Reporting codes

Four codes, one family, rules that differ.

A comparison of JORC (2012 edition), NI 43-101, S-K 1300 and the CBRR Guide with ANM Resolution 94/2022. Each cell cites the clause, item or article read in the source. Reviewed 24/09/2026.

Comparison of the four codes#

The JORC text cited is the 2012 edition; a new edition is being finalised and this table will be revised when it is published. The CBRR Guide cited is the 2022 edition, read in the PDF published by the CBRR; ANM Res. 94/2022 was read on ANMlegis; S-K 1300 in 17 CFR 229.1300 to 1304.

Comparison of mineral resource and reserve reporting codes

Point	JORC 2012	NI 43-101 (CIM 2014)	S-K 1300 (SEC)	CBRR Guide and ANM Res. 94/2022
Where and who governs	Australasian code, incorporated into the ASX (1989) and NZX (1992) listing rules. Every ASX public report containing an Exploration Target, Results, Resources or Reserves follows JORC (LR 5.6).	National Instrument 43-101, a Canadian securities rule. Resource and reserve categories are those of the CIM Definition Standards (NI items 1.2, 1.3 and 2.2).	SEC rule for registrants whose mining operations are material. Mandatory from the first fiscal year beginning on or after 01/01/2021.	CBRR Guide (2022 edition), from the Brazilian committee, a CRIRSCO member since December 2015; definitions aligned with the CRIRSCO International Reporting Template (2019 revision). ANM Res. 94/2022 sets the concepts (art. 4), makes them mandatory in the technical documents of mining-title processes, such as the RFP and PAE (art. 10), and refers public statements to the CRIRSCO and CBRR guides (art. 5, § 2). The ANM does not certify results, resources or reserves (art. 2, sole paragraph).
Who signs	Competent Person. Minimum of 5 years of relevant experience in the style of mineralisation or type of deposit under consideration and in the activity undertaken (cl. 11).	Qualified Person. Minimum of 5 years in mineral exploration, mine development or operation, or mineral project assessment, with experience relevant to the project (item 1.1).	Qualified Person. Minimum of 5 years of relevant experience in the type of mineralization and type of deposit under consideration and in the specific type of activity undertaken (17 CFR 229.1300).	Qualified Professional (CBRR Guide, cl. 3.6): registered with the CBRR or a member of a Recognised Professional Organisation. A CBRR-registered professional has at least 10 years of professional experience, 5 years of relevant experience in the style of mineralisation, deposit type and activity, and 3 years in a Position of Responsibility. Res. 94/2022: public statements signed by a qualified professional (art. 8); technical documents by legally qualified professionals (art. 11).
Professional organisation	Member or fellow of AusIMM, AIG or a Recognised Professional Organisation, with power to suspend or expel.	Professional association with disciplinary power, in good standing.	Eligible member or licensee in good standing of a recognised professional organisation.	Registration with the CBRR (PQR.CBRR mark) or membership of a Recognised Professional Organisation with disciplinary processes, including the power to suspend or expel (CBRR Guide, cl. 3.6).
Independence required	No. Relationships and conflicts are disclosed (cl. 9). On the ASX, an independent CP is required only for a production target based solely on Inferred Resources (LR 5.16.6).	Yes, in triggers (item 5.3(1)): a technical report by an independent QP on first disclosure of resources, reserves or a PEA on a material property, in a prospectus, and on a change of 100% or more; exemptions for producing issuers (5.3(2) and (3)).	Not as a general rule. The QP may be an employee of the registrant, with individual written consent.	No. The Guide requires disclosing whether the Qualified Professional is an employee, who the employer is and any conflict of interest (cl. 3.3), and that the professional is satisfied the work was not unduly influenced by whoever commissioned it (cl. 3.12).
