Mining disclosure ยท Canada and S-K 1300
NI 43-101 Technical Report: QP, 27 Items, 45-Day Rule
A NI 43-101 technical report backs up what a Canadian-listed miner tells investors: 27 items on Form 43-101F1, a Qualified Person’s signature, CIM resource categories, and filing within 45 days of a first resource. Rules, tables and calculators below.

Key takeaways
- Every scientific or technical statement about a material mineral project, including on a website, must be prepared, supervised or approved by a Qualified Person (s. 2.1).
- Resources use only the CIM categories Inferred, Indicated and Measured, reported separately, with Inferred never added to the others (s. 2.2).
- An exploration-stage report uses 19 of the 27 Form 43-101F1 items; items 15 to 22 apply only to advanced properties.
- A first-time resource, reserve or PEA in a news release needs its technical report filed within 45 days, usually by an independent QP.
- The CSA proposed in June 2025 to replace the instrument; at the October 2026 check regulators showed no final rule, so the 2011 text still governs.
In this article
- When a 43-101 technical report is required, and the 45-day rule
- What a 43-101 technical report contains: the 27 items of Form 43-101F1
- Who writes it: the Qualified Person under NI 43-101
- Inferred, Indicated and Measured: the CIM categories in a report
- What a junior may say before it has a resource
- How to read a technical report in ten minutes
- How many technical reports get filed, and by whom
- Where NI 43-101 came from: Bre-X to the current text
- The CSA proposal to replace NI 43-101, and where it stands
- NI 43-101 vs S-K 1300 vs JORC
- Where satellite data fits before a technical report
- Key terms
- Frequently asked questions about NI 43-101
Short answer. A NI 43-101 technical report (often searched as 43101) is the document that backs up what a Canadian-listed mining company tells investors about a property. It follows the 27-item Form 43-101F1, it is written or supervised by a Qualified Person (QP), meaning a professionally registered geoscientist or engineer with at least five years of relevant experience, and it uses only the CIM resource categories: Inferred, Indicated and Measured. When a news release shows a first-time resource, reserve or preliminary economic assessment, the supporting report is due on SEDAR+ within 45 days (unofficial consolidation).
This page works from the instrument itself, as listed on the British Columbia Securities Commission instrument page, and from the CIM Definition Standards it incorporates. It is written for the people who live with the rule: licence owners selling or optioning a project, consultants who commission reports, investors who read them, and the CEOs, geologists and investor-relations teams who publish them. The spellings “43-101” and “NI43101” both name the same instrument. For the Australian equivalent, see our explainer on the JORC Code, and for how a resource number is built, our guide to mineral resource estimation.
The rest of the page is arranged by the questions people ask in this order: when is a report required and how fast, what is inside it, who may sign it, what the resource categories mean, what a company without a resource may say, how to read a report quickly, where the rule came from, what is proposed to replace it, and how it compares with the US and Australian systems.
When a 43-101 technical report is required, and the 45-day rule
The instrument is the Canadian Securities Administrators’ (CSA) rule, so it binds the issuer, not the rock. Section 1.1 defines disclosure as any oral statement or written disclosure made by or for an issuer that is intended to be, or is reasonably likely to be, available to the public in a Canadian jurisdiction. A conference talk, a CEO’s social post, a roadshow slide and a map on the company website are all inside it. A TSX Venture junior drilling in Nevada, Ghana or Peru is bound by the instrument for everything it says in Canada about those projects. Oil and gas fall outside the definition of a mineral project; metals, coal, diamonds, industrial minerals and royalty interests in them fall inside it.
Infographic
From drill hole to filed technical report: six steps
- 1Drill and assayA QA/QC program runs with the work and is summarized in every release (s. 3.3).
- 2QP verifies the dataData verification plus a current personal inspection of the property (s. 3.2, 6.2).
- 3Estimate in CIM termsInferred, Indicated and Measured, each reported separately (s. 2.2).
- 4Disclose with the factsQP name, effective date, key assumptions and risks (s. 3.1, 3.4).
- 5File within 45 daysForm 43-101F1 report with each QP’s certificate and consent (s. 4.2(5), 8.1, 8.3).
- 6Reconcile in a releaseA news release on filing explains any material differences (s. 4.2(5)(b)).
Section 4.1 requires a technical report for each material property when an issuer first becomes a reporting issuer in Canada. Section 4.2 then lists the documents that trigger a filing: a preliminary long form prospectus, an annual information form (AIF), a valuation, certain circulars and offering documents, and the one most juniors meet, paragraph 4.2(1)(j). That paragraph covers written disclosure, such as a news release, that reveals for the first time resources, reserves or preliminary economic assessment (PEA) results that are a material change for the issuer, or a material change to them since the last report.
For the 4.2(1)(j) trigger, the report is due 45 days after the disclosure, or earlier in two cases: on the filing date if the same disclosure appears in a preliminary short form prospectus, or 3 business days before a take-over bid expires if it appears in a directors’ circular. If a property becomes material less than 30 days before the AIF deadline, the issuer has 45 days from that date. When the numbers were prepared and filed by another issuer that holds or held the property, the filing window stretches to 180 days, provided the release names that report, its date, the other issuer and the QP who reviewed it, and states there is no new material information (section 4.2).
