Important changes to the latest draft of the JORC Code were laid out by JORC this week following the 2024 consultation, which showed significant interest from industry stakeholders 6 min read
The Joint Ore Reserves Committee (JORC) shared the latest developments regarding its update of The Australasian Code for Reporting of Exploration Results, Mineral Resources and Ore Reserves (JORC Code or Code) at a public webinar event on Wednesday, 10 September 2025.
Following the release of the draft JORC Code on 1 August 2024 (2024 Draft), JORC sought public feedback over a three-month period ending on 31 October 2024. During this period, JORC received over 8200 comments from a wide range of stakeholders, with 55% of respondents having between 20-40 years of minerals industry experience, and 78% being technical professionals from the minerals industry.
Subsequent to a thorough review of the feedback, JORC (a committee of volunteers, together with the support of various volunteer working groups) has produced an updated draft JORC Code (2025 Draft), which was distributed to key stakeholders including ASX, ASIC and the JORC Parent Bodies (AIG, AusIMM and MCA) in June 2025. A comprehensive legal review of the 2025 Draft has also commenced, which Allens is pleased to be leading.
This Insight explains the top five key changes reflected in the 2025 Draft to date to address the feedback received, as well as the next steps to completing the JORC Code update.
ESG
The 2024 Draft included additional ESG-focused provisions, geared at increasing awareness of ESG considerations appropriate to the stage of a project's development.
JORC reported the topic of 'ESG' received a significant and sometimes emotive public response. Feedback expressed concern with the inclusion of ESG in the 2024 Draft, which was perceived to be promoted over and above other Modifying Factors. Feedback also suggested that the division of ESG accountability between boards of directors and Competent Persons required clarification, that the ESG requirements could exceed the expertise of Competent Persons, and that there were too many ESG prompts in Table 1.
After careful consideration of the feedback, JORC has undertaken a comprehensive redraft of ESG provisions in the 2025 Draft to recalibrate and clarify the ESG disclosure requirements from the 2024 Draft. The 'ESG' acronym and certain clauses related specifically to ESG have been removed, with the 2025 Draft now moving to a modified definition of 'Modifying Factors', which includes 'environmental, social and regulatory factors'. The ESG prompts in Table 1 have been reduced significantly and the ESG guidance matrix has been simplified and moved to the proposed Extended Materials Library (refer to the 'Structure and volume' heading below).
It's important to note that 'ESG' reporting has not disappeared from the 2025 Draft. The 2025 Draft clarifies disclosure against Modifying Factors is restricted to that information which is 'available and material', and related to the project which is the subject of the public report. JORC confirmed there is not an expectation for Competent Persons to go on an 'information hunt' or 'crystal ball' gaze when reporting on Modifying Factors.
Competence and specialists
Substantial feedback was provided on the subjects of competence and specialists. The inclusion of 'Specialists' as a defined term was poorly supported, particularly around the lack of available professional organisations for many speciality areas (especially in emerging fields such as ESG), along with concerns of accountability, ambiguity and administrative burdens. In response to these, the definition of 'Specialists' has been removed in the 2025 Draft.
In response to a call for further clarification on the Competent Persons' responsibilities and accountabilities, the 2025 Draft confirms that Competent Persons can use contributing Competent Persons or inputs from small 's' specialists if there is a reasonable basis to do so, with JORC confirming a Competent Person should not blindly accept the material provided to it by a specialist (ie there is an expectation that the material is reviewed and understood).
JORC confirmed the CV of Record remains the recommended option, with a legal review to be undertaken to address privacy concerns, noting that there needs to be a mechanism in the JORC Code to provide some visibility on the experience of a Competent Person, rather than moving to a full registration or exam model (as is the case in other international reporting codes). The CV register is intended to apply to all reporting under the JORC Code, be it internal, public or private, to ensure integrity in reporting.
Finally, the requirement for a Competent Person to undertake induction has been removed, with JORC flagging that guidance will be provided as to the various ways a Competent Person can demonstrate their understanding of the JORC Code.
Structure and volume
JORC received feedback on the length, complexity and repetition of the 2024 Draft. The general feedback was that the JORC Code should be simplified in structure and shortened in volume, and included concern over the significant level of detail required in Table 1. Although splitting the JORC Code and Guidance Notes into two separate documents was widely supported, the structure and volume was a key concern of stakeholders.
In response to this feedback, the overall structure and length of the 2025 Draft compared to the 2024 Draft has been reduced to date by ~20%, including by removal of 44 clauses. Competent Persons will rejoice, with Table 1 itself presently sitting at 91 rows, approximately half the row count from the 2024 Draft. In addition, content from the JORC Code not considered mandatory has been moved through the proposed implementation of a three-layer model:
- JORC Code: these are mandatory provisions
- Guidance Notes: these are categorised as persuasive, for interpretation of the JORC Code
- Extended Materials Library: these are considered resources for good practice, and will be available on JORC's website.
JORC also noted changes seeking alignment to the ASX Listing Rules on a verbatim basis have been made, largely to achieve consistency of reporting where the JORC Code is used in other markets.
Risk
The 'Risk: Opportunities and Threats' section of the 2024 Draft was widely questioned in feedback. The term 'risk' was considered to be loaded and have many meanings, resulting in confusion about the level of application being requested in disclosures. The requirement for a consideration of 'all identified risks' by Competent Persons was considered onerous. Substantial concern was raised that 'opportunities' disclosure would be inappropriately used as a means for promotion of blue-sky potential in conflict with other JORC Code requirements and the Australian corporations law regime more generally.
In response, the section has been renamed in the 2025 Draft to 'Uncertainty' and the disclosure requirements have been limited to the potential consequences impacting the technical or economic viability of the reported project. The 'risk matrices' in the Guidance Notes have been renamed an 'uncertainty map' to confine disclosure to the reported project and avoid confusion with corporate risk matrices.
Clarification of 'Competent Persons' Documentation'
Feedback also indicated that it was unclear whether the 'Competent Persons' Documentation' was a public report or a private internal document to assist in drafting a public report. To assist in clarifying this distinction, the 2025 Draft includes updated language to reflect that Competent Persons' Documentation is drawn upon in order to generate public reports and is not to be reported as a public report.
Where to from here?
JORC identified the following as next steps for the progression of the JORC Code update:
- A legal review of the 2025 Draft is underway
- JORC is aiming to finalise the drafting of the JORC Code in consultation with the ASX and ASIC by the end of 2025
- A further consultation process for consequential ASX Listing Rules changes will be undertaken by ASX, with timing to be confirmed
- Implementation of the updated JORC Code and transition arrangements are to be confirmed with the ASX and ASIC, with mandatory reporting under the new Code to commence thereafter.
Importantly, JORC confirmed there is not a present intention to open up the 2025 Draft for further consultation once it is finalised and becomes publicly available.
What can you do now to prepare?
As JORC Chair Steve Hunt intimated in the webinar, the good news is that the new Code is not going to sneak up on anyone, with the expectation being that a finalised version will be in place well before implementation to give users plenty of time to prepare for reporting under it.
A document summarising feedback received on the 2024 Draft and the changes to date will be available on the JORC website.