Resource and reserve categories	Resource: Inferred, Indicated, Measured (cl. 20). Ore Reserve: Probable, Proved, derived from Measured and/or Indicated Resources (cl. 29).	Inferred, Indicated, Measured; Probable, Proven, per the CIM Definition Standards (NI items 1.2 and 1.3; reconciliation required when a foreign code is used, item 7.1(2)).	Inferred, Indicated, Measured; Probable, Proven (17 CFR 229.1300). An inferred resource may not be converted to a reserve.	Exploration potential, Resource (inferred, indicated, measured) and Reserve (probable, proved), with modifying factors (Res. 94/2022, art. 4).
Exploration Target	Cl. 17: a range of tonnes and a range of grade. The terms Resource and Reserve must not be used in this context.	Item 2.3(2): the potential quantity and grade of a target only as ranges, with an equally prominent statement that they are conceptual, that exploration is insufficient to define a resource and that it is uncertain the target will become one, plus the basis of the estimate.	Exploration target: a range of tonnage and a range of grade for mineralization with insufficient exploration to estimate a resource (17 CFR 229.1300); disclosure allowed with the rule's cautionary statements.	Exploration potential (Res. 94/2022, art. 4, I; CBRR Guide, cl. 5.1): a range of tonnage and a range of grade, never to be confused with a resource or reserve (cl. 5.2).
Study that supports a reserve	Pre-Feasibility or Feasibility Study (cl. 29). A Scoping Study must not be used as the basis for Ore Reserves (cl. 38).	A Preliminary Economic Assessment (PEA, item 2.3(3)) may include Inferred Resources, with an equally prominent cautionary statement, but does not support reserves. The terms pre-feasibility and feasibility study may only be used for studies that meet the definitions (item 2.3(4)).	An Initial Assessment supports resources only and cannot be the basis for reserves. A Preliminary Feasibility Study and a Feasibility Study support reserves (17 CFR 229.1300).	Conceptual, Pre-feasibility and Feasibility Study (CBRR Guide, cl. 8.1). A reserve needs at least a Pre-feasibility Study (cl. 4.6 and 8.9); a Conceptual Study cannot support a reserve (cl. 8.4). Res. 94/2022, art. 4, III: a reserve is the mineable part of a measured and/or indicated resource with demonstrated technical and economic viability.
Disclosure document	Public Report, with Table 1 on an if not, why not basis. On the ASX: the CP is named, with employer and organisation, and consents in writing (LR 5.22).	Technical Report on Form 43-101F1 (items 1 to 27; QP certificate and consent, items 8.1 and 8.3). On first disclosure of resources, reserves or a PEA on a material property, the report is filed within 45 days (item 4.2(5) and (6)).	Technical Report Summary, filed as an exhibit on first disclosure of resources or reserves and on a material change.	RFP and PAE using the art. 4 concepts (art. 10); public statements under the CRIRSCO and CBRR guides (art. 5, § 2), signed by a qualified professional (art. 8). Filing the statement with the ANM is optional and its content is not confidential (art. 5, § 3; art. 12, § 2).
Foreign or historical estimate	Reportable under LR 5.11 and 5.12, with source, date, category differences and a cautionary statement. Verification and reporting under JORC within 3 years (LR 5.14 and 5.16.7).	Item 7.1: an issuer incorporated abroad, or a Canadian issuer for a property abroad, may use an acceptable foreign code (JORC, PERC, SAMREC and others), with reconciliation of category differences (7.1(2)). Item 2.4: a historical estimate may be disclosed in its original terminology, with source, date, relevance, category differences and a cautionary statement.	17 CFR 229.1304(h): an estimate not verified as current by the Qualified Person, made before the acquisition, is not considered current and cannot support disclosure; it may only appear in a filing on a merger, acquisition or business combination, when it cannot be updated before closing, with source, date and a statement that the Qualified Person has not verified it.	Res. 94/2022, art. 9: in an RFP filed before the rule took effect, measured, indicated and inferred reserves are read as measured, indicated and inferred resources; in an earlier PAE, a measured reserve becomes a proved reserve, an indicated reserve becomes probable if its economics are demonstrated, and an inferred reserve becomes an inferred resource.