The news release is a summary and the technical report is the record. When the two disagree, section 4.2(5)(b) makes the issuer reconcile the material differences in a news release at the time it files the report. The calculator below counts the days left on your clock.
What the rule does not do
- It does not tell anyone how to drill or assay. It regulates who signs, the words used and what the disclosure must contain.
- It does not define the resource categories itself. Sections 1.2 to 1.4 adopt the CIM Definition Standards for resources, reserves and studies, as amended.
- It does not demand an independent QP for every statement. Independence is required for specific reports, set out in section 5.3 and covered below.
- It does not cover filings made only under non-securities law. A report lodged with a mining ministry to meet a mining-law requirement is not “disclosure” just because it becomes public.
Who must have a report, and who does not
Not every company on a Canadian exchange files one every year. A report is event-driven: it is triggered by an event such as an IPO, a first resource, a PEA or a material change, not by the calendar. A junior with only claims and a drill plan, and no resource, need not file a report just to announce drill results. It must still follow Part 3 on how those results are worded, which is covered in the exploration section below. Producing issuers with C$30 million of revenue in the last year and C$90 million over the last three can in many cases skip the independence test, with conditions in sections 5.3(2) and 5.3(3).
Calculator
How many days are left to file your technical report?
Enter the days since your first-time disclosure, and your window if a prospectus or circular shortens it.
- Filing deadline, days after disclosure: 45
- Days left on the other-issuer route, s. 4.2(7): 170
Assumptions: section 4.2(5)(a) as in force from 30 June 2011: 45 days after the disclosure, or earlier if the same disclosure is in a preliminary short form prospectus (its filing date) or a directors’ circular (3 business days before the bid expires); enter that shorter window in the second field if it applies. The third line applies only when every condition in section 4.2(7) is met. Calendar days. A replacement instrument was proposed in June 2025 and is not in force. General information, not legal advice.
What a 43-101 technical report contains: the 27 items of Form 43-101F1
Form 43-101F1 fixes the order of every technical report, so a gold project in Nevada and a lithium project in Quebec read the same way. The form’s instruction (4) is the part juniors often miss: the QP must use the headings of Items 1 to 14 and 23 to 27 for every report, and the headings of Items 15 to 22 only for an advanced property. An advanced property is one with mineral reserves, or with resources whose potential viability is supported by a PEA, pre-feasibility or feasibility study. So an exploration-stage report has 19 headings, not 27.
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The 27 items of Form 43-101F1 by group
Number of items per group; items 15 to 22 only for advanced properties
| Items | Headings | Required for |
|---|---|---|
| 1 to 3 | Summary; Introduction; Reliance on Other Experts | Every report |
| 4 to 8 | Property Description and Location; Accessibility, Climate, Local Resources, Infrastructure and Physiography; History; Geological Setting and Mineralization; Deposit Types | Every report |
| 9 to 12 | Exploration; Drilling; Sample Preparation, Analyses and Security; Data Verification | Every report |
| 13 to 14 | Mineral Processing and Metallurgical Testing; Mineral Resource Estimates | Every report |
| 15 to 22 | Mineral Reserve Estimates; Mining Methods; Recovery Methods; Project Infrastructure; Market Studies and Contracts; Environmental Studies, Permitting and Social or Community Impact; Capital and Operating Costs; Economic Analysis | Advanced properties only |
| 23 to 27 | Adjacent Properties; Other Relevant Data and Information; Interpretation and Conclusions; Recommendations; References | Every report |
Experienced readers turn to Items 11 and 12 first. They show which labs were used, what standards, blanks and duplicates went into the sample stream, and whether the QP checked the database against original records. Item 14 must give the estimation method, the cut-off grade and the assumptions. Item 26 sets out the recommended work program with a cost breakdown for each phase, no more than two phases, each ending in a decision point, which is why financiers read it closely. If you commission assays for a program like this, see our guides to assay services for mining and choosing a gold assay lab, and for the core behind Items 10 and 11, geological core samples.
Every report also needs a title page, a dated signature page, a table of contents and legible, dated maps with a scale, a north arrow and a legend, including a location map and a geology compilation map. Three more rules shape the document. The report carries an effective date, which is the date of the most recent scientific or technical information in it, often months before the filing date. Section 6.4 bars a QP from disclaiming their own part of the report, outside the narrow reliance allowed by Item 3. And section 6.3 makes the issuer keep assay and analytical certificates, drill logs and other underlying information for 7 years.
Exploration-stage report versus advanced-property report
The difference is the size of the document and the burden of proof. An exploration-stage report on a claim block describes history, geology, the exploration done, and a two-phase budget. An advanced-property report adds mining and processing methods, infrastructure, markets, permitting, costs and a cash-flow model, and it is the version lenders put through their own review. Because each study level carries different cautions, our guide to scoping, pre-feasibility and feasibility studies explains how each one is built.
