Engineered tailings and water-management infrastructure at a mine site.
By Penny Langford | Deep-dive analysis
For mining companies, ESG reporting is moving from the sustainability department into financial controls, operating risk and board oversight.
In 2026, the compliance landscape is being shaped by five overlapping developments: IFRS S1 and S2 adoption across more than 20 jurisdictions, CSRD double materiality, the GRI 14 Mining Sector Standard, rising expectations for GISTM tailings conformance and California’s SB 253 emissions reporting law.
The practical challenge is not simply publishing another sustainability report. It is building one evidence-backed data system that can support regulators, investors, auditors, lenders, communities and mine-site managers.
Mining ESG compliance 2026 at a glance
| Framework or rule | Status in 2026 | Core requirement for mining companies |
|---|---|---|
| IFRS S1 and S2 | Adopted or made available on a mandatory or voluntary basis in more than 20 jurisdictions; 40-plus jurisdictions have adopted, are using or are preparing to introduce ISSB standards | Disclose material sustainability and climate-related risks, opportunities, governance, strategy, metrics and targets |
| EU CSRD and ESRS | Mandatory for entities within scope, subject to EU phase-in and 2026 legislative changes | Apply double materiality: assess both financial effects and impacts on people and the environment |
| GRI 14: Mining Sector 2024 | Effective for reports or materials published on or after January 1, 2026 | Provide sector-specific impact disclosures covering mining activities, communities, biodiversity, waste, closure and human rights |
| GISTM | Industry standard rather than a government regulation | Demonstrate lifecycle governance and risk controls for tailings storage facilities |
| California SB 253 | Applies to qualifying US-organized entities doing business in California | Report Scope 1 and Scope 2 emissions from 2026, followed by Scope 3 reporting from 2027 |
The distinction between adoption, alignment and enforceable reporting is important. The IFRS Foundation’s jurisdictional guide tracks countries that have adopted, are using or are introducing ISSB-based requirements. However, effective dates, assurance expectations and the companies covered vary by market.
ISSB IFRS S1 and S2 become the global baseline
IFRS S1 covers general sustainability-related financial disclosures. IFRS S2 focuses specifically on climate-related risks and opportunities. Both standards are effective for annual reporting periods beginning on or after January 1, 2024, although local adoption schedules differ.
The standards ask whether sustainability-related information could reasonably affect a company’s cash flows, access to finance or cost of capital. For miners, that brings issues such as water stress, extreme weather, carbon pricing, energy costs, biodiversity constraints and community opposition into the same risk architecture as production, currency and commodity-price assumptions.
A mining company preparing for ISSB-aligned reporting should be able to explain:
- How the board oversees climate and sustainability risks.
- Which physical and transition risks affect assets and mine plans.
- How those risks influence capital expenditure and operating costs.
- What assumptions support transition plans and emissions targets.
- How Scope 1, Scope 2 and Scope 3 emissions were calculated.
- Which metrics are subject to internal controls or external assurance.
Scope 3 remains one of the most difficult areas. Emissions may arise from contractors, explosives, steel, shipping, smelting, refining, customer use and other downstream activities. The data often sits outside the company’s direct operational boundaries, requiring consistent supplier and customer methodologies.
Mining groups operating across Australia, Brazil, Chile, Mexico, the United Kingdom, Singapore, Hong Kong and other adopting markets may need a consolidated ISSB-aligned data architecture, even when local rules use different names or phase-in periods.
CSRD double materiality adds the impact lens
The EU Corporate Sustainability Reporting Directive and European Sustainability Reporting Standards use double materiality. A topic is material if it is financially significant, has a significant impact on people or the environment, or meets both tests.
That is particularly important for mining.
A tailings facility may create a serious potential impact on downstream communities before the risk appears in a financial model. Water withdrawals may affect local users and ecosystems even if the mine remains profitable. Biodiversity loss may delay permits, restrict expansion or increase closure liabilities, creating both impact and financial materiality.
The two lenses are:
- Financial materiality: How sustainability matters affect the company’s development, performance, position, cash flows, access to finance or cost of capital.
- Impact materiality: How the company affects people, communities and the environment through its operations and value chain.
In-scope mining companies should maintain evidence showing:
- Which sites, projects and value-chain activities were assessed.
- How affected communities, Indigenous groups and other stakeholders were identified.
- The thresholds used to evaluate severity, likelihood and financial effect.
- Why a sustainability topic was included or excluded.
- How the assessment connects with enterprise risk management and capital allocation.
The European Commission’s CSRD reporting page and EFRAG implementation guidance remain important references because the scope, phase-in rules and reporting requirements continue to develop.
For mining companies, likely material topics include climate change, pollution, water, biodiversity, resource use, waste, worker health and safety, affected communities, Indigenous rights and mine closure. A generic group-wide assessment is unlikely to capture the different risks of a copper operation in a water-stressed basin, a rare earths project near sensitive habitat or an underground mine close to populated areas.
Tailings monitoring systems provide evidence for operational risk and external reporting.
