Indigenous Peoples and the Initiative for Responsible Mining Assurance (IRMA)
The Initiative for Responsible Mining Assurance (IRMA) is a multi-stakeholder standard that runs independent, third-party, site-level audits of industrial mines. IRMA is a reference for buyers, investors, workers, communities, and regulators to understand their threshold for responsible mining.
For Indigenous Peoples, confidence in IRMA centers mainly on two categories: how the standard requires and assesses implementation of free, prior and informed consent (FPIC) and respects Indigenous governance, and the transparency and availability of site‑level audit results.
The following article covers IRMA’S structure, how audits work, and key improvements and gaps in proposed revisions to chapter 2.2 of the Standard, Indigenous Peoples & FPIC.
What is IRMA
Established in 2006, IRMA released its first Standard (v1.0) in 2018. The v2.0 revision had its first public consultation in 2023, and a second public consultation from July 22 to October 24, 2025. The IRMA Standard’s goal is to define and measure best practice for responsible mining and provides a way to verify performance at the mine site through independent assessments and public reporting.
The IRMA Standard is organized under four Principles: 1) Business Integrity, 2) Planning for Positive Legacies, 3) Social Responsibility, and 4) Environmental Responsibility. Each Principle contains multiple chapters, including chapter 2.2, Indigenous Peoples & FPIC (discussed below).
Mines are assigned one of four IRMA achievement levels: IRMA Transparency (public audit), IRMA 50, IRMA 75, and IRMA 100. IRMA Transparency means a site has been independently audited and publishes its results. IRMA 50 and IRMA 75 mean a site meets the core set of requirements and scores at least 50% or 75% in each of IRMA’s four principles. An IRMA 100 meets all requirements of the Standard. Results are valid for three years and then reassessed.
IRMA’s board of directors has two voting representatives from each of six sectors: mining companies; downstream purchasers; investors and finance companies; affected communities and Indigenous rights-holders; organized labour; and environmental and human-rights NGOs. Decisions aim for consensus as two “no” votes from the same sector can block a decision.
By leading with sustainability and human rights, and as one of the few non-industry led standards, IRMA is significant for a number of reasons:
Signals to markets: Buyers and investors increasingly reference IRMA’s site-level evidence when evaluating supply chain risk and performance.
Public accountability: IRMA publishes public summary reports of site audits with chapter-by-chapter findings, creating shared facts for communities, workers, and regulators.
Influence: IRMA is now recognised by companies in major sectors such as the automotive industry and electronics as a credible source of assurance. It is also referenced by the Global Battery Alliance. While IRMA is not one of the core standards inside the Consolidated Mining Standard Initiative (CMSI), in practice, existing IRMA site-audit evidence may be cross-recognised for CMSI at some point in the future.
Limits: IRMA is voluntary and achievement levels reflect audited performance at a single site, not a whole company. A mine can earn IRMA 75 with minor, time-bounded corrective actions, and IRMA lets the report be delayed up to 12 months to verify those fixes.
How IRMA Audits Work
A single IRMA-approved audit firm conducts one integrated, site-level assessment of the entire mine using a multi-disciplinary team (e.g. social and FPIC, labor, environment, and technical). Issues affecting workers and issues relating to Indigenous Peoples and FPIC are assessed within the same audit, and the findings are issued as one public report.
After the draft audit, a site may take up to 12 months to finalize the public report. Then there is a surveillance audit within 18 months and a reassessment within 36 months. For the full, current schedule, see IRMA’s audit process page.
To raise concerns about an audit, communities can submit through IRMA’s online form (preferred), email, WhatsApp, or by postal mail. For issues with audit findings or auditor conduct, IRMA asks to first use the audit firm’s complaint process and unresolved matters can escalate through IRMA’s Issues Resolution System. Anonymous submissions are accepted. More information is provided in the Feedback and Complaints section of IRMA’s website.
Improvements, Gaps & Recommendations
Tallgrass Institute provided analysis and recommendations of IRMA’s proposed revisions to chapter 2.2 of the Standard, Indigenous Peoples & FPIC.