Who writes it: the Qualified Person under NI 43-101
Ask a securities lawyer which definition matters most and most will point to the Qualified Person. Section 2.1 says all disclosure of scientific or technical information about a mineral project on a property material to the issuer must be based on information prepared by or under the supervision of a QP, or approved by one. The issuer and its directors still own the disclosure. The QP is the technical gatekeeper, and section 3.1 adds that every written disclosure must name the QP and state their relationship to the issuer.
A QP is an individual who meets five tests in section 1.1:
- An engineer or geoscientist with a university degree, or equivalent accreditation, in geoscience or engineering relating to mineral exploration or mining.
- At least five years of experience in mineral exploration, mine development or operation, or mineral project assessment, or a combination, relevant to that degree or area of practice.
- Experience relevant to the subject matter of the mineral project and the technical report.
- Good standing with a professional association.
- If the association is foreign, a designation that requires a position of responsibility and independent judgment, plus a favourable confidential peer evaluation or a recommendation by at least two peers and demonstrated prominence in the field.
The professional association test carries the weight. The body must admit members on qualifications, experience and ethical fitness, require professional standards, encourage continuing development, and have and apply the power to suspend or expel a member wherever they practise. In Canada that usually means a provincial engineering or geoscience regulator. Relevant experience is not a box-ticking exercise: the CIM Definition Standards say a QP should be able to face their peers and show competence in the commodity, deposit type and situation. CIM’s own example is that for a vein gold estimate, experience in high-nugget vein-type mineralisation such as tin or uranium is relevant, while experience in massive base-metal deposits may not be (CIM Definition Standards, 2014). Team estimates are normal, and CIM recommends that each QP takes responsibility for the part they did.
Independence: when the QP must come from outside
Section 1.5 makes a QP independent if no circumstance, in the view of a reasonable person aware of all the facts, could interfere with their judgment. Section 5.3 then lists when every QP on a report must be independent at both the effective date and the filing date.
| Trigger (section) | Situation | Independent QP needed |
|---|---|---|
| 5.3(1)(a), 4.1 | First technical report on becoming a reporting issuer | Yes |
| 5.3(1)(b) | Report supporting a long form prospectus or a valuation | Yes |
| 5.3(1)(c)(i) | First-time disclosure of resources, reserves or PEA results | Yes, for the triggers listed |
| 5.3(1)(c)(ii) | A 100% or greater change in total resources or reserves | Yes, measured from the last independent report |
| 5.3(2), 5.3(3) | Producing issuer (C$30 million revenue last year and C$90 million over three years) | Generally no, with conditions |
In practice independence is the norm. In its 2025 notice the CSA estimated that about 87% of the technical reports filed in a recent four-year window were prepared by independent QPs: 65% by consulting firms, 22% by individual consultants and 13% by internal QPs (CSA notice, 12 June 2025). The figures describe reports filed by issuers whose principal regulator is the Ontario Securities Commission.
The site visit and the certificate
Section 6.2 requires at least one QP responsible for the report to complete a current personal inspection of the property before the issuer files. There is one narrow exception: for an early-stage exploration property (no current resources or reserves and no drilling or trenching proposed), the visit can wait if seasonal weather blocks access, provided the report and the disclosure say so and give a timetable. The issuer must then complete the visit as soon as practical and refile. Every report ends with a certificate for each QP (section 8.1) and a signed consent (section 8.3). The certificate states the QP’s qualifications and associations, the date and duration of the most recent site visit, the items they are responsible for, whether they are independent, and any prior involvement with the property.
Read the certificate page before the summary. Two minutes on the QP certificates answers most credibility questions: which professional body, how many years of relevant experience, when the site visit happened, which items each person signed, and whether they are independent. A report on a gold project signed by someone whose experience is all in coal deserves a second look.
Inferred, Indicated and Measured: the CIM categories in a report
Resource estimation under the rule uses only the categories in the CIM Definition Standards on Mineral Resources and Mineral Reserves, adopted by CIM Council in May 2014. A Mineral Resource is a concentration or occurrence of solid material of economic interest in such form, grade or quality and quantity that there are “reasonable prospects for eventual economic extraction”. The QP has to state the basis for that judgment, including the cut-off grade (the lowest grade that is still worth mining), recovery, commodity price, mining and processing method and the costs assumed (CIM, Canadian Mineral Resource and Mineral Reserve Definitions).