Sources: JORC 2012 (cl. 9, 11, 17, 20, 29, 38); NI 43-101 (items 1.1, 1.2, 1.3, 2.2, 2.3, 2.4, 4.2, 5.3, 7.1) and Form 43-101F1; 17 CFR 229.1300, 1302 and 1304 (S-K 1300); ASX Listing Rules ch. 5; ANM Res. 94/2022 (arts. 2, 4, 5, 8 to 12); CBRR Guide 2022 (cl. 3.3, 3.6, 3.12, 4.6, 5.1, 5.2, 8.1, 8.4, 8.9).

Where is the asset going?#

ASX and NZX

JORC (2012)

Every public report, including website content, containing an Exploration Target, Results, Resources or Reserves follows JORC (LR 5.6). A foreign or historical estimate enters under LR 5.12. The announcement names the Competent Person, employer and organisation, with written consent (LR 5.22). Main care point: a Scoping Study does not support a reserve, and a foreign estimate cannot be used in a scoping, PFS or FS study.

ASX Listing Rules, ch. 5 (5.6, 5.12, 5.22); JORC 2012, cl. 38

TSX and TSX-V (Canada)

NI 43-101

The Qualified Person signs the Technical Report in the Form 43-101F1 format, with certificate and consent. Use of a foreign code follows item 7.1, with reconciliation; an estimate made before the acquisition follows item 2.4. On first disclosure of resources, reserves or a PEA on a material property, the report is filed within 45 days (item 4.2(5)). Main care point: item 5.3(1) requires an independent QP for that first disclosure, in a prospectus, and on a change of 100% or more.

NI 43-101, items 1.1, 2.4, 4.2, 5.3 and 7.1; Form 43-101F1

SEC registrants (USA)

S-K 1300

Applies to a registrant whose mining operations are material. The first disclosure of resources or reserves requires the Technical Report Summary, filed as an exhibit. Main care point: only a Preliminary Feasibility and a Feasibility Study support reserves; an Initial Assessment supports resources only. The QP may be an employee of the registrant, with individual consent; if not, the registrant names the employer and discloses affiliations (17 CFR 229.1302(b)(5)). A pre-acquisition estimate not verified by the QP cannot support disclosure, except in a merger or acquisition filing (17 CFR 229.1304(h)).

17 CFR 229.1300, 1302 and 1304; SEC, Small Entity Compliance Guide

Brazil (ANM and CBRR)

CBRR Guide (2022) and ANM Res. 94/2022

The RFP (Final Exploration Report) and the PAE (Economic Development Plan) use the art. 4 concepts (art. 10), under the responsibility of a legally qualified professional (art. 11). Public statements follow the CRIRSCO and CBRR guides (art. 5, § 2), signed by a Qualified Professional (CBRR Guide, cl. 3.6). Filing with the ANM is optional and public; the ANM does not certify the content (art. 2, sole paragraph). Main care point: an RFP filed before 7 Aug 2022 is read under art. 9: the former measured, indicated and inferred reserves count as measured, indicated and inferred resources, not as reserves.

ANM Res. 94/2022, arts. 2, 4, 5, 9, 10 and 11; CBRR Guide 2022, cl. 3.6

An estimate made under another code is not an automatic conversion#

An estimate made under another code is not an automatic conversion. A figure in categories of the former Brazilian regime, or of another code, does not become a JORC or NI 43-101 Resource by relabelling.

ASX. A foreign or historical estimate may be reported under LR 5.12, with source, date, category differences relative to JORC, relevance, reliability and a verification programme (LR 5.11, 5.12 and 5.14), with a cautionary statement next to the figure. Verification and reporting under JORC have a deadline of up to 3 years (LR 5.14 and 5.16.7). These estimates cannot be used in a scoping, PFS or FS study.

NI 43-101. Item 7.1 admits an acceptable foreign code (JORC, PERC, SAMREC and others with consistent categories), with reconciliation of the differences. Item 2.4 allows disclosure of a historical estimate in its original terminology, provided the source and date, relevance and reliability, category differences and a cautionary statement are given; Form 43-101F1 asks for those estimates under Item 6 (History).

