Traceability Is the Word on Everyone’s Lips, But What Do Anticorruption Experts Think?

Accessing reliable information on supply chains is one of the perennial challenges of a sector as complex as mining, with the various midstream and downstream industries that rely on it. Traceability has emerged as one approach to address this challenge and support fairer and reliable supply chains. But action is needed to ensure that the concept becomes more than a buzzword.

What is traceability?

Traceability is the ability to track three types of information related to a product: (1) its geographical route, including origin, processing or transit; (2) its chain of custody, that is, the various entities that have held the product throughout the supply chain; and (3) its physical evolution, including processing and transformation.

Many hope that traceability will unlock a fairer mining sector, including by helping tackle harmful corruption. We’ve seen how corruption in the sector denies citizens and communities access to the benefits of mining, exacerbates and obscures social and environmental harms, and leads to costly delays and disruptions which impact supply chain stability. Yet there are also concerns that traceability is being presented as a magic solution to nuanced and complex problems. Without serious consideration of how to use the data for positive change, it risks becoming yet another tick box exercise. While useful, traceability alone is not a substitute for due diligence.

One thing is clear: minerals and efforts to make their supply chains more traceable—and ultimately more sustainable and secure—are expected to receive significant attention at international fora in the closing months of 2025. At COP30 in Belém, Parties[AM1]  and advocates are aiming for the first ever mention of minerals and their relevance for a just transition in COP text. The Colombian government has tabled a draft resolution at the UN Environment Assembly (UNEA7) in December, aimed at advancing talks on a global mineral treaty, after first proposing the idea of a binding international agreement on minerals traceability and accountability when it hosted the biodiversity COP16 in 2024.

Traceability and anticorruption efforts

Given these efforts, the Expert Group on Preventing Corruption in Transition Mineral Supply Chains today published a two-page explainer for decisionmakers on how traceability can—and cannot—be used to fight the pressing issue of mineral sector corruption. We explore how traceability data can be used to support anticorruption due diligence efforts, the limitations of traceability systems for anticorruption work, ensuring the integrity of traceability systems themselves, and the roles that different actors can play.

The explainer is the latest collaborative effort from the Expert Group, set up in 2022 as a multistakeholder forum of experts from civil society, governments, academia, enforcement agencies, and international organizations, co-coordinated by Natural Resource Governance Institute, the Extractive Industries Transparency Initiative (EITI) International Secretariat, and the Organisation for Economic Co-operation and Development (OECD) Centre for Responsible Business Conduct. We came together to draw attention to the risks of rapid growth in a sector that is of critical importance to discussions on both the energy transition and energy security.

Below, members of the group share why talking about this topic matters.

Traceability systems for critical minerals enable transparency across mineral origins, ownership structures, supply chain movements, and sustainability performance. As highlighted in the IEA-OECD report on the Role of Traceability in Critical Mineral Supply Chains, well-designed systems provide actionable data to policy makers and industry, helping to identify risks, promote diversification, and enhance energy security.

K.C. Michaels, Legal Counsel, International Energy Agency

Our research shows that corruption is a key enabler of criminal activity along mineral supply chains, shaping who gains access, how oversight is applied, and how revenues are distributed. Traceability and emerging technologies can make a real difference to anticorruption efforts, but only when supported by strong integrity mechanisms that keep data reliable and credible throughout the supply chain.

Matthew Burnett Stuart, Programme Officer, United Nations Interregional Crime and Justice Research Institute (UNICRI)

At Resource Justice Network, we envision traceability as a paramount tool for ensuring a just energy transition. But access to data is not enough, without accountability, traceability becomes a box-ticking exercise. By integrating strong anticorruption measures, we work to ensure that transparency translates into real justice for communities and effective governance across the supply chain.

Pierre Saade, Head of MENA Region and Anticorruption Focal Point, Resource Justice Network

To discuss the ideas and recommendations in the explainer, please reach out to Susannah Fitzgerald at sfitzgerald@resourcegovernance.org.