| Category | Confidence in the evidence | What it may support | May become |
|---|---|---|---|
| Inferred Mineral Resource | Limited evidence and sampling; enough to imply, not verify, continuity | Only a PEA, with the cautionary language in s. 2.3(3); never pre-feasibility or feasibility economics | Nothing. It must not be converted to a reserve |
| Indicated Mineral Resource | Adequately detailed and reliable; enough to assume continuity between points | Mine planning and a pre-feasibility study | Probable Mineral Reserve only |
| Measured Mineral Resource | Detailed and reliable; enough to confirm continuity between points | Detailed mine planning and final evaluation of viability | Proven or Probable Mineral Reserve |
The line between an inferred and an indicated resource is the one that moves money in any technical report. Indicated material can feed a pre-feasibility study and, with the Modifying Factors applied (mining, processing, metallurgical, infrastructure, economic, marketing, legal, environmental, social and governmental considerations), become a Probable reserve. Inferred material cannot. CIM says Inferred resources must not be included in the economic analysis, production schedules or mine life of publicly disclosed pre-feasibility or feasibility studies, though it is reasonably expected that most of it could be upgraded to Indicated with more drilling. A Mineral Reserve is the economically mineable part of a Measured or Indicated resource, demonstrated by at least a pre-feasibility study, including dilution and losses. Older reserve figures often came from classical tonnage methods, covered in our guide to ore reserve estimation methods.
Four rules for every resource number (s. 2.2)
- Use only the CIM categories.
- Report each category separately and say how much of the reserves are included in the resources.
- Never add Inferred to the other categories.
- If contained metal is stated, also give the grade and quantity for each category.
When the disclosure is written, section 3.4 adds the effective date of each estimate, the key assumptions, parameters and methods, any known legal, political, environmental or other risks that could affect development, and, if there is an economic analysis, an equally prominent statement that resources that are not reserves do not have demonstrated economic viability.
What section 2.3 forbids
Section 2.3 lists four kinds of number an issuer must not publish, and they are exactly the numbers a promoter most wants to show:
- Quantity, grade or metal content of a deposit that has not been categorized as a resource or reserve.
- An economic analysis that includes Inferred resources, unless it is a PEA that carries the prescribed cautions.
- The gross value of metal in a deposit, a sampled interval or a drill intersection.
- A metal-equivalent grade without the grade of each metal used to build it.
Section 2.3(4) adds a naming rule: an issuer must not call a study “pre-feasibility” or “feasibility” unless it meets CIM’s definition. A headline that multiplies ounces by today’s gold price is exactly the gross metal value section 2.3(1)(c) prohibits, so “billions of dollars in the ground” is a banned number. If a Canadian reporting issuer publishes one, read the rest of its disclosure with extra care.
Old numbers: historical estimates
Many properties arrive with estimates made by a previous owner, sometimes decades old and in other vocabulary. The instrument defines a historical estimate as one that the issuer has not verified as a current resource or reserve and that was prepared before the issuer acquired, or agreed to acquire, an interest in the property. Section 2.4 lets an issuer mention one, in its original terms, only if it gives the source and date, comments on relevance and reliability, the key assumptions and methods where known, whether it uses non-CIM categories, any more recent data, the work needed to verify it, and an equally prominent statement that a QP has not done enough work to classify it as current and the issuer is not treating it as current. In practice a historical estimate is a lead for new drilling, not an asset to value. If you are deciding what an old estimate is worth to a buyer, our guide on how to sell a mine covers valuation and deal types, and types of ore deposits explains why grades and tonnages differ so much by deposit style.
What a junior may say before it has a resource
Most TSX Venture and CSE issuers have no resource at all. They have claims, a geological idea, some samples and a drill plan. The instrument still applies to every word, and Part 3 sets the bar for written disclosure of exploration information on a material property. Under section 3.3(1), any written disclosure of exploration information must summarize the material results of surveys and investigations, the interpretation of that information, and the quality assurance program and quality control measures used while the work was done. Section 3.2 adds a statement on whether a QP has verified the data, how, any limits on that verification, and an explanation of any failure to verify.
Rules for drill and sample results
When a release carries sample, analytical or test results, section 3.3(2) requires, for those results:
- the location and type of the samples;
- the location, azimuth and dip of the drill holes, and the depth of the sample intervals;
- a summary of the relevant analytical values and widths and, as far as known, the true widths of the mineralized zone;
- the results of any significantly higher-grade intervals inside a lower-grade intersection;
- any drilling, sampling, recovery or other factors that could materially affect accuracy or reliability; and
- the type of analytical procedure, sample size, and the name and location of each laboratory, plus any relationship between the lab and the issuer.
Section 3.5 lets a release skip some of these details by referring to the title and date of a previously filed document that already complies. Most juniors use a standard paragraph for QA/QC and a link to the last technical report, and keep the hole-by-hole table in the release itself.
Exploration targets: the only potential size you may publish
Before a resource exists, the one door open is section 2.3(2). An issuer may disclose the potential quantity and grade of a target for further exploration, expressed as ranges, if it states with equal prominence that the figures are conceptual, that exploration has been insufficient to define a mineral resource, and that it is uncertain whether further work will define one, and if it states the basis for the ranges. The calculator below shows why ranges from a junior can look wide. At its default ranges of 2 to 4 million tonnes and 1.0 to 1.5 g/t, the low and high cases differ by a factor of three. That spread is the honest answer at this stage, and the reason the rule bans single numbers. The calculator has no price input on purpose, because the gross metal value of a target is banned outright.
