By the IEMA – Integrating Sustainability, Business & Community

A complex industrial closure was approaching the hard part, proving it would remain safe, stable, and compliant in an environment where climate change may move the goal posts in the long term future. IEMA – Integrating Sustainability, Business & Community was brought in to answer the question regulators, investors, and communities are all asking: Will this plan still work in 2050?

The brief

Stress-test a full closure plan end to end against plausible climate futures. Translate the findings into concrete actions that shorten the road to sign-off and reduce surprises after handover.

What we did

• Followed the evidence, not the vibe. We assessed risks under IPCC RCP 2.6, 4.5, 8.5 to 2050, aligned to national sustainability reporting expectations.
• Broke down silos. Hydrology, geotech, ecology, climate science, and socio-economics were integrated, because landforms, water, and community impacts don’t behave in isolation.
• Tested what matters. We looked for climate assumptions inside designs and models, covers, caps, retention basins, seals, water balances, flood modelling, not just mentioned in the narrative.
• Rated controls the way auditors do. Likelihood × consequence across environmental, social, operational, financial, and reputational dimensions, with clear evidence trails.

What we found

• 19 material risks surfaced: 11 physical (stability, potential subsidence/sinkholes, erosion, surface–groundwater interactions, retained infrastructure) and 8 transition (regulatory shifts, disclosure, reputation, residual-risk governance).
• The pattern: Many controls were in progress or untested. The work had started, but assurance and climate scenario integration weren’t yet bulletproof.

Commercial impact: Untested controls and ambiguous residual risk are what delay relinquishment. Fixing them brings timelines forward and reduces cost-of-waiting.

The 10 recommendations that changed the trajectory

Here’s where the assessment turned into momentum. We translated risk into ten concrete recommendations, design tweaks, modelling upgrades, and governance shifts, that hard-wired climate futures into the closure program and removed the roadblocks to sign-off. In short: practical steps, clear owners, measurable outcome

1. Bake climate futures into design specs (RCP 2.6/4.5/8.5) for covers, caps, drainage, storage.
2. Stand up post-execution monitoring & maintenance with KPIs, triggers, and a realistic budget.
3. Lock corporate–project alignment on required scenarios and disclosures.
4. Define a residual-risk framework (ownership, funding, monitoring, reporting).
5. Re-run flood modelling on the final landform under RCP 4.5/8.5 to validate basin sizing and spillways.
6. Couple the water balance (surface + groundwater) for post-closure conditions with climate inputs.
7. Resolve heritage infrastructure pathways to remove safety/liability ambiguity.
8. Inform seal designs with hydrogeology that reflects future groundwater behaviour.
9. Adopt climate-ready revegetation (species mix, establishment, success criteria, adaptive management).
10. Institutionalise regulatory horizon-scanning between corporate and site teams.

Results that matter to decision-makers

For decision-makers, the outcomes are clear: residual risk needs to be acceptable across all climate scenarios; climate futures are required to be embedded as traceable design inputs and validated against extremes; governance needs to be audit-ready with defined roles, artefacts, and decision trails that build regulator and investor confidence.

When to reopen the file (so you don’t get caught out)

There is a need to reopen the assessment whenever the ground shifts, think changes to IPCC scenario assumptions or national reporting rules; updates to closure methodology, final landform, or land use; modifications to water infrastructure or its performance; heightened sensitivity of nearby community assets; or revised corporate risk appetite and disclosure expectations.

The takeaway

If your closure case hinges on “we think this will hold,” expect delays. If it demonstrates how it holds across plausible futures, with evidence in the specs, budgets, and governance, approvals get simpler, and handover gets faster.

Considering a closure in 2025?

IEMA – Integrating Sustainability, Business & Community helps asset owners prove climate resilience, compress approval timelines, and de-risk handover with a practical, evidence-first playbook. If you want your next regulator meeting to start with “we’ve already tested that,” let’s talk.

By Andrew Hutton (based on work by Will Mitry and Erin Littlewood presented at the 2025 AusIMM LOM Conference, Brisbane.

