latin American jurisdictions follow Chile/Peru's
lead, and continued scrutiny of whether existing bond levels genuinely cover full closure and post-closure
water-treatment costs.