Frequently asked questions about mining in Colombia

The usual path is to submit a concession contract proposal over a free area, which the Mining Authority evaluates. In general, the steps are:

1. 1Define the mineral, the area and who the holder will beIt can be an individual or a legal entity with legal capacity. If it is a company, its corporate purpose must expressly include mineral exploration and mining.
2. 2Check that the area is free and that mining is allowed thereThat it does not overlap with current titles or applications, and that it is not in excluded zones such as natural parks, protective forest reserves or páramos. In restricted zones, such as urban perimeters, additional permits are needed.
3. 3Choose the structure that fits youOrdinary concession, concession with differential requirements if you are a small-scale miner, or a structure under someone else's title. They are compared in the next question.
4. 4Prepare the proposalMunicipality and Environmental Authority of the area, description and extent, mineral, mention of ethnic groups settled there, the terms of reference and guides to be applied in exploration with the investment estimate, and the map. Economic capacity must also be demonstrated.
5. 5File it and follow the evaluationThe authority reviews the technical, legal and economic aspects and may ask you to correct deficiencies. Evaluation times belong to the authority and nobody can guarantee them.
6. 6If there are ethnic communities in the areaTheir right of first refusal is triggered and, where applicable, prior consultation.
7. 7Sign the contract and register itThe title exists from its registration in the National Mining Registry. From then on the contract stages and the surface fee run.
8. 8Explore and prepare what comes nextBefore exploration ends, the PTO is submitted and the environmental licence is processed. Without both, mining cannot begin.

This is a general guide. Checking the area and choosing the structure is the least costly step and the one that defines everything else, so it is worth doing before investing in studies.

The proposal is submitted on the Mining Authority's standard form, through the Integrated Mining Management System (AnnA Minería). In addition to the applicant's name, identification and address, it must contain:

• The municipality where the area is located and the Environmental Authority with jurisdiction over it.
• The description and extent of the area, now defined in cells of the mining grid.
• The mineral or minerals to be explored and mined.
• Mention of any ethnic groups settled in the area.
• If the area includes zones restricted for mining, a statement to that effect.
• The terms of reference and mining guides to be applied in exploration, with the investment estimate.
• The map of the area, prepared under the engineering, geology and surveying rules required by law.

Separately, the applicant demonstrates economic capacity under the Mining Authority's current criteria. If it is a company, its corporate purpose must expressly include mineral exploration and mining.

If you are a small-scale miner, there is a proposal with differential requirements. It can be used once only, without holding another current title, and over a maximum of 100 hectares.

The Mining Code calls the concession contract registered in the National Mining Registry a mining title, but that is not the only route. There are concession modalities designed for different applicants, and there are structures for operating under someone else's title. These are the ones analysed at the start of a project:

01Ordinary concession contract

Proposal over a free area before the Mining Authority. Up to 30 years, with exploration, construction and assembly, and production stages.

Law 685 of 2001, arts. 14, 45, 70 to 72 and 271

02Concession with differential requirements (PCCD)

Contract proposal for small-scale miners and beneficiaries of returned areas, with technical and economic requirements adjusted to their size. It carries a Differential PTO.

Law 1955 of 2019, art. 326; Decree 1378 of 2020; Law 2250 of 2022

03Mining zones of ethnic communities

Indigenous reservations and community councils of Black communities can request that a mining zone be delimited within their territory, and have a right of first refusal so that the concession is granted to them before any third party.

Law 685 of 2001, arts. 121 to 136 (first refusal: 124 and 133); Law 70 of 1993; Decree 1396 of 2023

04Special Reserve Area (ARE)

For communities that have carried out traditional mining in the zone. The Mining Authority delimits it and the special concession is granted only to that community.

Law 685 of 2001, arts. 31 and 249

05Mining formalization subcontract

Agreement between the holder of a concession and the small-scale miner already working inside it. The Mining Authority authorizes and approves it, it lasts at least four years, renewable, and the subcontractor is accountable for its own area.