In an era of rising environmental expectations, regulatory scrutiny, and climate uncertainty, mine closure is no longer a back-end activity. It is a forward-thinking process that must embed resilience, accountability, and nature-positive outcomes from the outset. At the forefront of this transformation are spatial data systems, practical technologies that integrate geographic, environmental, and operational data into intelligent frameworks to support better closure decisions.

That’s why two (2) new spatial intelligence platforms, IMERCS and EcoScenario, developed by staff at IEMA – Integrating Sustainability, Business & Community are gaining momentum. Both are built in Australia, field-tested on operational sites, and developed by mining and closure professionals for mining and closure professionals. Remember “we have walked in your shoes”. Together, they offer a new standard for closure compliance, resilience, and biodiversity performance.

The Shift: Why Spatial Intelligence Matters to mine closure planning

Traditional mine closure systems often rely on disparate data sources, manual workflows, and regional climate assumptions. These legacy approaches struggle to:

• Track evolving closure obligations
• Capture and retain institutional knowledge
• Assess future climate and biodiversity risks
• Demonstrate compliance and performance to regulators

Spatial data systems overcome these limitations by:

• Centralising structured and unstructured environmental data
• Embedding GIS, AI, and automation into operational workflows
• Enabling high-resolution, site-specific modelling
• Supporting transparent, real-time reporting and audit readiness

IMERCS: An Intelligence System for Closure Compliance

IMERCS (Integrated Mining, Environmental, Rehabilitation and Closure System), developed by IEMA in partnership with Whitehaven Coal, is a modular, cloud-based platform built on:

• AWS Cloud Infrastructure – Scalable, secure, and globally deployable
• ESRI ArcGIS – For spatial data integration and visualisation
• OpenAI APIs – To enable AI-driven document interrogation and regulatory reasoning
• FME (Feature Manipulation Engine) – For data automation, transformation, and ingestion across systems

It integrates management plan obligations with execution records, using spatial intelligence, automated workflows, and AI agents to support mine closure and rehabilitation. IMERCS operates on a Plan-Do-Check-Act cycle. IMERCS offers a suite of 13+ configurable modules that can be tailored to site needs. These include:

• Environmental Monitoring: Tracks surface water, groundwater, dust, flora and fauna parameters spatially and temporally
• Rehabilitation Planning and Tracking: Links design with actual performance through drone surveys, NDVI analysis, and milestone tracking
• ePTW (electronic Permit-to-Work): Integrated with spatial constraints and biodiversity overlays
• Cultural Heritage and Subsidence Management: Maps sensitive areas and ensures protection during closure activities
• Closure Cost Estimation: Uses spatial metrics and schedule data to refine provision forecasts
• Regulatory Reporting: Generates automated reports aligned with State and Federal regulations

A standout feature is the AI toolkit embedded in IMERCS:

• IMERCS GPT: Parses management plans, execution records, and survey data to surface compliance status, overdue actions, and misalignments.
• Audit AI: Assists in regulatory audits by extracting and comparing obligation fulfillment across time.
• Regulator GPT: Crosswalks internal documentation with regulatory frameworks to highlight gaps or inconsistencies.
• RehabEye AI (in development): Uses machine learning on drone imagery to assess erosion, vegetation cover, and landform stability.

At Narrabri Coal Operations, IMERCS processed 100+ digital ePTWs without incident, delivered >95% rehab success in key zones, and impressed regulators with its audit readiness.

EcoScenario: Designing for Nature-Positive Closure

Presented at Life of Mine 2025, EcoScenario is IEMA’s GIS-based closure simulation platform. It lets planners model landform and biodiversity performance under future climate conditions, using real site data, not regional proxies. The platform is also being developed to integrate the requirements of mandatory climate reporting into closure planning and can be supported by a detailed climate change risk assessment tailored to site-specific exposures.