S-K 1300. An estimate made before the acquisition and not verified as current by the Qualified Person is not considered current and cannot support disclosure; it may only appear in a filing on a merger, acquisition or business combination, when there is no time to update it, with source, date and a statement that the Qualified Person has not verified it (17 CFR 229.1304(h)).

Brazil. ANM Res. 94/2022, art. 9, fixes how the former regime is read: in an RFP, measured, indicated and inferred reserves become measured, indicated and inferred resources; in a PAE, a measured reserve becomes proved, an indicated reserve becomes probable if its economics are demonstrated, and an inferred reserve becomes an inferred resource.

Differences of philosophy in practice#

JORC: principles-based (Transparency, Materiality and Competence, cl. 4), with responsibility concentrated on the Competent Person. Table 1 works on an if not, why not basis. Effective 20/12/2012 and mandatory since 01/12/2013.
NI 43-101: a securities rule: mandatory form (Form 43-101F1, items 1 to 27), filing triggers (item 4.2), a 45-day deadline, QP certificate and consent (items 8.1 and 8.3) and independence in triggers (item 5.3). It is more prescriptive than JORC.
S-K 1300: an SEC rule for registrants, with the Technical Report Summary as an exhibit and three named studies (Initial Assessment, PFS and FS).
Brazil: ANM Res. 94/2022 makes the concepts mandatory in the technical documents of mining-title processes (art. 10), but filing public statements with the SBRRM is optional (art. 5, § 3) and the ANM does not certify the content (art. 2, sole paragraph). The CBRR Guide is the reporting code; the securities yardstick belongs to the exchange where the asset is listed.
Independence: none of the four codes requires it as a general rule; NI 43-101 requires it in triggers (item 5.3) and the ASX only for a production target based solely on Inferred Resources (LR 5.16.6). Requiring it beyond that is the policy of whoever commissions the work, not of the code.

A USGS reserve is not a code reserve#

In the USGS Mineral Commodity Summaries 2026 (rare earths), Australia's reserves total 6.3 Mt. Note 13 clarifies that 3.3 Mt are JORC-compliant or equivalent reserves. For Brazil, the USGS reports 11 Mt, noting that the reserves of Australia, Brazil and Malaysia were revised based on Government reports, and gives no equivalent code-compliant figure. A USGS reserve and a Reserve declared by a Competent or Qualified Person are quantities of a different nature.

The Brazilian code#

Brazil has its own yardstick, aligned with CRIRSCO. The Brazilian committee (CBRR) is the ninth CRIRSCO member, admitted in December 2015; the CBRR Guide, 2022 edition, carries definitions aligned with the CRIRSCO International Reporting Template as revised in 2019 and is published as a PDF on the CBRR website.

ANM Res. 94/2022: published in the Official Gazette on 08/02/2022, in force 180 days later (art. 13), on 07/08/2022. Names the Brazilian System of Mineral Resources and Reserves (SBRRM, art. 2); the ANM is not a certifying body (art. 2, sole paragraph).
Art. 4 and art. 10: set the concepts of exploration potential, inferred, indicated and measured resource, probable and proved reserve, and modifying factors, mandatory in the technical documents of mining-title processes (RFP and PAE); art. 11: those documents are the responsibility of legally qualified professionals.
Art. 5 and art. 8: public statements follow the CRIRSCO and CBRR guides and are signed by a qualified professional under the competence criteria of art. 7, III.
SBRRM: filing statements with the ANM is optional, the content is not confidential and is available to any user (art. 5, § 3; art. 12, § 2).
RFP before 7 Aug 2022 (art. 9): the former measured, indicated and inferred reserves are treated as measured, indicated and inferred resources; in an old PAE, a measured reserve counts as proved, an indicated one as probable if its economics are demonstrated, and an inferred one as an inferred resource. Read the number through that conversion table, not as a CRIRSCO reserve.