Law 1753 of 2015, art. 19; Decree 1949 of 2017

06Return of areas for formalization

The holder returns part of the area so that the Mining Authority can title it to the small-scale miners who have been working it.

Law 1753 of 2015, art. 19; Decree 1949 of 2017

07Association or operating contract

Private contract by which the holder mines the area together with a third party, or hands over the operation, without creating a company. The operator works under the title; the holder remains accountable to the Mining Authority. It differs from the works contract, which gives no right to a share of the mineral.

Law 685 of 2001, arts. 221 and 27

08Subsistence mining

Manual open-pit extraction, without mechanized equipment. It requires no title, but it does require free personal registration with the municipality, renewed every year, and respecting the maximum volumes.

Law 1955 of 2019, art. 327; Decree 1073 of 2015, art. 2.2.5.1.5.3 (Decree 1666 of 2016); Resolution 40103 of 2017 of the Ministry of Mines and Energy; Decree 1102 of 2017 (sale of the mineral, RUCOM)

Which one suits you depends on whether the area is free or already titled, on who holds that title, on the scale of the operation and on who the applicant is. That analysis comes before any technical document.

No. Since the 2001 Mining Code came into force, the right to explore and mine State-owned minerals is constituted only by the concession contract registered in the National Mining Registry. That contract is the mining title.

Before 2001 there were exploration licences, mining permits and licences, mining contracts and contracts over contributed areas. The Code preserved those in force when it came into effect. Their holders comply with the conditions of the laws under which they were granted.

Nor does the title make the holder the owner of the minerals in the subsoil. It gives the exclusive and temporary right to establish whether there is usable mineral in the area and to take ownership of it on extraction.

Two things sometimes called permits that are not titles: the environmental licence, granted by the Environmental Authority to control the effects of the works, and the subsistence miner's registration with the municipality.

In order, the procedure goes through these stages:

• Proposal: submitted to the Mining Authority over a free area, with the technical and economic support corresponding to the modality, ordinary or with differential requirements.
• Contract and registration: once the proposal is evaluated and accepted, the contract is signed. It only takes effect from its registration in the National Mining Registry.
• Exploration: up to 3 years, extendable.
• Construction and assembly: 3 years.
• Production: the remaining time, up to a maximum contract term of 30 years.

During exploration and construction and assembly, a surface fee is paid. During production, royalties.

The extension of the production period is requested from the Mining Authority at least two years before that period expires, and may be for up to thirty years. It is not automatic: the authority evaluates and decides. In general, the path is this:

1. 1Check the expiry date and the regime of your contractThe general rule is to request it at least two years before production ends. Contracts signed under Decree 2655 of 1988 have their own rule: at least six months before.
2. 2Bring your obligations up to dateThe law requires being current with all contract obligations, for example royalty payments and the submission of Basic Mining Forms.
3. 3Check the mining and environmental bondIt must be in force and covering the obligations in the terms of the Mining Code.
4. 4Prepare a new PTOThe application is accompanied by a Mining Work Program for the extension period.
5. 5File it and follow the evaluationThe authority carries out a cost-benefit evaluation of the extension. Timing and decision are its own.
6. 6Sign the record and register itIf granted, the extension is perfected by a record signed by the parties and registered in the National Mining Registry.

The exploration stage is different. It lasts three years from registration of the contract and the law allows extensions of two years each, up to a total of eleven years. To request them you must substantiate the technical and economic reasons, show the work done and the work remaining, be current with the surface fee and keep the mining and environmental bond in force. Integration of areas, by contrast, never gives rise to an extension.

