From voluntary to binding: Integration of sustainability standards and initiatives in public mining governance
This report examines the integration of sustainability standards and initiatives (SSIs) into public mining governance. Through surveys and case studies in Brazil, Madagascar, and Sweden, it demonstrates how voluntary standards complement mandatory regulations to address environmental, social, and governance risks, supporting policy formulation, implementation, and transparent reporting.
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OVERVIEW
The mining and minerals sector generates high economic value but is associated with significant environmental, social, and governance (ESG) risks. This report examines how sustainability standards and initiatives (SSIs) are being integrated into public mining governance to help governments address these challenges. It argues that SSIs and mandatory regulations are interlinked and can be mutually reinforcing. By using three case studies from Brazil, Madagascar, and Sweden, the report demonstrates how SSIs can complement and strengthen public regulatory instruments under the right conditions.
1.1 What are SSIs?
SSIs refer to rules, mechanisms, and tools developed by businesses, industry associations, or non-governmental organisations designed to assess and verify sustainability performance along global value chains. While many SSIs are voluntary market-based tools, they increasingly comprise a combination of sustainability requirements, assurance, and verification processes. These tools allow economic actors to choose production and processing practices that are more sustainable, often facilitating market access and product differentiation in return for compliance.
1.2 Evolution of SSIs in the mining sector
The history of mining SSIs began in the early 1990s with multistakeholder efforts such as the Whitehorse Mining Initiative. The landscape has since grown to include 158 active SSIs as of 2025, which vary in focus and objective. These initiatives are broadly categorised into three types: supply chain due diligence SSIs, performance or compliance SSIs, and principle-based SSIs. Driven by market demands for sustainable raw materials and investor willingness to consider non-financial indicators, governments have increasingly integrated these tools into sectoral policies, trade agreements, and sustainable procurement measures.
1.3 SSIs in mining sector public policy
An Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) survey conducted in early 2025 found that 89% of respondents who integrated SSIs used them as a foundation for drafting or revising policies and legislation. Furthermore, 34% of respondent countries reported that SSIs are directly referenced as mandatory requirements in regulations or offered as optional proof of legal compliance. Despite this growth, 83% of respondents highlighted the need for additional training and institutional capacity to effectively incorporate SSIs into national frameworks. The integration of these initiatives primarily occurs at the policy implementation stage, though they also play roles in policy formulation and reporting.
2.0 Case studies: overview
Three case studies were selected to illustrate the interplay between SSIs and public policy across different governance contexts. These include the Global Industry Standard on Tailings Management (GISTM) in Brazil, the Extractive Industries Transparency Initiative (EITI) Standard in Madagascar, and the Global Reporting Initiative (GRI) in Sweden. Together, they demonstrate how governments engage with SSIs across different stages of the policy cycle, ranging from voluntary alignment to mandatory regulatory incorporation.
3.0 Case study 1: the GISTM in Brazil
The GISTM was launched in 2020 in response to catastrophic tailings dam failures, including the Brumadinho collapse in Brazil. In 2022, Brazil’s National Mining Agency (ANM) introduced Resolution No. 95/2022, which used the GISTM as a technical reference. With over 900 registered tailings dams, Brazil’s regulatory reform aimed to strengthen oversight. While the resolution aligns with GISTM requirements, such as governance structures and independent reviews, Brazilian law established stricter obligations in certain areas, such as the prohibition of upstream dams. This case illustrates the use of an SSI as a technical and conceptual reference for strengthening domestic regulation.
4.0 Case study 2: the EITI standard in Madagascar
In 2022, the mining sector represented 4.5% of Madagascar’s GDP and 43.8% of its total exports. Madagascar integrated the EITI Standard’s beneficial ownership requirements into its 2023 Mining Code, shifting these disclosures from a voluntary practice to a legal obligation. The code defines a beneficial owner and sets a 5% ownership disclosure threshold, aligning with EITI recommendations. This integration ensures that all mining permit holders must publicly disclose ownership information, contracts, and payments to the state, thereby strengthening transparency and accountability in a sector often challenged by informality and illicit gold exports.
5.0 Case study 3: the GRI in Sweden
Sweden has a long mining history, with state-owned enterprises (SOEs) like LKAB playing a central role. In 2007, the Swedish government mandated the use of the GRI Standards for all SOEs to address a governance gap in sustainability reporting. Between 2007 and 2008, reporting in accordance with GRI rose from 14% to 89% among Swedish SOEs. This case highlights how an internationally recognised reporting standard can be embedded into state ownership policy as a binding governance instrument, enabling standardised assessment of ESG impacts across a diverse portfolio of state-owned assets.
6.0 Key takeaways
The report concludes that governments are increasingly using SSIs to complement national mining governance, particularly where regulatory gaps exist. SSIs are most effective when used as complementary instruments that reinforce, rather than replace, public regulation. Key pathways for integration include serving as a foundation for drafting laws, being referenced as proof of compliance, or being explicitly mandated in administrative requirements. Policy-makers are encouraged to identify SSIs relevant to national priorities, systematically assess their value within the policy cycle, and strengthen institutional capacity for oversight and data interpretation.