- October 22, 2025
Navigating Closure and Life of Mine Plans Under the Updated NI 43-101 and JORC Code
For the first time in over a decade, both the Canadian Securities Administrators (CSA) National Instrument 43-101 (NI 43-101) and Australia’s Joint Ore Reserves Committee (JORC) Code are undergoing significant revisions. Updates to these standards and codes are crucial to providing consistent, transparent, and reliable evaluations of mineral projects. For us as closure consultants, the recent revisions mean we can anticipate greater accuracy in a project’s life of mine operations and risk profile at the onset of the project lifecycle, which ultimately provides additional information that can be used to improve our knowledge base and planning for responsible closure and post-mining transitions.
In this month’s Conversation on Closure, we will discuss several updates that, if adopted, may result in changes to how and when mine closure is considered in the project lifecycle, as well as the outcomes of integrated life of mine (LOM) planning and mine closure strategies.
What is NI 43-101?
First introduced in 2001 and revised in 2011, NI 43-101 is a mandatory standard for disclosing and reporting scientific and technical information to the public about mineral projects across Canada (CIM, 2025). The standard requires companies to use Qualified Persons to prepare and validate technical reports (as well as oral statements, written documents, and websites) that are accurate, verified, and aligned with standardized industry terms and definitions (CIM, 2025; Pizale et al., 2024).
What is JORC Code?
With objectives similar to NI 43-101, the JORC Code is the Australasian professional code of practice for publicly reporting mineral exploration results, resources, and ore reserves (JORC, n.d.). Published in 2012, it provides a mandatory system for classifying these resources and results based on the level of confidence in geological knowledge, as well as technical and economic considerations, promoting transparency, consistency, and reliability in public reports (JORC, n.d.).
What are the revisions to NI 43-101 and JORC Code?
NI 43-101 released its proposed draft this year, while the JORC Code released its proposed draft last year. Both have since welcomed public comments from technical professionals and other subject matter experts. While the revisions cover a broad range of reporting requirements, this article focuses on updates we consider most material to integrated life of mine planning, mine closure planning, and ultimately, successful post-mining land transitions.
NI 43-101
Early stage and advanced properties
One of the changes to NI 43-101 relates to the terminologies and definitions, particularly the removal of the definitions for “early stage and advanced properties”. According to the Canadian Securities Administrators (CSA)’s Proposed Repeal and Replacement of NI 43-101 Standards of Disclosure for Mineral Projects (2025), the definitions for the terms early stage property and advanced property will be removed to make the Proposed Form applicable to mineral projects at all stages of development.
When reviewing the adoption of the broader terminology from a closure and post-mining land use perspective, it is evident that the benefits this revision to the NI 43-101 can achieve in supporting the inherent responsibility of mining companies have as stewards of the land. The previous definition of property types implied that different stages of the project lifecycle could have different considerations of stewardship obligations by the simple act of compartmentalizing them However, this change in terminology weaves together all stages of the project lifecycle with one unifying concept of a singular “project” definition, implying that exploration, development, production, and closure activities should be guided by consistent management and evaluation practices. This unifying concept can be applied to the consideration of closure and land use transition planning by applying the same consistent management and evaluation systems to closure considerations, and integrating into the overall project evaluation throughout the lifecycle.
Life of mine plans
The term, life of mine plan, is introduced in the proposed revisions for disclosing the status of a mineral project in production, aligning the CSA documentation with their ongoing collaboration with the Canadian Institute of Mining, Metallurgy and Petroleum (CIM) and global standards. The proposed definition frames a life of mine plan as a technical and economic study for an existing operation, incorporating detailed assessments of modifying factors, operational considerations, and financial analysis to demonstrate that continued extraction is reasonably justified (CIM, 2025).
The definition guide suggests that life of mine plans should be based on reliable technical, economic, and operational data, including geological, geochemical, geotechnical, and hydrological information, mining methods, mine rock and material management, and closure cost estimates (CIM, 2025). Integrating comprehensive data enables iterative updates to mine plans, supporting adaptive management that reduces potential closure and post-mining land use transition risks to as low as reasonably possible.
Environmental and social issues, and Indigenous rightsholders and communities
Several proposed changes to how environmental and social issues are addressed in the NI 43-101 revision will have an impact on the overall reporting of financial and social liabilities. This may open the door to improvements in closure planning through early identification and recognition of Indigenous Peoples, rightsholders, and communities and their contributions to the project as key stakeholders.
These revisions align the NI 43-101 process with regional regulatory requirements and global industry standards, particularly for collaborating and engaging with Indigenous Rightsholders and external stakeholders, as well as achieving overall environmental and sustainability outcomes. Integrating these components into the NI 43-101 process better captures the costs and implications of compliance and social responsibility into the reporting that supports investment decisions.
Furthermore, the inclusion of rightsholder and stakeholder engagement, along with alignment to environmental and sustainability outcomes at the NI 43-101 stage of project development, inherently integrates social and environmental responsibilities into the overall mine planning activities. This approach can enhance the closure plan by identifying engagement opportunities and desired outcomes earlier in the project lifecycle. It also enables social and environmental risks to be identified earlier in the project lifecycle, integrating them into project development, risk management, and investor considerations from the outset. A key tenet of successful engagement is early, effective, and meaningful communication. Aligning project activities with this guiding principle provides the greatest likelihood of achieving positive engagement outcomes and effective integration into both operational and closure planning.