Assigning the rights under a mining title requires approval from the Mining Authority. A private contract between the parties is not enough. In general, the path is this:

1. 1Review the file before negotiatingConfirm pending obligations, open requirement notices and the validity of the bond. It is the way to know what is being bought or sold.
2. 2Sign the negotiation documentThis is the written assignment agreement between the holder and the party receiving the rights.
3. 3Confirm that the assignee meets the requirementsThe Mining Authority verifies the assignee's legal requirements and economic capacity.
4. 4File the applicationIt is submitted by the beneficiary of the title, that is, the assigning holder, before the Mining Authority, together with the negotiation document.
5. 5Follow the evaluationThe law gives the authority sixty days to decide on the application.
6. 6Register the approvalIf the assignment is approved, the administrative act of approval is registered in the National Mining Registry. That registration is the only proof of the assignment.

It is the structure that allows several titles for the same mineral, held by one or several holders, to be merged into a single contract with a single exploration and mining program. It applies when the areas are contiguous or neighbouring, and also when they are not but belong to the same deposit.

It tends to be worthwhile when a single operation needs to work several areas at once. That happens, for example, when the same mineralized body was split between titles, or when the mine design crosses the boundaries between contracts.

The law sets an express limit: integration never gives rise to extensions of the titles. The application is evaluated by the Mining Authority under the conditions set by regulation.

The PTO is the technical document that defines how the area will be mined. It is submitted to the Mining Authority before the exploration stage expires and, once approved, is attached to the contract as an obligation of the holder. It must contain, among other things:

• Definitive delimitation of the mining area and topographic map.
• Location, calculation and characteristics of the reserves.
• Location of the mining, processing and transport facilities.
• Mine plan.
• Geomorphological, landscape and forest recovery plan.
• Scale and duration of expected production.
• Physical and chemical characteristics of the minerals.
• Closure plan for the operation and abandonment of installations and infrastructure.

It is prepared under the Mining Authority's terms of reference. For small-scale mining there is a version with differential requirements, the Differential PTO (PTOD).

The PTO is not a requirement for obtaining the title. The title comes first; the PTO is what allows the move into construction and assembly and into production.

The PTO is submitted to the Mining Authority before the exploration stage ends. It needs the definitive delimitation of the area, the minimum content set by the Mining Code and the authority's current terms of reference. In practice, it is prepared like this:

1. 1Close exploration with sufficient informationThe PTO rests on what exploration left behind: geology, sampling, grades and the deposit model. Without those data, the rest of the document has no basis.
2. 2Delimit the definitive mining areaAt the end of exploration, the definitive delimitation of the zone to be tied to the mining works is submitted, with its topographic map.
3. 3Support the deposit's resources and reservesThe location, calculation and characteristics of the reserves are part of the minimum content, and are supported by the geological studies of the deposit. Resource and reserve information is reported under the Colombian Standard for the Public Reporting of Exploration Results, Mineral Resources and Reserves, or another standard recognized by CRIRSCO.
4. 4Design the mine planMining method, scale and duration of expected production, and location of the mining, processing and transport facilities.
5. 5Include recovery and closureThe geomorphological, landscape and forest recovery plan, and the Mine Closure Plan, which since Decree 0742 of 2026 is submitted as part of the PTO.
6. 6Follow the terms of reference that apply to youThe ordinary PTO has its own. For small-scale mining under a special contract or with differential requirements there is the Differential PTO (PTOD), with its own terms of reference.
7. 7File it and follow the evaluationIt is filed in the Integrated Mining Management System and evaluated by the Mining Authority. Once approved, it is attached to the contract as an obligation of the holder.
8. 8Coordinate it with the environmental licenceWithout an approved PTO and an environmental licence mining cannot begin, so the PTO and the EIA should describe the same operation.

Three things at the same time:

• A title or a structure that covers the operation: registered concession contract, approved formalization subcontract, operating contract with the holder, or another of the structures described above.
• The PTO approved: by the Mining Authority.
• The environmental licence granted: without it, mining works cannot begin.

Once in operation, the holder must:

• Pay royalties.
• Keep the mining and environmental bond in force.
• Submit periodic reports to the Mining Authority (Basic Mining Forms).
• Comply with the mining safety regulation and the SG-SST system.
• Appear as an authorized mining operator in the RUCOM lists and issue a certificate of origin for each sale.