EcoScenario is a GIS-based platform that:

• Operates at a 5m x 5m grid resolution for terrain, habitat, and climate inputs
• Utilises IPCC RCP Scenarios (2.6, 4.5, 8.5) to simulate possible climate futures
• Integrates species movement models, fire/flood risk overlays, and hydrological algorithms
• Provides interactive visualisation layers for stakeholder engagement and adaptive design

Core Applications

• Biodiversity Offsets and Connectivity: Models future species corridors, habitat recovery, and edge effects
• Landform Evolution: Simulates erosion, slope stability, and drainage performance under extreme events
• Climate Risk Assessment: Evaluates exposure to cyclones, fire weather, drought stress, and inundation
• Stakeholder Planning: Produces interactive maps and scenario narratives for Traditional Owners, regulators, and communities

Case Studies:

The power of spatial intelligence lies not just in its technical sophistication, but in its practical impact on the ground. IMERCS and EcoScenario have been deployed at active mine sites across diverse geographies and operational contexts, where they are helping closure teams move from static plans to adaptive, data-driven strategies.

The following case studies demonstrate how these platforms can be used to:

• Translate complex closure objectives into spatially targeted actions
• Anticipate environmental risks under future climate scenarios
• Improve regulator confidence through transparent, auditable data
• Deliver measurable ecological outcomes that go beyond compliance

These examples reflect the evolving role of closure professionals—not just as stewards of compliance, but as strategic designers of post-mining landscapes

Hunter Valley, NSW

EcoScenario helped reimagine the post-mining land use from low-productivity grazing to a 570-hectare native woodland corridor, increasing habitat connectivity by 20% and aligning with local biodiversity targets.

North Queensland

Under cyclonic rainfall simulations, EcoScenario identified vulnerabilities in legacy drainage design. Redesign efforts, guided by platform outputs, ensured tailings dam resilience under 1-in-200-year rainfall events

Lessons from the Field: What Makes These Systems Work?

1. Site-Specific Data Over Regional Proxies

Both IMERCS and EcoScenario anchor their intelligence in on-site monitoring and survey data—enabling precise, confident decision-making.

2. Embedded into Operational Workflows

IMERCS integrates seamlessly with daily site operations, connecting rehabilitation teams, planners, and environmental specialists. EcoScenario feeds directly into closure visioning, risk assessments, and community consultation tools.

3. Scalable and Modular Architecture

IMERCS adapts across different operations—from open-cut coal to metalliferous mines—with a plug-and-play module framework. EcoScenario can be calibrated for any terrain, landform objective, or regulatory jurisdiction.

4. AI and Automation

From GPT-powered audits to drone-based landform analytics, the platforms minimise manual effort, maximise insight, and accelerate response times.

Looking Ahead: The Spatial Data Advantage

As mining companies face growing expectations from investors, regulators, communities, and nature itself, the ability to demonstrate closure outcomes will be key to maintaining social license.

Spatial data systems offer:

• Data-driven compliance tracking and audit readiness
• Nature-positive design that restores ecosystems, not just landform
• Risk visibility for climate adaptation and liability management
• Stakeholder transparency to build trust and accountability

Closing Thoughts: Turning Risk into Readiness

Mine closure is no longer the final chapter; it’s a live process unfolding over decades. The most effective practitioners will be those who can turn complexity into clarity, using tools that speak the language of both regulators and ecosystems.

IMERCS and EcoScenario aren’t just technologies, they’re strategies. They’ve been built with real closure constraints in mind, tested on operational sites, and designed to evolve as the expectations do.

If you’re in the closure game, now is the time to upgrade your toolkit—not just to meet obligations, but to lead the transition to transparent, resilient, nature-positive mining.

Want to see how these tools can work at your site?

Erin Littlewood – Principal Consultant, IEMA [email protected]

Will Mitry – Associate Consultant, IEMA [email protected]

By Andrew Hutton – Managing Director, IEMA

In the world of mining, extraction is only half the story. The other half – often less glamorous but just as critical – is what happens when the digging stops and how we can contemplate the transition of mine sites to a beneficial reuse that generates employment and supports the regional economies surrounding it.

Across New South Wales, a quiet transformation is underway. Mines are maturing, leases are winding down, and the industry is shifting from boom-and-bust to something more measured: legacy management, rehabilitation, and ultimately, relinquishment.

But if you’ve ever tried navigating the maze of mining lease sign-off in NSW, you’ll know it’s not just a matter of ticking boxes and walking away. Nor should it be.

The Missing Piece? Evidence

At the heart of the process is evidence, not intent, not effort, but cold, hard proof squarely based on a firm base of a solid and robust risk assessment.

