From Pledges to Practice: Accelerating Progress Using Lessons from ICMM’s Contract Disclosure Journey

Oxfam, NRGI and RJN's new brief evaluates mining company performance on contract disclosure and shares recommendations for improvements.

In September 2021, International Council on Mining and Metals (ICMM) member companies made a commitment to publish their mineral development contracts with governments. This was an important step in the decades long shift toward contract transparency as an established global norm.

Four years later, this brief reflects on lessons learned from the implementation of the commitment as three major policy processes—the creation of the Consolidated Mining Standard Initiative (CMSI), the revision of the International Finance Corporation (IFC) Sustainability Framework and the upcoming 2026 Extractive Industries Transparency Initiative (EITI) Global Conference—are poised to shape approaches to contract transparency for the years to come.

The rise of contract transparency

Over the past two decades, contract disclosure has shifted from a niche reform to an expectation backed by governments, investors, companies and civil society.

Contracts governing oil, gas and mining projects outline critical obligations on taxes, environmental management, community benefits, and more. Publishing these agreements builds trust, reduces corruption risks, and increases stability. Over the past two decades, contract disclosure has shifted from a niche reform to an expectation backed by governments, investors, companies and civil society.

Members of ICMM helped accelerate this shift by engaging in policy dialogue and through early statements of support. Then in 2021, ICMM made a high-profile commitment: its member companies would begin publishing their mineral development contracts with governments.

The ICMM commitment—four years on

As part of our ongoing efforts to support ICMM members to publish contracts, we carried out a review to determine the extent that the commitment had led to public disclosure of contracts by ICMM companies.  We found that eight of 24 ICMM companies now publish contracts—up from just three before the commitment. Continued disclosures by Orano, Rio Tinto and South32; and new disclosures by Glencore, Hydro, Newmont, MMG and Sibanye-Stillwater, reflect meaningful momentum. What is more is that each of these companies is publishing many documents that are not required to be made public under the commitment, most notably contracts agreed before 2021.

Key lessons to accelerate progress

1. Encouragements alone do rarely lead to consistent uptake
   Companies that did not disclose largely interpreted the requirement as not applying to their contracts. Standards like the CMSI and IFC can strengthen uptake by turning encouragements into requirements. If they are unable to do this they should set clear pathways for companies to achieve encouraged practices.
2. Retroactive disclosure is possible
   Most disclosed contracts were older, voluntary releases—challenging the idea that pre-2021 agreements must remain outside contract transparency requirements.
3. Companies need clearer, harmonized guidance
   ICMM’s new guidance is useful but differs in some areas from EITI practice, particularly around its narrow definition of “contracts” and exclusion of agreements with Indigenous Peoples and communities. Aligning standards with the latest EITI guidance note would ensure a harmonized approach to contract transparency across standards.
4. More detailed assurance will support meaningful transparency
   Current ICMM assurance processes do not provide sufficient information for stakeholders to assess whether commitments are being met. Requiring more thorough assurance reports, particularly on which contracts were published and how, and why other contracts were not required to be made public, would improve accountability and confidence around contract transparency standards.

A moment of opportunity

With the CMSI nearing finalization, the IFC updating its Sustainability Framework and EITI preparing for its 2026 Global Conference, the coming year offers rare chances to lock in stronger requirements, clearer guidance and more accountable disclosure systems.

ICMM’s contract transparency commitment was an important milestone. The next phase is ensuring that implementation aligns with ambition. Stronger standards across CMSI, IFC and EITI can help ensure that contract disclosure becomes routine practice, supporting trust, accountability and better governance at a time when global demand for minerals is rapidly increasing.