A requirement notice is a formal act: the authority points to an obligation it considers unfulfilled and sets a deadline to respond. Whatever is not answered on time stands as non-compliance. In general, the path is this:

1. 1Read the full act and locate the notification dateThe deadline runs from notification, not from when you open the email. The law allows the authority to set up to 30 days.
2. 2Identify which type it isUnder threat of a fine, or on grounds of forfeiture. The second is more serious, because forfeiture ends the contract.
3. 3Locate the exact obligation being citedThe most frequent are the surface fee, royalties, the mining and environmental bond, Basic Mining Forms, the PTO, safety rules and the environmental instrument.
4. 4Gather the supporting recordsPayment receipts, previous filings, bonds, reports and inspection records. Compare what the notice says with what is on your file.
5. 5Define the responseCorrect the deficiency within the deadline, prove with evidence that there was no non-compliance, or request more time explaining why it is needed.
6. 6File through the official channel and keep the receiptA response filed late, or through a different channel, may not be taken into account.
7. 7Follow upIn forfeiture proceedings the regulation provides for the authority to decide within ten days of the deadline expiring. The decision can be appealed in the terms indicated in the act.

This is a general guide. The content of the response depends on the obligation cited and the status of your file, and the final decision rests with the Mining Authority.

Grade is the concentration of gold in the ore, expressed in grams per tonne (g/t). It is determined by systematic sampling of the deposit (channels in drifts, drill holes, trenches) and laboratory analysis, normally by fire assay. At the plant it is estimated with metallurgical balances relating the ore fed, the tailings and the gold recovered. Grade, together with tonnage, is the basis for the reserve calculation in the PTO and for the project's economic viability.

Whenever there is mining, underground or open pit, whatever the mineral. What changes with the size of the project is who grants it. It falls to the national Environmental Authority when the projected operation is equal to or greater than:

• Coal: 800,000 tonnes per year of projected production.
• Metallic minerals and precious and semi-precious stones: 2,000,000 tonnes per year of total projected material moved, that is, ore plus waste.
• Construction materials and clays or non-metallic industrial minerals: 600,000 tonnes per year for clays. For other construction materials or non-metallic industrial minerals, 250,000 m³ per year.
• Other minerals and materials: 1,000,000 tonnes per year.

Below those thresholds it is granted by the regional or urban Environmental Authority. There are exceptions: a project in the buffer zone of a National Natural Park always goes to the national authority.

The exploration stage does not require an environmental licence, but it does require the specific resource-use permits it needs: water, discharges or forest use.

The environmental licence for a mine is requested with an Environmental Impact Assessment (EIA). In mining no Environmental Alternatives Assessment is submitted. The licence is granted by the national or the regional Environmental Authority depending on the volume of the operation, and the procedure is the same. Step by step:

1. 1Have the title registeredA copy of the mining title or concession contract registered in the National Mining Registry is delivered with the application.
2. 2Define which authority is competentIt depends on the mineral and the projected volume, using the thresholds in the previous question. A project in an already determined buffer zone of a National Natural Park always goes to the national authority.
3. 3Prepare the EIAUnder the Ministry of Environment's terms of reference for mining operations (TdR-13) and the General Methodology for the Preparation and Submission of Environmental Studies, which is mandatory.
4. 4Cover the minimum content of the studyAbiotic, biotic and socioeconomic characterization, impact and risk assessment, management zoning, economic evaluation of impacts, Environmental Management Plan, follow-up and monitoring, contingency plan, 1 % investment plan where there is direct water abstraction, and biodiversity loss compensation plan.
5. 5Identify the natural resources you will useWater, discharges, occupation of watercourses, forest use or emissions are identified in the EIA. The licence implicitly carries those permits for the life of the project.
6. 6File the application with its annexesAmong others: Single Environmental Licence Form, maps, investment and operating cost, proof of payment of the evaluation fee, Ministry of the Interior certificate on ethnic communities and proof of filing with the ICANH.
7. 7Attend the site visit and the additional-information meetingAfter the opening order, the authority may visit the project within the following 20 working days. If it needs more information it asks once only, in a meeting recorded in minutes, and you have one month to deliver it, extendable by one more month.
8. 8Await the decisionWith the information complete, the authority has up to 30 working days to grant or deny the licence. The terms are suspended if there is an environmental public hearing or while prior consultation is carried out, where applicable.