Investors: look for the three cautions next to any target. A compliant exploration target carries all three statements at equal prominence, plus the basis for the ranges. A target quoted as a single tonnage and grade, or with a dollar value, does not meet section 2.3(2). The CSA reviewed issuers’ website presentations in Staff Notice 43-309 (2015) and found room for improvement. Because written disclosure includes websites, a “resource potential” slide or an old historical estimate left on an investor page without the section 2.4 caveats is a disclosure problem, not a marketing one. For where exploration targets come from in the first place, see our mineral exploration guide and the overview of geophysical survey methods, and for how drilling choices follow, exploration drilling technologies. General information, not investment advice.
Calculator
How wide is your exploration target range in ounces?
Enter the low and high ends of your tonnage and grade ranges to see the conceptual contained-ounce range.
- High case, troy ounces in situ: 192,904
- High case as a multiple of the low case: 3.0
Example values only. Formula: troy ounces = tonnes x grade (g/t) / 31.1035, applied to the low ends together and the high ends together. Section 2.3(2) lets an issuer disclose potential quantity and grade only as ranges with the prescribed cautions. There is no price input on purpose: gross metal value is banned by s. 2.3(1)(c). Not a mineral resource. General information, not legal or investment advice.
โถ Farmonaut video: the five numbers that matter in a satellite gold exploration report. ยท 2:00
How to read a technical report in ten minutes
A full report can run to several hundred pages. Investors, lenders and buyers’ consultants usually triage it in a fixed order, and the order below answers the questions that decide whether to read on.
- Certificate page. Which professional body, which items each QP signed, the date of the site visit, and whether they are independent (section 8.1).
- Effective date. A resource is tied to a drill database and to price assumptions as of that date. A report whose effective date is years old tells you about the past.
- Item 14 table. Tonnes, grade and contained metal for each category, with the cut-off grade and the metal price used. If you cannot find the cut-off and the price, keep reading until you do.
- Items 11 and 12. Lab names, standards, blanks, duplicates, and what the QP did to verify the database.
- Item 25 and 26. The conclusions and the work program. A two-phase budget with a decision point is what a compliant exploration-stage report looks like.
- Item 1 last. The summary is written by the same author as everything else, but readers often accept it without checking the body.
Six common mistakes when reading a 43-101 report
- Treating Inferred tonnes like reserves. CIM bars converting Inferred to reserves and keeps them out of pre-feasibility and feasibility economics.
- Adding the categories. A “total resource” that adds Inferred to Indicated and Measured is not a compliant figure under section 2.2.
- Ignoring the effective date. The estimate is only as current as the drilling behind it.
- Reading “Qualified Person” as “independent”. The certificate says which; not every report needs an independent QP.
- Reading historical estimates as current. They need the section 2.4 caveats and are not resources.
- Missing the price and cut-off. A resource only means something against a stated cut-off and commodity price.
For how these reports feed financing decisions, see our guides to mining project finance modelling and finding mining investors. If you hold a royalty rather than a project, selling mineral royalties describes how buyers value one; note that the 2025 proposal would end the technical report requirement for royalty-only issuers.
How many technical reports get filed, and by whom
The CSA’s own cost-benefit analysis gives a rare look at the volume. Reporting issuers whose principal regulator is the Ontario Securities Commission file about 180 technical reports a year, from an average of about 120 issuers, which is roughly 36% of the reporting issuers with mineral projects in that group. The split by project stage shows that most reports are written for companies without a mine: exploration and mineral-resource reports make up 70% of the total (73 and 53 of 180), PEA reports 12%, reserve-stage development reports 9%, and production reports 8%.
Chart
Technical reports filed per year, by project stage
Average per year over four years; about 180 reports, issuers regulated principally by the OSC
That mix is why the exploration-stage and early-resource items of the form matter most to most readers. About three reports in ten (PEA, reserve-stage and production together, 53 of 180) carry the full set of mining, processing and economic items. The figures are the CSA’s approximate breakdown of reports filed per year over the previous four years, in its notice of 12 June 2025.
Where NI 43-101 came from: Bre-X to the current text
The rule took effect on 1 February 2001, in response to the 1997 Bre-X scandal, in which a Canadian company falsely claimed a major gold discovery at Busang in Indonesia; it replaced the earlier National Policy 2-A (CIM Magazine). The lesson regulators took from it is the one still visible in the rule today: technical claims to the public must be traceable to a named, accountable, professionally registered person, and the numbers must be stated in agreed categories so that investors can compare one project with another.
Chart
How long each text of the rule has run
Years after 1 February 2001; current text counted to 29 October 2026
The instrument has had three texts. The first took effect in 2001, a replacement in 2005, and the current text in force from 30 June 2011, which replaced the 2005 version and the earlier form and policy. Later amendments, the most recent in 2023, dealt with the move to the SEDAR+ filing system rather than with the substance. The chart shows how long each text has run, with the current one counted to 29 October 2026 (ASC consolidation).