In our experience, the NSW Resources Regulator wants to see that every risk has been controlled, every contour restored, and every patch of land returned to a safe, stable, and sustainable state. That means having a robust Rehabilitation Management Plan, documented works, and a rigorous level of verification.

This is where Inspection and Test Plans (ITPs) come into their own. Too often treated as back-office admin, they’re actually the backbone of the entire process. ITPs show how each rehabilitation activity was executed, assessed, and verified. They create the traceability regulators need to say “yes.”

Without structured, consistent records management, it’s impossible to demonstrate compliance confidently. Strong projects are now building their Relinquishment Assurance Reports (RARs) off carefully curated evidence chains supported by ITP completion data—not guesswork.

It’s Also Intelligent Use of Spatial Tech

Gone are the days when relinquishment was tracked in folders and memory sticks. Today, spatial data systems are driving decision-making, visualising what areas are ready for submission, overlaying verification data, and identifying gaps.

Smart operators are using GIS platforms to:

• Map completion criteria against real-time landform data
• Identify high-risk zones like tailings facilities
• Track forward works with geospatial accuracy
• Collect evidence spatially
• Use AI to generate workflows and match site obligations

This spatial intelligence isn’t just a visual tool – it’s a strategic asset. It helps teams prioritise work, engage with regulators using evidence, and communicate progress with stakeholders.

It’s a Project and a Strategy

Too often, companies treat relinquishment as the final checkbox on a closure plan. In reality, it’s a standalone project – with its own scope, resources, and risks. It’s big, the dollars are material – treat it like it’s a $50M project, not a rehab job. Establish governance, processes and IPRs. Move along the project pathway of Concept, PFS and Feasibility – and give yourself plenty of time to pivot whilst you have budget, cashflow, kit and people on site.

The most forward-thinking operators are treating relinquishment as a strategic opportunity. They’re using spatial analysis to map areas for early sign-off and getting them through the process ahead of time. Using the processes to build credibility with stakeholders is key. They’re integrating post-mining land use into their plans. They’re even lining up rezoning applications and new approvals alongside ESF2 submissions to unlock future land value and direct the relinquishment of the site towards a known beneficial reuse – which narrows the breadth of “what ifs” and options.

It’s about transitioning an asset, not just closing a liability.

Regulator Engagement Matters

One of the most underappreciated aspects of the process? Genuine Dialogue.

The best outcomes come when operators engage early and transparently with the regulator – presenting draft RARs, discussing land use transitions, and clarifying long-term residual risk management strategies.

These conversations aren’t about box-ticking—they’re about building alignment. When done well, they remove ambiguity, build confidence, and streamline the ESF2 process.

The Future of Mine Closure Is Professionalised

We’re entering an era where closure and relinquishment are treated with the same rigor as development and operations. It’s now a specialty and it requires project managers who can move across all technical issues and challenges. Subject Matter Experts (SMEs) are essential, but it’s much more than designing a cap, reviewing a landform, modelling water, or engaging with community—it’s about meshing it all together and managing risk.

That means:

• Project-managed relinquishment pathways
• Project governance and processes
• Detailed and dynamic risk assessments
• Dedicated specialists in spatial, rehab, risk, and land use
• Robust ITPs and digital evidence systems
• Transparent reporting and regulator engagement

It’s no longer enough to “rehab and hope.” Companies need to verify and validate – and they need to prove it with systems that hold up under scrutiny.

As more NSW operators edge closer to end-of-mine life, the conversation is shifting from “how do we comply?” to “how do we exit well?”

That’s not just a compliance challenge – it’s a reputational and strategic opportunity. And for those who get it right, relinquishment doesn’t mark the end, nor does it need to be made hard and drag on. Holding costs for mining leases are material, and care and maintenance does not mean no costs. It marks the handover to what comes next, whether that’s conservation, community benefit, or commercial redevelopment.

Andrew Hutton is Managing Director of IEMA, an environmental and closure advisory firm based in regional NSW. He has nearly 30 years’ experience in mine closure strategy, regulatory approvals, and stakeholder engagement.