Following the terms of reference does not guarantee the licence: the resolution adopting them says so itself. And if the EIA does not meet the minimum requirements of the evaluation manual, the authority terminates the procedure.

The Environmental Impact Assessment (EIA) is the instrument used to apply for the environmental licence: it describes the project, establishes the baseline, identifies and evaluates the impacts and already includes, as one of its components, the Environmental Management Plan (PMA), with the prevention, mitigation, correction and compensation measures. In a new project no stand-alone PMA is submitted: it goes inside the EIA.

When each is required:

• EIA: in every environmental licence application for mining, regardless of volume. To modify a licence, a supplement to the EIA with the adjusted PMA is submitted.
• PMA as an instrument of its own: only for projects that obtained their environmental authorizations under earlier rules and remain in the transition regime. If such a project wants to add new areas with activities that today require a licence, it must apply for one.
• Mining formalization: the temporary environmental licence for formalization is also requested with an EIA, prepared under differential terms of reference, and not with a PMA.

Environmental authorities cannot impose a PMA on projects other than those indicated by the regulation, nor outside the transition regime.

It is the document that defines how the area disturbed by mining will be left. It is governed, under the name Mine Closure Plan, by Decree 0742 of 9 July 2026, published in Official Gazette 53,549 of 10 July and in force from the day after publication. It covers, among other things:

• Removal of equipment and dismantling of facilities.
• Physical and chemical stability of structures.
• Recovery, restoration and morphological reshaping of the area.
• Water resource management and ecological rehabilitation.
• Risk management for the post-mining use of the area.

It is submitted as part of the PTO, or of the PTOD in small-scale mining, to the Mining Authority and the Environmental Authority. In mining it replaces the dismantling and abandonment plan that used to go in the EIA.

The decree distinguishes five types of closure: progressive, temporary, early, final and gradual technical. Gradual technical closure corresponds to small-scale mining with an environmental instrument and to miners in formalization, as Law 2250 of 2022 already required.

As of October 2026 two pieces remain pending: the plan's terms of reference and the regulation on financial guarantees.

The Mine Closure Plan applies to mining title holders and to beneficiaries of temporary authorizations in construction and assembly or in production, or intending to be. These are its main obligations:

• Submit it with the PTO: or with the applicable technical instrument, to the Mining Authority and the Environmental Authority. In small-scale mining with a PTOD it goes as an annex, with progressive closure and final closure.
• Cover the minimum content: removal of equipment, dismantling, physical and chemical stability, recovery and reshaping of the area, water management, ecological rehabilitation, landscape functionality and risk management for post-mining use.
• Plan post-closure: maintenance, monitoring and follow-up after closure is executed.
• Update it: every five years in medium and large-scale mining. Also when technical or operating conditions change, when additional impacts appear or when the authority requests it.
• Back it with financial guarantees: whose regulation has not yet been issued.

The new regime also reaches those who already submitted a PTO or an EIA that has not been approved, and those who have them approved and need to update or modify them.

The plan's terms of reference have not yet been issued. The decree allowed six months for this. Until they are published, the reference is the minimum content set by the decree itself.

It depends on the stage of the project:

• With an environmental licence: the water concession is implicit in the licence, provided the water use is clearly identified in the EIA.
• Without a licence yet, or for a use that was not included: it is processed as a separate permit before the regional Environmental Authority. The source (surface or groundwater), the flow, the use and the abstraction system are indicated, and there is a technical visit before it is granted by resolution.

If the project's licence falls to the national Environmental Authority, the regional authority cannot grant permits that form part of that project.

