CSA Proposes Amendments to Modernize and Streamline Canada’s Mining Disclosure Standards

Introduction 

On June 12, 2025, the Canadian Securities Administrators (CSA) announced extensive proposed amendments (Proposed Amendments) aimed at modernizing and streamlining Canada’s mining disclosure regime. The Proposed Amendments would repeal and replace National Instrument 43-101 Standards of Disclosure for Mineral Projects (NI 43-101), Form 43-101F1 Technical Report (43-101F1), and the current Companion Policy 43-101CP to NI 43-101 (Companion Policy), and include consequential amendments to certain other existing instruments and forms.

The Proposed Amendments would mark the first significant update to Canada’s mining disclosure regime in 14 years and are intended to update and enhance the disclosure requirements for mineral projects without introducing unnecessary regulatory burden.

The CSA has requested comments on the Proposed Amendments by October 10, 2025.

Background 

In April 2022, the CSA published Consultation Paper 43-401 Consultation on National Instrument 43-101 Standards of Disclosure for Mineral Projects (Consultation Paper), seeking feedback to inform potential amendments to Canada’s mining disclosure regime. In response, the CSA received extensive feedback from a broad range of market participants, including reporting issuers, individuals, consulting and law firms, regulatory bodies and advocacy groups, including groups representing Indigenous Peoples.

In publishing the Proposed Amendments, the CSA aims to address evolving disclosure practices while taking into account policy considerations identified by CSA staff, investor expectations and the comments received in response to the Consultation Paper.

The Proposed Amendments would:

• Remove or replace certain definitions that have become outdated
• Modernize and streamline certain requirements to reflect current industry practice
• Remove certain requirements that have become outdated
• Provide clarification and guidance on certain definitions and requirements
• Make certain other minor drafting changes to clarify disclosure requirements

The Proposed Amendments 

The Proposed Amendments include the following key changes:

Terms and Definitions

• Mineral Project: The Proposed Amendments replace the existing interchangeable use of the terms “mineral project,” “property,” “mineral property,” and “project” with the term “mineral project.” The definition has also been clarified to reflect that terms such as diamonds, base metals and industrial minerals are examples of natural solid inorganic or fossilized organic material, rather than discrete categories requiring separate treatment.
• Producing Issuer: Issuers that meet the definition of “producing issuer” are permitted to file technical reports prepared by internal qualified persons. The definition of “producing issuer” is based on the Canadian dollar gross revenue from mining operations from the most recently completed fiscal year and three fiscal year period. The existing thresholds of C$30-million and C$90-million, which have been in place since 2001, are proposed to be increased to C$55-million and C$165-million, respectively, to reflect the impact of inflation.
• Early-Stage and Advanced Properties: Existing definitions of “early-stage exploration property” and “advanced property” have been removed to make 43-101F1 suitable for all mineral project stages, including those that do not fall neatly within the existing categories.
• Qualified Person: The definition of a qualified person has been revised to:
  • Remove the education requirement, which is already addressed through professional licensing
  • Clarify that relevant experience must be gained after registration as a professional geologist or engineer
  • Clarify the meaning of experience relevant to the subject matter of the mineral project

Alignment With Global Reporting Standards

The Proposed Amendments remove the ability of foreign issuers, and Canadian issuers with foreign mineral projects, to report mineral resources and mineral reserves using categories of an acceptable foreign reporting code. The CSA notes that this allowance is no longer necessary due to global harmonization efforts. Under the Proposed Amendments, all scientific and technical information contained in an issuer’s disclosure must align with the CIM Definition Standards for Mineral Resources and Reserves (CIM Definition Standards).