GRI 14 makes mining impacts more specific
GRI 14: Mining Sector 2024 is effective for reports or other materials published on or after January 1, 2026, according to the Global Reporting Initiative.
GRI 14 applies to organizations involved in mineral exploration, extraction and primary processing, excluding oil, gas and coal. It is not a government regulation, but it becomes relevant when a mining company reports in accordance with GRI.
The standard helps structure disclosures around mining-specific impacts, including:
- Tailings and mine waste.
- Biodiversity and land disturbance.
- Water and pollution.
- Indigenous peoples and affected communities.
- Artisanal and small-scale mining.
- Human rights and conflict-affected areas.
- Mine closure and post-closure obligations.
GRI 14 is impact-focused, while ISSB is primarily investor-focused. CSRD sits across both dimensions through double materiality. A company should not treat the three frameworks as separate reporting projects. The same site-level evidence can often support all three, provided the boundaries, definitions and materiality conclusions are documented clearly.
GISTM tailings conformance is becoming a board metric
The Global Industry Standard on Tailings Management is built around six topic areas, 15 principles and 77 auditable requirements. It covers governance, facility design, operation, monitoring, emergency response, stakeholder engagement, closure and post-closure management.
GISTM is not an IFRS or CSRD regulation. It is an industry standard, but its influence extends into lending, insurance, investor due diligence and community scrutiny.
The latest public ICMM benchmark reports:
- 67% full conformance across 836 tailings facilities at ICMM member companies.
- More than 80% full conformance among facilities classified as having “extreme” or “very high” potential consequences.
- 53% to 65% conformance among lower-consequence categories.
The often-cited 65% to 85% range should therefore be treated as a shorthand for different facility-risk groups, not as a single sector-wide average. ICMM’s official figures do not establish 85% overall conformance.
For 2026, mining companies should report more than a percentage. They should identify the facilities covered, consequence classifications, independent reviews, known gaps, corrective action plans and the individuals responsible for closing them.
Water treatment and recycling infrastructure supports both compliance and operational resilience.
California SB 253 adds a separate emissions obligation
California’s SB 253 Climate Corporate Data Accountability Act applies to qualifying partnerships, corporations, limited liability companies and other US-organized entities with more than $1 billion in annual revenue that do business in California.
The first reporting cycle requires:
- Scope 1 and Scope 2 emissions reporting in 2026.
- A current first-year submission deadline of November 10, 2026, under California Air Resources Board implementation materials.
- Scope 3 reporting from 2027, subject to the statutory timetable and implementing requirements.
- Independent assurance that increases over time.
The law is narrower in entity scope than many multinational mining groups assume: foreign-organized companies are not automatically covered solely because they sell into California. However, a US-organized subsidiary or holding company may be in scope if it meets the revenue and California nexus tests.
Companies already preparing IFRS S2 or ESRS E1 disclosures should use the same controlled emissions inventory where possible, while checking differences in organizational boundaries, fiscal years, assurance and filing formats.
Mining ESG compliance 2026 checklist
| Control area | Questions mining leaders should answer | Evidence to retain |
|---|---|---|
| Jurisdictional scope | Which entities, listings, assets and subsidiaries are covered by ISSB, CSRD, GRI or SB 253? | Legal-entity map, revenue tests and reporting calendar |
| Materiality | Which topics are financially material, impact material or both? | Board-approved methodology, stakeholder inputs and assessment records |
| Emissions | Can reported Scope 1–3 figures be traced to source data? | Fuel, electricity, contractor, logistics and supplier records |
| Water | Are withdrawals, consumption, recycling and discharge linked to catchment conditions? | Metering data, laboratory results, water-stress assessments |
| Tailings | Is each facility classified, monitored and assigned to accountable roles? | GISTM assessments, engineer reviews, emergency plans and gap registers |
| Biodiversity | Are impacts measured against credible site baselines? | Habitat surveys, disturbance maps, restoration and closure monitoring |
| Communities | Are grievances, resettlement, Indigenous rights and benefit-sharing tracked? | Consultation records, grievance logs and remediation actions |
| Assurance | Can an auditor reproduce material figures and management judgements? | Data dictionary, control testing, sign-offs and audit trail |
The operational priority is data quality
The strongest 2026 compliance programs will not be built around a single ESG software purchase. They will be built around consistent definitions, accountable data owners and reliable site-level controls.
A practical sequence is to:
- Map obligations by entity, jurisdiction and reporting period.
- Run one documented double-materiality process.
- Create a controlled data dictionary for emissions, water, tailings, social and biodiversity metrics.
- Assign executive and site-level owners for every material disclosure.
- Test reported figures back to operational records before assurance begins.
For mining companies, ESG compliance is becoming inseparable from mine planning, permitting, financing and operational resilience. The question is no longer whether sustainability information belongs in the financial control room. It is whether the data reaching that room is consistent, traceable and decision-useful.
For related coverage, see Skillings’ reporting on mining regulation, mining operations and mining technology.