There is no single route. The deciding question is whether the area is free or already has a current title:

• In a free area: the concession proposal with differential requirements (PCCD), the Special Reserve Area if there is a traditional mining community, or the mining zone if the territory belongs to an indigenous reservation or a community council.
• Inside someone else's title: the formalization subcontract or the return of areas, agreed with the holder and approved by the Mining Authority.
• With a traditional mining formalization application already filed: that procedure continues, with mediation by the Mining Authority.

In all cases the PTO or the Differential PTO must be submitted and the environmental instrument obtained.

Whoever holds a final act from the Mining Authority certifying their formalization process applies for a temporary environmental licence, with an EIA under differential terms of reference. That licence runs until the global or definitive environmental licence is granted or denied. Once the concession contract is granted or the subcontract registered in the National Mining Registry, there is one year to obtain the definitive licence. If that year passes without it, the temporary licence lapses. Without that act and without the temporary licence, mining is not allowed.

First you need to know which structure you fit into, because each has its own regulation and requirements. What defines the route is how you work, at what scale and whether the area is free or already titled. The general path is this:

1. 1Determine whether it is subsistence miningSubsistence is manual open-pit extraction, without machinery or explosives, and includes panning (barequeo). It needs no title, only registration with the municipality. If you use mechanized equipment or work underground, it is no longer subsistence.
2. 2Check the areaFind out whether it is free or already has a current title, and whether it falls in zones excluded or restricted for mining. That decides which structures are available to you.
3. 3If the area is free, choose among the dedicated structuresThe concession proposal with differential requirements, used once only and over a maximum of 100 hectares, or the Special Reserve Area if there is a traditional mining community.
4. 4If the area is titled, negotiate with the holderThe formalization subcontract is for those already mining inside the title before 15 July 2013. The other route is the return of areas for formalization. Both are authorized by the Mining Authority.
5. 5File with the Mining AuthorityLegalization and formalization applications are filed in the Integrated Mining Management System. In Antioquia, since January 2024 they are handled directly by the national Mining Authority, through its Medellín Regional Service Point.
6. 6Process the environmental instrumentWithin the year following the final act certifying your formalization process, the temporary environmental licence application is filed with the environmental authority together with an EIA under differential terms of reference. In the formalization subcontract, once registered, the subcontractor applies for the environmental licence with its EIA.
7. 7Submit the Differential PTOSmall-scale mining being legalized or formalized submits a Differential Mining Work Program (PTOD), which is the follow-up instrument for its operation.
8. 8Obtain the definitive licenceThe temporary licence runs until the global or definitive environmental licence is granted or denied. Once the concession contract is granted or the subcontract registered in the National Mining Registry, there is one year to process and obtain it. If that year passes without it, the temporary licence lapses and closure activities follow.

To sell the mineral, gold included, you must appear as an authorized mining operator in the lists the Mining Authority publishes in the RUCOM. The holder in production, the formalization subcontractor, the beneficiary of a Special Reserve Area and the formalization applicant with legal authorization also issue a certificate of origin for each sale. The subsistence miner does not issue one: they sell with the production declaration. Without those documents, an authorized trader cannot buy the mineral.

Subsistence mining is manual, open-pit extraction, without mechanized equipment or machinery for extraction. It covers river sand and gravel for construction, clays, precious metals and precious and semi-precious stones, and includes panning. It requires no mining title, but it does require these conditions:

• Free personal registration: with the municipality where you work, in one municipality only.
• Data for registration: identity card, tax registration (RUT) with the mining activity, Sisbén, the mineral extracted and a description of the zone where you work.
• Owner's authorization: if you work on private land.
• Annual renewal: the registration is renewed every year, in person and with biometric validation.
• Limits of the activity: no underground workings, machinery or explosives are allowed. There are maximum production volumes: for precious metals, an average of 35 grams per month and a maximum of 420 grams per year.
• To sell: you must be published in the RUCOM as an authorized mining operator and hold the production declaration. The subsistence miner does not issue a certificate of origin. Panners also need the municipal registration certificate and the RUT.