New CIM Definitions Incorporated

The Canadian Institute of Mining, Metallurgy and Petroleum (CIM) is working in tandem with the CSA to include new definitions in the CIM Definition Standards that will be incorporated by reference in the proposed amendments to NI 43-101:

• “scoping study” replaces the existing definition of “preliminary economic assessment”
• “exploration target” replaces the expression “target for further exploration”
• A new definition, “life of mine plan,” is used when disclosing mineral project status while in production

Disclosure Related Changes

• Scientific or Technical Information: All written disclosure of scientific or technical information —whether relating to a material or non-material mineral project — must be based on information prepared or approved by a qualified person, aligning with current industry practice.
• Royalty-Only Issuer Technical Reports: The obligation for issuers that only have a royalty or similar interest in a mineral project to file a technical report has been removed, recognizing that such issuers often do not have access to sufficient project-level data or the ability to perform personal inspections.
• Environmental and Social Disclosure Enhancements: The Proposed Amendments modernize disclosure around environmental, permitting and social matters by introducing broader and more inclusive terminology (e.g., using “rightsholders”). Technical reports must disclose the dates and sources of such information to improve transparency regarding its currency and reliability. 
• Indigenous Peoples and Rightsholders: In response to feedback from Indigenous groups and other stakeholders during the consultation process, the Proposed Amendments to 43-101F1 will require disclosure of any permits, agreements or negotiations with Indigenous Peoples, rightsholders or communities that are directly related to the mineral project. Broader information regarding an issuer’s general relationships with Indigenous communities remains subject to materiality assessments under existing continuous disclosure obligations. 
• Personal Inspection Requirements: A standalone item has been added to the Proposed Amendments to 43-101F1 to provide detailed disclosure regarding the current personal inspection conducted by each qualified person. The existing ability to defer personal inspections due to seasonal conditions has been removed. At least one qualified person must conduct a current personal inspection prior to filing.
• Mineral Resource Disclosure: The existing prohibition on aggregating inferred mineral resources with other categories of mineral resource estimates to disclose total mineral resources has been removed, provided that each category is also disclosed separately. This change aligns with global mining disclosure practices.
  • To align with best practices and enhance comparability, the Proposed Amendments require:
    • Information about how reasonable prospects for eventual economic extraction were determined
    • Enhanced disclosure around mineral resource classification
    • Disclosure of the issuer’s attributable ownership interest in any jointly held mineral resources
    • Project-specific risk disclosure related to mineral resource estimates
• Adjacent Property Disclosure: Issuers may continue to reference adjacent properties, but the issuer cannot focus on this type of disclosure, and the disclosure must include cautionary statements that this information is not necessarily indicative of mineralization on the issuer’s mineral project.
• Enhanced Data Verification Requirements: Qualified persons must describe the data verification process for each item of the technical report, including data beyond exploration and drilling (e.g., metallurgy, mining methods).
• Prohibition on Disclaimers: The Proposed Amendments clarify that an issuer’s disclosure, including a technical report, cannot include any disclaimer of scientific or technical information.
• Expanded Written Disclosure Requirements to Non-Material Mineral Projects: The Proposed Amendments clarify that certain prescribed requirements for written disclosure apply to both material and non-material mineral projects, aligning with current industry practice. The requirements apply to written disclosure regarding data verification, exploration information, and mineral resources and mineral reserves. 
• Clarification on “Relevant” vs. “Material” Information: The phrase “material scientific and technical information” is replaced with “relevant scientific and technical information,” which clarifies that the qualified person is responsible for determining relevance within the context of the technical report, without needing to assess materiality for continuous disclosure purposes.

Companion Policy Guidance

The Proposed Amendments to the Companion Policy include guidance on preparing and interpreting 43-101F1, providing greater clarity for qualified persons and improving consistency across the industry.

Consequential Amendments to Other Instruments

The CSA also proposes related amendments to other national instruments and forms to align with the Proposed Amendments.

Call for Comments 

The full text of the Proposed Amendments can be found at 43-101 CSA Notice and Request for Comment, June 12, 2025.

The CSA is inviting public comments on the Proposed Amendments during a 120-day comment period that ends on October 10, 2025.

For further information, please contact the authors or any other member of our Capital Markets group.