JORC Code
Environmental, social, and regulatory factors
The 2025 draft of the JORC Code introduces several important updates, particularly in how environmental, social, and regulatory factors are defined and how risks are framed. One notable change is the removal of the ‘Environmental Social Governance (ESG)’ acronym, with language adjusted to align more closely with the terminology of the 2012 code that practitioners are familiar with (JORC, 2025). The proposed change in terminology continues to require consideration of environmental, social, and regulatory outcomes within the JORC process, as part of the Modifying Factors. The importance of mine closure outcomes remains a key aspect of this evaluation.
Uncertainties
Another significant update relates to how risks are conceptualized. The traditional framing of “opportunities and threats” has been replaced with “uncertainties”, and the familiar risk matrix is now described as an “uncertainties map” (JORC, 2025). This change reflects the long-term nature of mine projects and closure, where factors such as climate change, socio-economic shifts, and evolving regulations introduce significant uncertainty.
Framing these challenges as uncertainties rather than risks, the code emphasizes adaptability and proactive planning. Leveraging tools such as Okane’s Roadmap to Closure framework can help mining companies navigate these uncertainties, highlighting opportunities to implement source-control strategies for mine water management and adopt progressive closure approaches for post-mining land uses, including renewable energy initiatives.
In a previous Conversation on Closure, we illustrated how opportunities can be highlighted to optimize pit design for post-mining land use. We discussed that pit limits can be designed to be deeper and wider, both to maximize economic resource extraction and to accommodate future uses such as pumped storage hydropower.
For example, the decommissioned upper and lower pits at the Kidston Gold Mine present a valuable opportunity for repurposing as reservoirs, leveraging their significant water-holding capacity to support 250MW of power generation as part of the Kidston Pumped Storage Hydro Project (Queensland Government, 2023). Incorporating such post-mining value through front-end closure planning into the assessment of mining potential can deliver long-term economic benefits for companies evaluating resource development.
Okane’s Approach
Okane’s Roadmap to Closure takes an integrated, risk-based approach to mine and closure planning, helping clients identify and understand key factors early in the assessment process. This can involve reframing factors traditionally seen as ‘risks’ into opportunities, allowing their integration into early project feasibility, economic assessments, adaptive risk management, and post-mining land use transitions. Our approach can help enhance project viability while supporting alignment with social license expectations and global industry standards, including the Committee for Mineral Reserves International Reporting Standards (CRIRSCO).
Revisions to the NI 43-101 and JORC Code acknowledge the growing importance of environmental stewardship, social responsibility, and community engagement as integral elements of technical reporting and project planning. The proposed revisions, should they be adopted, will enhance the economic assessments, which will be used to determine the overall viability of the project by being both proactive and pragmatic about not only the permitting responsibilities, but also the social license expectations for the proposed project.
Although many economic assessments will focus on the “risks” associated with environmental and social considerations, there are also inherent opportunities arising from these considerations that could be captured in economic and investment decisions. For instance, effective land transition can be a valuable opportunity if planned from the outset, recognizing the post-mining social and economic value of the land for future use when planned appropriately. For example, opportunities include designing the landform to support future solar, wind, or gravitational storage energy projects, or integrating the construction of renewable energy facilities to offset the mine’s energy consumption as part of progressive reclamation planning, or even providing a reliable energy source in remote regions during operations, which could later be transitioned to the surrounding community after closure.
To learn more about how Okane can support your project in navigating jurisdictional and international standards for post-mining transitions and aligning with closure, environmental, and social outcomes, please contact info@okaneconsultants.com.
References
Canadian Institute of Mining, Metallurgy and Petroleum (CIM). (2025). Canadian Securities Regulatory Standards for mineral projects. CIM Mineral Resources & Mineral Reserves. https://mrmr.cim.org/en/standards/canadian-securities-regulatory-standards-for-mineral-projects
CIM. (2025). Proposed additions to the CIM Definition Standards for mineral resources and mineral reserves. CIM. https://www.cim.org/news/2025/public-comment-period-open/
Canadian Securities Administrators (CSA). (2025). B.6 Request for comments. CSA. https://www.osc.ca/sites/default/files/2025-06/csa_20250612_43-101_rfc-disclosure-mineral-projects.pdf
Joint Ore Reserves Committee (JORC). (n.d.). What is the JORC Code?. JORC Code Update. https://www.jorc.org/
JORC. (2025). Draft JORC Code: Survey feedback & summary of changes – Draft JORC code 2024 vs Draft JORC code 2025. https://www.jorc.org/docs/Draft-JORC-Code-Summary-Feedback-Changes-2024-2025.pdf
Queensland Government. (2023). Kidston pumped storage hydro project: Project overview. State Development, Infrastructure and Planning. https://www.statedevelopment.qld.gov.au/coordinator-general/assessments-and-approvals/coordinated-projects/completed-projects/kidston-pumped-storage-hydro-project
Pizale, A., Hogan, G., & Baraich, S. (2024). National Instrument 43-101: What issuers need to know about technical terminology. Cassels. https://cassels.com/insights/national-instrument-43-101-what-issuers-need-to-know-about-technical-terminology/