If the operation exceeds those limits or uses equipment, it is no longer subsistence and needs a title or a formalization structure.

It is a zone the Mining Authority delimits temporarily, for social or economic reasons, in areas where informal traditional mining operations already exist.

• While it lasts, no new proposals from third parties are admitted over the area.
• The authority carries out the geological and mining studies, which may take no longer than two years.
• The concession is granted only to the communities that have traditionally mined the area, through a special concession contract.
• It is requested by organized mining communities, not by a company.

The Single Registry of Mineral Traders (RUCOM) is the Mining Authority's database in which mineral traders are registered. The same platform publishes the lists of those who mine the mineral.

• Must register: mineral traders and owners of processing plants that are not part of a project covered by a mining title.
• Do not register, but appear as authorized mining operators: the mining title holder in the production stage, the legalization or formalization applicant with legal authorization, the beneficiary of a Special Reserve Area while it is being decided, the formalization subcontractor and the subsistence miner. The Mining Authority publishes them in the RUCOM.
• Supporting document for each sale: the certificate of origin, issued by the authorized mining operator. The subsistence miner does not issue one: they sell with the production declaration and, if a panner, with the municipal registration certificate.

Without those documents, an authorized trader cannot buy the mineral.

SAGRILAFT is the name by which the anti-money-laundering system for companies is known. External Circular 100-000020 of 2026 of the Superintendency of Companies merged it with the PTEE (transparency and business ethics program) into a single system. Its full name is the Self-Control and Risk Management System for Money Laundering, Terrorism Financing, Financing of the Proliferation of Weapons of Mass Destruction, Domestic Corruption and Transnational Bribery. Whether it applies depends on the activity registered in the commercial registry (CIIU code) and on the size of the company:

• Full system, general rule: supervised or controlled companies with total revenue or total assets equal to or greater than 4,929,017 UVB, as of 31 December of the previous year.
• Full system, trading in precious metals and stones: supervised or controlled companies with CIIU 4662, 3211, 2421 or 0722 (the last being the extraction of gold and other precious metals), with total revenue or assets from 3,696,762 UVB.
• Minimum-measures regime: companies with total revenue from 369,676 UVB or total assets from 616,127 UVB whose CIIU is one of those of the mining and energy sector (B05 coal, B07 metal ores, 4662) or of trading in precious metals and stones (0722, 3211, 2421). Quarries and construction materials (B08) are on neither list.

The thresholds are in basic value units (UVB), not in minimum wages. To know whether your company is subject to the system, the conversion must be made with the UVB value of the reference year.

Under the minimum-measures regime the responsible person is the legal representative, not a compliance officer. Companies that already had a system have until 31 May 2027 to adjust it. In the meantime, what they have implemented is deemed valid.

Even if a mining company is not required to comply, banks apply their own system (SARLAFT) and RUCOM traders require proof of origin and anti-money-laundering controls. Having equivalent policies and documentation makes it easier to open accounts and sell the mineral.

Under External Circular 100-000020 of 2026 of the Superintendency of Companies, the first thing is to know which regime your company falls under, because the full system and the minimum-measures regime do not require the same things. In general, the path is this:

1. 1Determine whether you are required to comply and under which regimeCheck the CIIU registered in the commercial registry and the total revenue and assets as of 31 December of the previous year, against the UVB thresholds in the previous question.
2. 2Appoint the responsible personUnder the minimum-measures regime it is the legal representative. Under the full system a principal and an alternate compliance officer are appointed, holding a professional degree, reporting to the board of directors or the highest corporate body.
3. 3Identify and measure your risksIn a mining company the usual sources are mineral suppliers, buyers, operating zones and the form of payment. The full system goes through four stages: risk identification, measurement, control and monitoring.
4. 4Write the policies and proceduresCounterparty due diligence, screening of binding lists and retention of records. They are approved by the board of directors or the highest corporate body.
5. 5Report to the UIAFSuspicious transactions are reported (ROS). If there were none in the quarter, the absence report (AROS) is submitted.
6. 6Train staffAt least once a year.
7. 7Follow up and meet the deadlinesIf your company already had a system, it has until 31 May 2027 to adjust it to the new circular. A company that becomes subject to the system implements it no later than 31 May of the following year.