As New South Wales inevitably confronts the question of what becomes of our former mine sites is no longer academic. Across the Hunter and other regions, vast tracts of land previously dedicated to extraction are now nearing or at the end of their operational life. What happens next will define not just landscapes, but regional economies, investment pipelines, and community futures.

The good news? NSW is well-positioned to lead the nation in defining what successful post-mining land use looks like.

While mine closure has historically been treated as a compliance task focused on stabilising slopes, replanting vegetation, and ticking regulatory boxes, it is increasingly being recognised as an opportunity to reshape regions for the better. But realising that opportunity requires a shift in mindset, backed by a coherent policy framework and coordination across agencies and stakeholders.

From my experience advising on closure projects across Australia and internationally, I believe NSW’s path forward hinges on five strategic imperatives.

1. Address the Residual Risk Barrier
2. Define Post Mining Land Use at the start, not the end
3. Coordinate the maze of Government Approvals
4. Build on the strategic momentum already underway
5. Learn from best practice across Australia and beyond.

1. Address the Residual Risk Barrier
The most persistent challenge in repurposing former mining land is the issue of residual risk. Even when a site is rehabilitated to meet regulatory requirements, uncertainty about long-term liabilities, such as tailings facilities, large dams, water quality in final voids, underground subsidence, or contamination. They can stall land handover indefinitely. This ambiguity deters both regulators and private investors.

NSW urgently needs a clear, proportionate framework to assess and manage these risks and, where appropriate, enable risk transfer mechanisms. Without this, many sites will remain in limbo, with potential unrealised.

2. Define Post-Mining Land Use at the Start, Not the End
A second, and often overlooked, challenge is the lack of early consensus on future land use. Too often, rehabilitation efforts are designed around technical parameters rather than a concrete vision for how land will be used post-mining. Is the goal agricultural productivity? Renewable energy generation? Biodiversity offsets? Community infrastructure?

Agreeing on this at the outset or during the operational phase of mining allows closure criteria to be tailored to real-world outcomes, streamlines approvals, and gives future users, whether developers, councils or the community, greater certainty. By achieving early approval for post mining land use enables the mining to partner with the developer and the “goal-posts” on hazards and risk are clearly defined. A pathway to approval certainty also makes investment attraction much easier.

3. Coordinate the Maze of Government Approvals
The complexity of the post-mining regulatory environment is well known. In NSW, responsibilities for closure touch at least a half-dozen agencies from Resources and Planning to the EPA and Water. With no single authority responsible for coordination, delays, duplication, and inconsistent advice are inevitable.

There is a strong case for a coordinating body perhaps a dedicated taskforce within a single Department with a clear remit to lead on post-mining land transition. This could include establishing a closure strategy review process at key planning and environmental assessment stages.

4. Build on Strategic Momentum Already Underway
NSW isn’t starting from scratch. The last 3-5 years has seen a material change in thinking and a real alignment to starting to strategically think about the post mining world. Not just by the miners, but by local governments, communities, think-tanks, Universities, now the wider community. For example, the Hunter Regional Plan 2041 explicitly addresses post-mining land use, highlighting the role of former mine sites in supporting energy transition and industrial innovation.

Meanwhile, the Hunter Joint Organisation (HJO) has developed a $20 million proposal to deliver:

• Place-based mine closure strategies
• A regional audit of mining lands and infrastructure
  \Master plans for legacy sites in Singleton, Muswellbrook, and Lake Macquarie

This local-regional alignment with state planning signals a shift in how mine closure is approached, not just as environmental remediation, but as part of long-term economic development.

5. Learn from Best Practice Across Australia and Beyond
WA and Queensland offer useful templates. In WA, closure planning must now include an agreed post-mining land use, while Queensland’s residual risk payment scheme (whilst not without its challenges) aims to offe a transparent way to manage liabilities after relinquishment. Canada and Germany also offer structured models for verification, transition governance, and post-closure funding.

NSW can adapt these lessons, but also improve upon them by ensuring local governments, mining companies and private developers are part of the planning conversation from the outset.

Post-mining land use is not just about safe closure; it’s about successful transition. NSW has the vision, the groundwork, and the regional leadership to become the benchmark in this space. What’s needed now is execution.

