The Brazilian benchmark that aligned with the world

ANM Resolution 94/2022, published in February 2022, established the Brazilian System for Mineral Resources and Reserves (SBRRM). This new framework introduces a classification structure aligned with international standards such as JORC, NI 43-101, and S-K 1300, allowing Brazilian assets to be evaluated with the same rigor required in global markets. This convergence directly impacts the transparency of technical reports, M&A negotiations, and the acquisition of foreign financing. Understanding SBRRM requirements is, therefore, an essential condition for investors and operators seeking legal certainty and data comparability.

What ANM Resolution 94/2022 created: the SBRRM#

Resolution 94/2022 established the SBRRM as the regulatory regime for the definition, reporting, and documentation of mineral resources and reserves within the national territory. The system replaces the previous classification based on disparate concepts and creates standardized categories that must be used in all technical documents submitted to the National Mining Agency.

SBRRM categories are structured in three hierarchical levels – exploration potential, resource, and reserve – and each level contains sub-classes that detail the confidence level and economic viability of the mineralized material. The text of the resolution further determines that the presentation of results must follow a technical report template, with specific fields for methodological description, tonnage estimates, grade, recovery factors, and market assumptions.

The mandatory nature of the SBRRM covers both exploration-phase projects and operational enterprises, ensuring that the same language is applied throughout the asset's entire lifecycle. In this way, the ANM ensures data consistency and facilitates comparison between different projects within the country.

The classification ladder: exploration potential, resource, reserve#

The first rung of the ladder – exploration potential – refers to areas where there is an indication of mineralization, but insufficient geological or engineering information to quantify volumes with confidence. At this stage, data are considered qualitative or preliminary, and estimates are expressed in terms of "indicative" or "potential."

The second level – resource – represents the quantification of mineralized material based on sampling, geological modeling, and preliminary economic assessment. Resources are divided into three classes (inferred, indicated, and measured) according to data density, the reliability of estimates, and the definition of economic cut-off parameters. This classification requires that the methodologies employed be documented and that results be auditable by a qualified professional.

The third rung – reserve – corresponds to the portion of the resource that, following detailed analysis of engineering, economic, environmental, and regulatory aspects, demonstrates viability for commercial production. Reserves are subdivided into probable and proven, following risk and safety margin criteria. Each reserve must be linked to a mining plan (PAE) that describes the production sequence, operating costs, and price assumptions.

The transition between levels depends on the quality and quantity of geotechnical information, laboratory tests, and feasibility studies. The absence of critical data may prevent an exploration potential from being elevated to a resource, or a resource to a reserve, limiting the confidence level attributed to the asset.

Why this benchmark is recognized outside Brazil: the CBRR and CRIRSCO#

The Brazilian Commission for Resources and Reserves (CBRR) was admitted as a member of CRIRSCO International in November 2015, becoming the ninth globally recognized national body. This affiliation implies that the SBRRM adopts the standardization principles developed by CRIRSCO, which are the foundation of JORC, NI 43-101, and S-K 1300 guidelines.

Adherence to CRIRSCO ensures that the terms "resource" and "reserve" used in Brazil have definitions equivalent to those used in major capital markets. Thus, international investors can evaluate a Brazilian asset using familiar metrics, without the need for additional conversion or interpretation.

Beyond semantic harmonization, the CBRR publishes a technical guide that details the practical application of SBRRM criteria, offering examples of calculation, sampling requirements, and auditing procedures. This guide functions as a best-practices reference, facilitating the review of documents by external auditors and market analysts.

Illustrative scenario: imagine a foreign investor analyzing two opportunities – one in Canada, reported according to NI 43-101, and another in Brazil, reported according to SBRRM. If both declarations use CRIRSCO definitions, the investor can directly compare the tonnage and grade of the resources, evaluating the risk margin based on the same confidence parameters. Should the Brazilian report not follow SBRRM, the comparison would require subjective adjustments, increasing uncertainty and potentially rendering the investment decision unviable.

Where these concepts become mandatory: Final Exploration Report and PAE#

Resolution 94/2022 determines that, upon conclusion of the mineral exploration phase, the Final Exploration Report (RFP) must incorporate the SBRRM classification. The RFP must present, in a structured manner, the identified exploration potential, estimated resources, and, when applicable, forecasted reserves, complying with established data quality and economic analysis criteria.

In parallel, the Economic Development Plan (PAE) – the document detailing the mining strategy, required infrastructure, and socio-environmental impacts – must explicitly reference the reserves that support the project's economic viability. The PAE requires the demonstration of profit margins, unit costs, and risk indicators, all aligned with SBRRM categories.

The mandatory nature of these documents creates a regulatory control point: the ANM verifies the consistency between the RFP and the PAE before authorizing the granting of mining rights or the expansion of already licensed areas. Non-compliance with the standards may result in a requirement for supplementary studies, delays in obtaining licenses, or, in extreme cases, the rejection of the exploration proposal.

Illustrative scenario: consider a project that concludes the exploration phase and produces an RFP indicating only higher-class resources, but omits the analysis of reserves in the PAE. The ANM, when analyzing the documentation, will identify the gap and require the production of mining engineering studies to validate the existence of reserves. While these studies are not completed, the project remains unable to move to the environmental licensing phase, generating additional costs and lost market opportunities.

What to ask about a Brazilian asset in light of this rule#

To evaluate a Brazilian asset's adherence to the SBRRM, it is necessary to direct the analysis toward specific aspects of the technical report and mining plan. The questions below assist in verifying compliance and identifying potential risks.

1. Verify the adopted classification – Does the document clearly indicate the category (exploration potential, resource, or reserve) according to the SBRRM?
2. Confirm data quality – Are the estimates supported by representative sampling, auditable geological modeling, and recognized laboratory assays?
3. Analyze calculation methodology – Does the calculation of tonnage and grade follow the CBRR guide guidelines, with transparency in cut-off parameters and recovery assumptions?
4. Evaluate economic assumptions – Does the study incorporate market prices, operating costs, and exchange rates compatible with the sector's reality?
5. Check the link between RFP and PAE – Are the reserves declared in the PAE derived from the resources presented in the RFP and do they present an adequate safety margin?
6. Identify environmental and regulatory requirements – Does the PAE contemplate all environmental conditions required by the ANM and state agencies?
7. Review independent audit – Has a Competent Person reviewed the technical report, attesting to compliance with the SBRRM?
8. Examine data updates – Is the presented data recent and does it reflect the latest exploration or mining engineering campaigns?

Summary#

Resolution 94/2022 established the SBRRM as the backbone of mineral resource and reserve classification in Brazil, aligning it with the CRIRSCO standard adopted internationally. The classification ladder – exploration potential, resource, and reserve – clearly defines the degree of confidence and economic viability of each stage, while the mandatory application in final exploration reports and economic development plans creates a robust regulatory control mechanism. By applying the provided verification questions, investors and technicians can evaluate a Brazilian asset's consistency with the standard's requirements, reducing risks and facilitating comparability with global projects. This approach, based on technical rigor and standardization, sustains the confidence required for raising capital and conducting transactions in the international mining market.

This articlepoint your camera
and take it with you