With a cash flow model that starts from what the geology and the mine plan support: tonnage, grade, plant recovery and production rate. On that cash flow the indicators are calculated and the project's sensitivity to its assumptions is tested.

• Net present value (NPV): the future cash flow discounted at a rate that reflects the cost of capital and the risk. If it is positive, the project creates value at that rate.
• Internal rate of return (IRR): the rate at which the NPV becomes zero. It is compared with the minimum return the investor requires.
• Payback period: how long the cumulative cash flow takes to return the initial investment.
• Cost per ounce or per tonne: what it costs to produce one unit, adding operation, processing, royalties and administration, against the selling price. It shows the real margin.
• Sensitivity to price and grade: how NPV and IRR change if the price falls or the grade turns out lower than estimated. A project that only works in the optimistic scenario is fragile.

Royalties are a percentage of the value of production at the mine mouth or mine edge. For gold and silver it is 4 %, and for alluvial gold under concession contracts, 6 %. Coal pays 5 % if production is below 3 million tonnes per year and 10 % if above. Construction materials pay 1 %, and emeralds and other precious stones, 1.5 %.

The base price for settling royalties is set by the UPME: quarterly for precious metals, metallic minerals and coal, and annually for non-metallic minerals. For gold, silver and platinum the base is 80 % of the average international price of the previous month on the London Metal Exchange. The UPME warns that those prices serve to settle royalties and not as a market reference.

This evaluation works with the available geological information and makes explicit the degree of certainty of each assumption. It does not replace a resource and reserve report under the Colombian Standard for the Public Reporting of Exploration Results, Mineral Resources and Reserves.

Two layers, required at the same time:

• Mining safety regulation: for underground workings, Decree 1886 of 2015, amended by Decree 944 of 2022. For open-pit mining, Decree 539 of 2022, which repealed Decree 2222 of 1993.
• Occupational Health and Safety Management System (SG-SST): mandatory for every employer, with the minimum standards of Resolution 0312 of 2019. Because mineral extraction is in risk class V, a mine meets the 60 standards even if it has ten workers or fewer.

Both are verified during the oversight visits of the Mining Authority and the labour authority.

With the same standards as a large mine, because the regulation measures risk and not just size. The extraction of coal, gold, construction materials and emeralds is in risk class V. With risk class IV or V, the company meets the 60 minimum standards of Resolution 0312 of 2019 even if it has ten workers or fewer. The reduced table of 7 standards does not apply to it. In practice, the system is set up like this:

1. 1Carry out the initial assessmentIt identifies the priorities in occupational health and safety. It is the basis of the annual work plan.
2. 2Write the OHS policyIn writing, dated and signed by the legal representative, covering all workplaces and all workers. It is reviewed at least once a year.
3. 3Identify hazards and assess risksWith a systematic methodology covering routine and non-routine tasks, from the working face to the processing plant. It is documented and updated at least every year.
4. 4Build the annual work planWith the activities to achieve each objective of the system. Since 2020 the SG-SST runs each year, from January to December.
5. 5Incorporate the mining safety regulationThe SG-SST does not replace the regulation: underground workings fall under Decree 1886 of 2015, amended by Decree 944 of 2022, and open-pit workings under Decree 539 of 2022. Their requirements are planned within the system.
6. 6Investigate incidents and accidentsEvery incident, occupational accident or occupational disease is investigated to find its causes, following the procedure of Resolution 1401 of 2007.
7. 7Self-assess and prepare the improvement planBelow 60 % the result is critical. Between 60 % and 85 % it is moderately acceptable, and above 85 %, acceptable. That result guides the following year's plan.