With the federal election behind us, Australia stands at an important crossroads for environmental reform and climate policy. Over the past term, we saw the Government attempt a bold overhaul of environmental laws and climate frameworks – many of which faced roadblocks in Parliament. As the newly re-elected Government settles in, the direction it takes now will have a lasting impact on the country’s climate commitments, biodiversity outcomes, and transition to renewable energy.

While details remain to be seen, now is a key time for businesses, industry leaders and environmental practitioners to stay engaged and contribute to consultations as these policies evolve.

Where Are We Headed?

Here are the major themes and expectations shaping the road ahead:

• Climate Targets: The Government is holding the course on its net zero by 2050 ambition and 2030 emissions reduction target (43% below 2005 levels). The Climate Change Authority will guide the setting of a 2035 target, as required under existing law.
• Renewable Energy Push: Building on the Powering Australia Plan, the target remains for renewables to provide 82% of the National Electricity Market by 2030. The Government has pledged a further $8 billion in investment via the Clean Energy Finance Corporation to accelerate the shift to low-emissions technology – firmly opposing nuclear as an alternative.
• Nature Positive Reforms – Still in Play?: After ambitious reforms to the Environment Protection and Biodiversity Conservation (EPBC) Act stalled during Labor’s last term, it’s unclear how far the next wave of environmental reforms will go. That said, Prime Minister Albanese has confirmed that reform is still on the agenda, albeit in a revised form. Importantly, the commitment to biodiversity protection remains, supported by a $262 million pledge over five years to meet the ’30 by 30′ conservation target – protecting 30% of Australia’s land and marine areas by 2030.

A Look Back: Progress and Setbacks

In 2022, the Government outlined its Nature Positive Plan – the most significant proposed revamp of federal environmental laws since the EPBC Act came into effect over two decades ago. The reforms were based on Professor Graeme Samuel AC’s independent review and promised to reshape environmental governance, impact assessment, and biodiversity protection.

Only a fraction of this agenda was implemented:

• Nature Repair Market: Launched on 1 March 2025, this world-first legislated biodiversity credit scheme allows landholders and organisations to earn and trade biodiversity certificates by undertaking verified conservation and restoration activities.
• Water Trigger Expansion: Reforms extended the ‘water trigger’ under the EPBC Act to apply to all unconventional gas projects, strengthening protections for vital water systems.

Other key components – like the proposed creation of Environment Protection Australia and Environment Information Australia – were introduced to Parliament but ultimately shelved in early 2025 due to lack of Senate support.

Looking Forward: What Should We Expect?

Although the full legislative reform agenda remains uncertain, the outcome of the election appears to have strengthened Labor’s Senate position, which could open the door for further environmental legislation.

For now, we can expect:

• Continued momentum on renewable energy and emissions reduction;
• Selective engagement with environmental law reform, likely in consultation with states, industry, and environmental groups;
• Increased funding and focus on biodiversity outcomes through programs like the Nature Repair Market and 30 by 30 initiatives.

Why It Matters

The decisions made in the next few months will shape how Australia manages its natural assets, responds to climate risk, and positions itself in a decarbonising global economy. For businesses, there’s a real opportunity – and responsibility – to align with these shifts. Staying informed, participating in consultations, and preparing for regulatory changes will be key.

#Sustainability #NaturePositive #ClimatePolicy #EnvironmentalReform #Australia2030 #Biodiversity #NetZero #EnvironmentalLaw

The Joint Ore Reserves Committee (JORC) has released its draft 2024 Code for public consultation, setting the stage for a step-change in the way Australia’s mining and resources industry communicates project viability and value.

This isn’t just a technical update—it’s a fundamental realignment with the modern expectations of investors, regulators, financiers, and communities. The proposed changes embed Environmental, Social and Governance (ESG) considerations, mine closure planning, and the structured use of multidisciplinary specialists into the core of public reporting for Exploration Results, Mineral Resources, and Ore Reserves.

Gone are the days when modifying factors could be treated as a footnote. The draft JORC Code signals that a project’s success is not just defined by geology and economics, but also by its social licence, environmental footprint, regulatory credibility, and long-term legacy.