The CSA’s consultation in April 2022 led to the proposal described next. In that consultation the CSA said it received 85 comment letters from issuers, individuals, consulting and law firms, regulatory organizations and advocacy groups, including groups representing Indigenous Peoples.
The CSA proposal to replace NI 43-101, and where it stands
On 12 June 2025 the CSA published for a 120-day comment period a proposal to repeal and replace the instrument, its Companion Policy and Form 43-101F1. Comments closed on 10 October 2025. CIM reported that the CSA was reviewing submissions and finishing drafting, and that the existing instrument remains in force until a new one takes effect (CIM Magazine). On 29 October 2026 the Ontario Securities Commission’s instrument page still listed the June 2025 notice and a separate 14 May 2026 proposal on take-over bid and beneficial ownership reporting as proposals, and showed no final replacement (OSC instrument page). So the 2011 text governs today. A final notice would set the effective date, so confirm the status on the OSC, ASC or BCSC page before relying on any wording here.
Changes the proposal would make
- Qualified Person. Drop the separate education test, which licensing already covers, and count the five years of experience after registration as a professional geoscientist or engineer, with clearer guidance on what “relevant to the subject matter” means.
- All projects. Scientific and technical disclosure on material and non-material projects alike would need a QP, and the prescribed written-disclosure rules on data verification, exploration information and resources would apply to both.
- No more stage split. The “early stage exploration property” and “advanced property” definitions would go, so one form fits every stage. The CSA also proposes “relevant” in place of “material” scientific and technical information in the report.
- Site visits. The seasonal deferral of the personal inspection would be removed, and each QP would report the inspection in a standalone item.
- New CIM terms. “Scoping study” replaces “preliminary economic assessment”, “exploration target” replaces “target for further exploration”, and “life of mine plan” is added.
- Foreign codes and royalties. Technical reports would use CIM definitions only, and royalty-only issuers would no longer file technical reports.
- Resources, adjacent properties and data checks. More disclosure on how reasonable prospects for eventual economic extraction were judged, on classification and on attributable percentage; cautionary statements on adjacent-property mineralization; data verification disclosed for every item, not only drilling; and no disclaimers of scientific or technical information anywhere.
- Environmental and social items. Dates and sources for environmental, permitting and social information, and disclosure about permits, agreements and negotiations with Indigenous Peoples, rightsholders or communities concerning the project.
The source for this list is the CSA’s notice itself (CSA Notice and Request for Comment, 12 June 2025). It does not propose requiring artificial intelligence, remote sensing or quarterly technical updates; it is a tidy-up of terminology, the QP test and the site visit, and a tightening of environmental, social and data-verification disclosure.
What to do while the old text still applies
Treat the 2011 text as binding and the proposal as a preview. An issuer commissioning a report today can already write it in the direction the proposal points: state the site visit clearly, document data verification item by item, date its environmental and social information, and use the words “scoping study” and “exploration target” alongside the current defined terms if its counsel agrees. Do not describe a report as meeting the proposed text. A report meets the instrument in force or it does not.
NI 43-101 vs S-K 1300 vs JORC
Canadian juniors often hold ground in Nevada, Idaho, Arizona or Alaska, and some list in the United States. That raises two separate questions: which rule governs the project, and which rule governs the filing. The location of the project decides neither. It applies to everything the issuer discloses in Canada. Whether the SEC’s S-K 1300 also applies depends on whether the company is an SEC registrant, and on how it files.
The SEC adopted subpart 1300 of Regulation S-K on 31 October 2018, replacing Industry Guide 7, and registrants had to comply from their first fiscal year beginning on or after 1 January 2021 (SEC press release 2018-248). Searchers often write it as SK 1300. It applies to a registrant whose mining operations are material to its business, judged on quantitative and qualitative factors and aggregated across all properties (17 CFR subpart 229.1300).
- Form 40-F filers. Canadian issuers eligible for the SEC’s multijurisdictional disclosure system (MJDS) file on Form 40-F and can generally keep reporting under the Canadian rule.
- Form 20-F and 10-K filers. S-K 1300 governs the SEC filing, so a QP often signs off under both systems.
- No SEC registration. A junior that trades only in Canada, or on US over-the-counter markets without SEC registration, reports under the Canadian rule alone. Confirm your status with US counsel.
