Who counts the ore? No country lets the market mine on its own word — the real divide is who validates the estimate

Asked (summary)

How does subsoil ownership connect with resource estimation standards such as JORC and CRIRSCO? Which countries estimate their own subsoil resources and which rely on expert opinion? Can estimates contradict each other, how is that resolved, and where does government set the conditions of extraction versus the licence holder relying on industry expertise and the market?

This report compares 26 representative jurisdiction records — 15 expert-led market-disclosure regimes (several documented through a single project) and 11 state-approved or dual regimes — against the 16 country and regional members CRIRSCO lists today. It is a comparative framework built from laws, regulator documents and project disclosures, not a complete country-by-country legal opinion. Ownership, estimation, public disclosure, state accounting and permission to extract are five distinct legal layers: a JORC or CRIRSCO estimate is a dated professional opinion by a company-appointed Competent Person, not a state inventory and not a licence to mine.

The governance spectrum: who controls the estimate, and how deep the state reaches into extraction

expert-led market disclosure dual/hybrid (two parallel figures) state-approved reserve system · hover or tap a country for who estimates, who validates and who approves extraction

“Expert-led” never means freedom to mine: even in the US the SEC-filed S-K 1300 reserve for Mountain Pass depends on county permits that allow operations only through 2042, and extending the mine plan to 2053 requires new permitted boundaries — sec.gov

Russia is the clearest dual system: the subsoil user prepares the estimate, FBU GKZ and an expert commission review it, Rosnedra approves it onto the state balance, and extraction is permitted only after state expert review — while CRIRSCO/JORC reporting may run in parallel for finance — oern.ru

China’s regulations effective 15 June 2026 keep the calculation with the mining-right holder but add strong administrative validation: the granting department reviews the reserve report, approves mining plans, and holds recovery and utilisation rates to national standards — news.chemnet.com

Contradictions are often legally designed in: Serbia’s socialist-era A/B/C1 balance reserves exclude mining dilution and losses, so they can never equal PERC Reserves — both figures stay valid because they answer different questions — eurogeologists.eu

When estimates change materially, the market route is correction and liability, not re-measurement: ASX Listing Rules 5.8 and 5.9 require detailed supporting information for any material change, with Competent Person consent and personal responsibility — company-announcements.afr.com

What number is this? A decision flow

1 · Investor disclosure

CRIRSCO-family public report (JORC, CIM/NI 43-101, S-K 1300, SAMREC, PERC, Certification Code). Controlled by the Competent/Qualified Person; policed by exchanges and securities regulators. Governs what the market may be told.

2 · State balance

GKZ-style approved reserves (Russia, Kazakhstan, Georgia, Kyrgyzstan, Uzbekistan, Mongolia, Czech national system). Controlled by a state commission; governs the national inventory and write-offs.

3 · Tax or royalty base

Where law ties fiscal terms to approved reserves — e.g. Uzbekistan’s commercial-discovery bonus is calculated on reserves approved by the authorised public authority.

4 · Licence milestone

Evidence of mineral content for lease grant or auction (India’s 2015/2021 Rules), feasibility acceptance (Ghana), concession application (Brazil). Controlled by the licensing authority.

5 · Approved mine plan

POPD, technical project, mining plan or permit boundary. This figure — not the resource statement — controls what can physically be extracted, everywhere.

There is ordinarily no universal factual winner between these numbers. Each legal purpose has its own controlling figure; two good-faith estimates can differ through drill data, interpretation, cut-off grade, price and cost dates, recovery, dilution, ownership share and classification rules without either being fraudulent.

Russia and China side by side

Russia — dual system

Who estimates: the subsoil user prepares the reserve-estimation materials.

Who validates: FBU GKZ and an expert commission review; Rosnedra approves and places reserves on the state balance.

Extraction condition: extraction is permitted only after state expert review (with narrow exceptions); the opinion covers geological, technological and economic condition limits.

Parallel market figure: OERN/NAEN or JORC/CRIRSCO public reporting may run alongside for finance; it does not substitute for state expertise. Legal basis: Law “On Subsoil”; Government Resolution No. 335 of 01.03.2023. oern.ru

China — state-approved system (from 15 June 2026)

Who estimates: the mining-right holder compiles the reserve report and answers for its authenticity.

Who validates: the original granting department reviews it and may commission a technical assessment; the reviewed report feeds state statistics and supervision.

Extraction condition: the department approves exploration and mining plans and major changes; feasibility studies must match the mining plan; mining recovery, beneficiation recovery and comprehensive utilisation must meet national standards. Legal basis: Mineral Resources Law; Implementation Regulations (State Council Decree No. 839). news.chemnet.com

Due-diligence checklist: reconciling a JORC/CRIRSCO estimate with a state-balance or permit figure

Identify the legal purpose of each number first — disclosure, state balance, tax, licence milestone or mine plan — before comparing tonnage.
Match categories, not totals: GKZ balance reserves and CRIRSCO Resources/Reserves are not one-to-one; check whether Resources are inclusive of Reserves.
Compare effective dates, commodity price, exchange rate and cost assumptions behind each figure.
Check cut-off grade, boundary, dilution and recovery treatment — Soviet-family balance categories often exclude dilution and losses.
Confirm ownership share and whether the figure is attributable or 100 percent.
Check the permitted mine design: extraction beyond approved boundaries or plans is not available regardless of the estimate.
Verify Competent/Qualified Person standing, independence and consent, and whether the report is superseded by a later one.
In state-review systems, confirm the state expert opinion is current and whether deposit or mining-method changes trigger re-examination.
Treat project-specific, transitional or dated rows (e.g. Uzbekistan’s pre-2025 statute, Kazakhstan’s KAZRC transition) as indicative, not definitive current law.
Remember neither figure is a guarantee of tonnage: both are conditional estimates for different masters.

All 26 jurisdiction records

Jurisdiction	Governance model	Reporting / inventory system	Government role	Caveat	Source

Comparative legal framework from 26 representative jurisdiction records (15 expert-led regimes, several documented via single-project disclosures; 11 state-approved or dual regimes), the CRIRSCO membership page listing 16 member countries/regions, and 79 conflict-and-update rule records under JORC/ASX, NI 43-101, S-K 1300 and the CRIRSCO template. Each table row cites its own source; sources mix official laws and regulators with secondary legal guides and project filings. Positions on the chart are qualitative placements from the described roles, not measured values. Research current to 2 October 2026; mining rules are commodity-specific, subnational and rapidly amended. Superseded SEC Industry Guide 7 excluded. Evidence excerpts cut for space.

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