Key Updates in the Draft JORC Code (2024)
1. Mandatory ESG Considerations in Public Reporting

The most prominent update is the introduction of mandatory ESG evaluation in all stages of reporting. ESG is now positioned as a core modifying factor—placing the onus on Competent Persons (CPs) to either directly assess, or transparently acknowledge, the ESG risks and opportunities that influence project outcomes.

What this means in practice:

• Environmental: Assessment of biodiversity impacts, water security, tailings and waste management, land disturbance, climate-related risks (e.g. flooding or bushfire), greenhouse gas emissions, and rehabilitation obligations.
• Social: Consideration of local and Indigenous community expectations, cultural heritage protections, landholder access, workforce capacity, housing impacts, and the project’s social licence to operate.
• Governance: Transparency regarding permitting pathways, compliance status, regulatory uncertainty, land tenure, and alignment with company governance structures and ESG performance frameworks.

Importantly, the Code does not expect every CP to be an ESG expert—but it does expect CPs to understand when ESG risks are material, and to engage recognised Specialists to fill those knowledge gaps. These ESG aspects will need to be explicitly described, not just assumed.

2. Mine Closure Is a Core Part of Reserve Evaluation

Another pivotal change is the formal integration of mine closure planning and liabilities into the Reserve estimation process. The Code makes clear that closure is not a distant event—it is a present-day risk that must be modelled and costed.

Competent Persons will now need to:

• Demonstrate that closure costs (progressive and final) have been quantified and factored into financial modelling
• Identify whether closure plans are approved, under development, or contested
• Account for the feasibility of relinquishment and any long-term monitoring obligations
• Assess how post-mining land uses align with community and regulatory expectations
• Consider whether residual risk could materially alter project viability, either technically or reputationally

Closure planning is no longer optional. It must now be aligned with life-of-mine scheduling, project valuation, and the narrative presented to markets.

3. Specialist Input is Mandatory, Not Just Preferred

The draft Code introduces an explicit requirement: if the Competent Person lacks competence in an area material to the project’s outcome, a named and qualified Specialist must be engaged, and their input clearly documented in the Public Report.

This includes (but is not limited to):

• ESG
• Tailings and water management
• Geotechnical risk
• Heritage and community engagement
• Closure planning
• Hydrogeology or groundwater modelling

This promotes transparency, prevents unqualified commentary, and ensures that assumptions are properly interrogated. The use of Specialists must be scoped, sourced, and declared—in other words, integrated into the reporting framework, not appended as an afterthought.

IEMA’s Role: Helping You Adapt and Thrive

At IEMA, we see this new Code as a welcome evolution, but not one that needs to be over complicated or adding multiple layers to the process. We’ve long believed that credible projects require more than strong geology—they demand strong governance, sound closure planning, and a clear understanding of community and environmental risk.

With decades of experience across exploration, operations, approvals, closure, and post-mining land use, our team offers more than technical input—we offer strategic perspective built on real-world project delivery.

We don’t just advise. We have walked in your shoes.

How We Help Clients Navigate the Draft JORC Code

• Integrated Risk Assessment We use structured frameworks to assess ESG, regulatory, and reputational risks early—helping you identify what matters most to Reserve classification, and ensuring modifying factors are fully substantiated.
• Closure Planning & Liability Management Our experts deliver costed closure plans, final landform concepts, progressive rehab strategies, and relinquishment pathways. We support mining clients in transforming closure from a compliance cost into a strategic advantage.
• Specialist Input & Validation From biodiversity and hydrogeology to tailings risk and heritage, we provide recognised Specialists who work closely with our team to support your Competent Persons. This collaborative model ensures your public reports are defensible and JORC-compliant—technically, socially, and environmentally.
• Strategic Reporting & Communications We help clients align internal studies, stakeholder strategies, and JORC reporting obligations into a single, cohesive narrative—reducing risk and improving investor confidence.
• Training, Mentoring & Peer Review Need to uplift capability within your team? We provide internal mentoring, technical peer review, and CP support to help organisations adapt to the Code’s expectations and embed them in business-as-usual.

Whilst the Code is in Draft with the public submissions being considered by the JORC committee, there is a real opportunity to get on the front foot and start to have conversations around what this means for your projects. Don’t wait till it drops and get in front of the curve on this issue.