| Point | NI 43-101 | S-K 1300 | JORC Code |
|---|---|---|---|
| Legal status | Canadian securities rule | US federal regulation (17 CFR 229.1300 to 229.1305) | Professional code, made binding through ASX and NZX listing rules |
| Accountable expert | Qualified Person: engineer or geoscientist, 5 years, good standing | Qualified person: mineral industry professional with 5 years in the deposit type and the specific activity | Competent Person, 5 years relevant experience |
| Basis for a resource | QP’s view of reasonable prospects for eventual economic extraction | An initial assessment, a preliminary technical and economic study by a QP | Reasonable prospects for eventual economic extraction |
| Supporting document | Technical report on Form 43-101F1, filed on SEDAR+ | Technical report summary filed as an exhibit | Public Report with the Table 1 checklist |
| Early-stage potential | Target for further exploration, ranges plus cautions (s. 2.3(2)) | Exploration target in a separately captioned section (Item 1302(c)) | Exploration Target, ranges plus cautionary statement |
| Price used | Assumption stated by the QP | A reasonable and justifiable price chosen by the QP and disclosed | Assumption stated by the Competent Person |
The row that changes budgets is the basis for a resource. Under S-K 1300, mineral resource disclosure must rest on a QP’s initial assessment that includes reasonably assumed technical and economic factors (Item 1302(d)). Under the Canadian rule, a junior can publish a first resource with the QP’s statement on reasonable prospects and no formal economic study. S-K 1300 also says exploration results alone cannot be used to derive tonnage, grade or production estimates. For a junior moving to a US listing, that is often the line item that surprises the CFO.
Summary disclosure differs too. A registrant with several properties must summarize resources and reserves by commodity and geographic area and for each property holding 10% or more of its combined Measured and Indicated resources or of its reserves (Item 1303). The good news is that the categories line up: all three systems follow the CRIRSCO template, and CRIRSCO’s member list shows both CIM (Canada) and SME (United States) as members (CRIRSCO members). The JORC Code 2012 edition uses “Ore Reserve” and “Proved” where CIM uses “Mineral Reserve” and “Proven”. A dual-listed company may show one deposit as a Canadian-standard resource in Canada and as an S-K 1300 resource in the US; the tonnes and grade should match or be reconciled, and the filings should explain any difference. For how to read the Australian tables, see our explainer on what JORC means in mining. General information, not tax, legal or investment advice; confirm with your advisers and the exchange.
Where satellite data fits before a technical report
The rule does not say which exploration technologies a QP may use. It governs the standard the results must meet when they are disclosed. That leaves a clear place for satellite analysis at the very start: deciding where to map, sample and drill, so that the data a QP later verifies comes from the right ground. For a licence owner it also means screening a block before buying or optioning it, and for a consultant it means mapping alteration and structure before a drill program is designed. Canadian claim systems differ by province, and our guide to gold exploration in Canada compares them; the Canada mineral deposits map shows where each metal is mined.
Farmonaut’s satellite-based mineral detection analyses multispectral and hyperspectral imagery to flag likely mineralised target zones, alteration halos, faults and fractures, with no ground disturbance. It takes coordinates, a KML or KMZ file or a polygon, plus country and target mineral, and delivers a PDF with georeferenced GIS files in 5 to 20 business days. Farmonaut states up to 80 to 85% lower early-exploration cost and timelines cut from months to days compared with starting on the ground, across 100,000+ hectares, 20+ minerals and 25+ countries.
What it is not. Farmonaut reports describe exploration targets. They are not Canadian technical reports or S-K 1300 technical report summaries, not mineral resources or reserves under the CIM Definition Standards, and no Qualified Person prepares or approves them. An issuer that discloses anything from them must have a QP take responsibility first, and any potential size must follow section 2.3(2).
To start, draw your claim block on mining.farmonaut.com or request a quote through the mining query form.
Before anyone sets foot on the ground. Hold a valid claim or licence first, from the provincial, territorial or state regulator; our mining cadastre portal guide by country lists the registries. Get permission from surface-rights holders and landowners, respect Indigenous lands and consultation requirements, never use mercury, and stay off other people’s claims, parks and protected areas. General information, not legal advice; confirm with the regulator.
โถ Farmonaut video: what satellite exploration cannot do, and why those limits matter in due diligence. ยท 2:08
Key terms
- Issuer. A company that has issued or proposes to issue securities; it applies to its disclosure in Canada.
- Material property. A property significant enough to the issuer that its scientific and technical disclosure brings in the instrument’s requirements.
- Advanced property. A property with mineral reserves, or with resources supported by a PEA, pre-feasibility or feasibility study.
- Early stage exploration property. A property whose technical report has no current resources or reserves and no drilling or trenching proposed.
- Effective date. The date of the most recent scientific or technical information in a technical report.
- Preliminary economic assessment (PEA). A study short of pre-feasibility that includes an economic analysis of resources; the 2025 proposal would call it a “scoping study”.
- Initial assessment. Under S-K 1300, the preliminary technical and economic study a QP must prepare before mineral resources can be disclosed.
- Cut-off grade. The lowest grade of material that is still treated as ore at the assumed price and cost.
- g/t. Grams per tonne, the usual unit for gold and silver grade.
- Modifying Factors. The mining, processing, metallurgical, infrastructure, economic, marketing, legal, environmental, social and governmental considerations used to turn a resource into a reserve.
Frequently asked questions about NI 43-101
What is NI 43-101?
National Instrument 43-101, Standards of Disclosure for Mineral Projects, is the Canadian Securities Administrators’ rule for how issuers disclose scientific and technical information about mineral projects. It requires a Qualified Person behind the information, CIM resource and reserve categories, and technical reports on Form 43-101F1 for certain disclosures.
