LBMA Achieves Score of 89% - European Commission Conflict Minerals Regulation (CMR) Assessment & Refiners Transparency Roadmap

Background

In 2023, LBMA submitted the Responsible Gold Guidance version 9 (RGG v.9) for an alignment assessment to become a recognised industry scheme under the EU Conflict Minerals Regulation. We are pleased to share that RGG v. 9 has achieved full alignment as a standard, with the European Commission (EC) acknowledging significant progress across all assessment categories. While the overall Responsible Sourcing Programme was assessed as ‘partially aligned’, we achieved an improved score of 89% in Section A and full alignment in Sections B and C. LBMA has made significant improvements to both the RGG v.9 and implementation, which was recognised by the EC through increased alignment scores.

We have broken down the main points identified by the EC and explained in more detail below what LBMA is doing to improve upon those areas.

Alignment Assessment Results

The EC’s final redacted report is available here.

The EC concluded that LBMA has been assessed as ‘fully aligned’ with sections B (alignment with the five-step framework) and C (specific responsibilities of schemes), and as ‘fully aligned’ with 89% of Section A (overarching due diligence principals). The remaining 11% of Section A was assessed as ‘partially aligned’, and no sections were deemed to be ‘not aligned’. To achieve full alignment with the scheme, Section A must have 100% of sections assessed as ‘fully aligned’ with the relevant criteria.

The principles where partial alignment was identified, specifically A.8 to A.10 relate to:

• auditor oversight; and
• due diligence within the supply chain.

Currently, LBMA anticipates submitting a new application by summer 2026. Work is already underway to strengthen the Responsible Sourcing Programme, which include the EC’s findings.

2025-2026 Key Work Streams

LBMA is committed to driving progress on the following key areas in 2025-2026 in advance of reapplication.

1) Fast Tracking Refiner Transparency - Roadmap

• LBMA has advanced the implementation of its proposals requiring refiners to publicly disclose additional information regarding suppliers of mined material including from ‘red flag’ locations as defined in the gold supplement of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (‘OECD Guidance’). These increased transparency requirements were originally scheduled for 2027 but will now, with the support of LBMA accredited Refiners and other gold supply-chain stakeholders, become part of Refiners’ compliance reports from next year.
• Specifically, as part of LBMA’s Refiner Transparency Roadmap, Refiners will continue to disclose the identity and location of suppliers located in high-risk areas to LBMA as currently required under version 9 of the Responsible Gold Guidance. This information will not be disclosed publicly. However, from 2026, Refiners will publicly disclose the following:
  • The identity of the refiner and local exporter in ‘red flag’ locations as per OECD Guidance;
  • All World Gold Council (WGC) miners and mines from which Refiners receive material;
  • All locations (countries) from which mined material is received.

• These changes will be implemented via an amendment to the Disclosure Guidance which supports GDL Refiners in the implementation of reporting and disclosure requirements. LBMA is publicly consulting over the summer with a view to finalising this process by the end of 2025. Further information about the consultation can be found here.
• Arrangements for further disclosure going into 2027 will be discussed and agreed with OECD and other stakeholders, but proposals will include the disclosure of the identity of suppliers, locations (countries) and total volumes of all mined material, not just those from WGC members. These disclosures are irrespective of the risk rating of either supplier or location. The proposal will also include the expectation of the disclosure of all suppliers in high-risk locations as defined in Responsible Gold Guidance (RGG 10) once published.

We are in the process of reviewing how LBMA can better communicate with key stakeholders regarding in-year enforcement of standards and policies. For more information on LBMA enforcement actions, please see our annual Sustainability and Responsible Sourcing Report as well as our case studies page, which includes actions as they are taken throughout the year.

2) Enhancing Assurance Provider Performance Globally

To support the consistent and effective implementation of the RGG by Assurance Providers in 2025, we are:

• working with independent experts to review the assurance programme. In doing so, LBMA will address measures to enhance its existing processes and internal control mechanisms, including the review of assurances themselves; and
• continuing to enhance assurance provider training and controls including the pre-assurance process, the assurance provider toolkit, LBMA Shadow Assurance and mandatory assurance provider training and exam. For further details on these, see the 2023 Sustainability and Responsible Sourcing Report.

3) Strengthen Value Chain Engagement

• Continued engagement with downstream actors beyond LBMA’s Membership including civil society, industry programmes, central banks, jewellery companies, ETFs, etc. to promote collective action on responsible sourcing.

4) Growing Demand for Responsible Sourcing of Artisanal & Small-Scale Gold

• Working with the multi-stakeholder ASM Taskforce to address governance challenges and improve responsible GDL refiner sourcing in key producer countries (Philippines, Ghana, Cote D’Ivoire, Peru, etc.).