Disclosure Guidance Version 3

LBMA Launches Disclosure Guidance Version 3 to Strengthen Transparency Across the Gold Supply Chain

Following an extensive public consultation conducted between June and September 2025, LBMA is pleased to announce the publication of Disclosure Guidance Version 3 (DG3).

DG3 provides greater alignment with the OECD Due Diligence Guidance[1] Footnote 59 reporting requirements and, in instances, goes beyond this to encourage more transparent and meaningful communication by Refiners. 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.

DG3 reflects the collective feedback of refiners, assurance providers, civil society, industry partners, and other stakeholders committed to responsible and transparent precious metal supply chains.

Key Enhancements in Version 3

From 1 January 2026, Refiners will publicly disclose:

  • The identity of the Refiner and local exporter in 'red flag' locations as per OECD Due Diligence Guidance;
  • All World Gold Council (WGC) miners and mines from which Refiners receive material;
  • All locations (countries) from which mined material is received.

DG3 should be interpreted as a minimum threshold upon which Refiners should build and continually improve reporting and disclosure practices. It forms part of the Refiners’ Toolkit and, as such, Refiners are expected to implement it on a comply or explain basis.

[1] Footnote 59 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas states: Business confidentiality and other competitive or security concerns means, without prejudice to subsequent evolving interpretation: price information; supplier identities and relationships (however the identity of the refiner and the local exporter located in red flag locations should always be disclosed except in cases of disengagement); transportation routes; and the identity of information sources and whistle-blowers located in conflict-affected and high-risk areas, where revealing the identity of such sources would threaten their safety. All information will be disclosed to any institutionalised mechanism, regional or global, once in place with the mandate to collect and process information on minerals from conflict-affected and high-risk areas.

Outcome of the Public Consultation

LBMA has incorporated this feedback into the final version of DG3, helping to ensure that the improvements are both ambitious and implementable. A summary of consultation themes and LBMA’s responses is available in the Consultation Report alongside the published Guidance.

Consultation Responses

Individual responses – where permission was granted – have been published below.

For more information, please view the DG3 Consultation Report.

HRW response to DG3 consultation.

Instituto Escolhas response to DG3 consultation.

Jiangxi Copper response to DG3 consultation.

Jurisconsult Ltd. response to DG3 consultation.

Open Supply Hub response to DG3 consultation.

SWISSAID response to DG3 consultation.

Zijin Mining response to DG3 consultation.

Anonymous response to DG3 consultation.

Anonymous response to DG3 consultation.

Anonymous response to DG3 consultation.

Anonymous response to DG3 consultation.

Anonymous response to DG3 consultation.

Anonymous response to DG3 consultation.

Anonymous response to DG3 consultation.

Anonymous response to DG3 consultation.

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Anonymous Response 19 to DG3 consultation.

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Anonymous Response 30 to DG3 consultation.