What is a 43-101 technical report?
It is a report prepared by or under the supervision of one or more Qualified Persons, following the 27-item Form 43-101F1, that summarizes the relevant scientific and technical information about a property as of its effective date. It is filed on SEDAR+ with each QP’s certificate and consent.
What are the 27 items of Form 43-101F1?
They run from Item 1, Summary, through property, history, geology, deposit types, exploration, drilling, sampling, data verification, metallurgy and resource estimates (Items 2 to 14), to reserves, mining, recovery, infrastructure, markets, environment, costs and economics (Items 15 to 22), then adjacent properties, other data, conclusions, recommendations and references (Items 23 to 27). Items 15 to 22 are required only for advanced properties.
Who can be a Qualified Person?
An engineer or geoscientist with a relevant degree or equivalent accreditation, at least five years of relevant experience in exploration, mine development or operation, or project assessment, experience relevant to the specific project, and good standing with a professional association that can discipline its members.
What is the difference between an inferred and an indicated resource?
An Inferred resource rests on limited evidence that implies but does not verify continuity, and it cannot become a reserve. An Indicated resource has enough reliable data to assume continuity between points, can support a pre-feasibility study, and can convert to a Probable reserve.
What are the CIM Definition Standards?
The CIM Definition Standards on Mineral Resources and Mineral Reserves, adopted by CIM Council in May 2014, define the Inferred, Indicated and Measured resource categories, the Probable and Proven reserve categories, the Modifying Factors and the pre-feasibility and feasibility study levels. The instrument incorporates them by reference.
When must a 43-101 report be filed?
On becoming a reporting issuer, with certain prospectuses, AIFs, circulars and valuations, and within 45 days after written disclosure that reveals a first-time or materially changed resource, reserve or PEA. Earlier dates apply when a short form prospectus or directors’ circular carries the same disclosure, and up to 180 days applies when another issuer prepared and filed the report.
Does a mine report need to be independent?
Not always. Section 5.3 requires every QP on the report to be independent for a first report on becoming a reporting issuer, for reports supporting a long form prospectus or a valuation, for first-time resource, reserve or PEA disclosure, and for a change of 100% or more in resources or reserves since the last independent report. Producing issuers meeting the revenue test can often use their own QPs.
What is SK 1300 and does it apply to Canadian juniors?
S-K 1300 is the SEC’s mining property disclosure rule, mandatory from fiscal years beginning on or after 1 January 2021. It applies to SEC registrants with material mining operations. Canadian issuers filing on Form 40-F under MJDS can use the Canadian rule instead; Form 20-F and 10-K filers follow S-K 1300 in their SEC filings.
Can a junior publish an exploration target?
Yes, as ranges of potential quantity and grade, with equally prominent statements that the target is conceptual, that exploration is insufficient to define a mineral resource and that it is uncertain whether further work will define one, and with the basis for the ranges. A gross metal value is never allowed.
Has NI 43-101 been replaced?
No. As of 29 October 2026 the regulators’ pages show no final replacement. The CSA proposed a replacement on 12 June 2025, and comments closed on 10 October 2025, but the regulators’ instrument pages show no final replacement in force. Check the ASC, BCSC or OSC pages for the current status.
Is a Farmonaut satellite report a technical report?
No. Farmonaut reports describe exploration targets for mapping, sampling and drilling. They are not technical reports under either regime, not CIM resources or reserves, and no Qualified Person prepares or approves them.
This page is for information only. It is not investment advice, tax advice or legal advice; confirm with your securities lawyer, the regulators and the exchange. The instrument may be replaced. Satellite results are exploration targets that sit ahead of a resource estimate. Prospecting needs permission from the claim holder and regulator, and mercury must never be used.
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Sources
- British Columbia Securities Commission, NI 43-101 Standards of Disclosure for Mineral Projects (instrument page): bcsc.bc.ca
- Ontario Securities Commission, NI 43-101 unofficial consolidation (June 2023): osc.ca
- Ontario Securities Commission, NI 43-101 instrument page and history: osc.ca
- Alberta Securities Commission, 43-101CP consolidation (June 2023): asc.ca
- CIM, Definition Standards for Mineral Resources and Mineral Reserves (2014): mrmr.cim.org
- CIM, Canadian Mineral Resource and Mineral Reserve Definitions: mrmr.cim.org
- Canadian Securities Administrators, Notice and Request for Comment on repeal and replacement of NI 43-101 (12 June 2025): osc.ca
- CIM Magazine, NI 43-101 overhaul advances (2025): magazine.cim.org
- US Securities and Exchange Commission, press release 2018-248 on mining property disclosure: sec.gov
- US eCFR, 17 CFR subpart 229.1300, Disclosure by registrants engaged in mining operations: ecfr.gov
- CRIRSCO, Members: crirsco.com
- JORC, Australasian Code for Reporting of Exploration Results, Mineral Resources and Ore Reserves (2012): jorc.org
- CSA, SEDAR+ public filing system: sedarplus.ca
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