Key improvements that we found included:
Protects Uncontacted/Isolated Peoples: The new draft adds explicit expectations for Peoples living in voluntary isolation: do not initiate contact. If existing impacts are identified, the entity must halt the relevant activities and remove impacting infrastructure, then determine and implement remedies with Indigenous bodies and experts. If past impacts are identified, determine and implement appropriate remedies. If proposed activities may affect them, redesign to avoid all impacts or cease the proposal.
Separates past and future: Draft 2 separates past harms from new approvals by establishing in subsection 2.2.4.1 the remedy for past impacts where FPIC was not obtained, assigning implementation and monitoring to 2.2.5, and addressing consent for new activities in 2.2.6, so past harms aren’t traded against new approvals.
No “public consultation” swap: General public consultation and engagement with Indigenous Peoples are now explicitly separated. The site cannot rely on general public consultation to stand in for Indigenous Peoples engagement unless Indigenous Peoples explicitly agree (see 2.2.4 and 2.2.6).
Grievance channel that works for Indigenous Peoples: The new draft requires the entity to collaborate with affected Indigenous Peoples to develop and implement a grievance mechanism specific to them and it must be rights-compatible and allow individual and collective complaints. If the general mechanism (chapter 1.6) is to be used, the entity may do so only with the express and explicit approval of affected Indigenous Peoples, and after ensuring it meets all 1.6 requirements and is reviewed and agreed with them (see 2.2.4.5).
Funding for independent, Indigenous‑chosen advisors: The entity must offer funding so Indigenous Peoples can select and hire their own technical and legal advisors to support FPIC or remediation processes. If the offer is accepted, funding must be provided in a manner agreed to by Indigenous Peoples so communities can participate on fair footing. (See 2.2.4.4)
Score guardrail to weigh scores: The Indigenous grievance score in chapter 2.2 cannot be higher than the site’s overall grievance score in Chapter 1.6 (2.2 ≤ 1.6). This prevents a high mark on the Indigenous item if the overall grievance system is weak.
In our analysis, we make the following recommendations to critical gaps found in revisions to chapter 2.2:
Plural/contested representation (2.2.4): There is guidance but no binding, community‑led process to confirm the legitimate representative for the affected Indigenous Peoples. Without this, companies can choose the most convenient interlocutor, which can split communities and weaken collective consent.
RECOMMENDATION: Add a binding clause in subsection 2.2.4 requiring a community‑led, neutrally facilitated process with the facilitator chosen by the Indigenous Peoples to confirm legitimate representatives and make completion of this process a prerequisite to concluding FPIC.Grievance scoring clarity & access: The chapter 2.2 ≤ chapter 1.6 grievance scoring rule is adopted but not clearly written in the clause or in the Assurance Manual. Vague rules can create inconsistent audits. Auditors should ensure grievance channels are available locally and not only in the capital, offline as well as online and in the relevant languages otherwise Indigenous Peoples may be effectively excluded.
RECOMMENDATION: Write the rule clearly. Require in‑country, locally accessible intake, plus a gender‑responsive, language‑access plan co‑designed with Indigenous Peoples.When Indigenous Peoples decline remedy (2.2.5): Draft 2 removed the option to award “good‑faith” points. But it does not spell out what happens when Indigenous Peoples decline or end remedy talks. Without a clear rule, a site can keep operating and still claim it “tried,” which pressures Indigenous Peoples and weakens their right to withhold consent.
RECOMMENDATION: Audits should not grant partial credit unless operations are paused or limited in line with the Indigenous Peoples’ decision. IRMA can acknowledge restraint in the audit narrative, but no points should be awarded.Precautionary suspension (2.2.6.8): Draft 2 adds steps to look into and fix problems when new facts put consent in doubt, but it doesn’t clearly require the mine to pause work. A site can keep operating while consent is in doubt. That raises the risk of harm and conflict.
RECOMMENDATION: Make pausing work mandatory whenever there is credible evidence of a breach or new facts that could change the FPIC outcome. Set clear time limits for when information will be available. For example to meet within 15 business days and complete an initial fact-finding within 60 days. Require written notice to the Indigenous Peoples, the authorities, buyers, and lenders in this case.Changes after consent to stage and scope (2.2.6.9): Draft 2 mentions stage‑ and scope‑specific consent in notes, but not as a firm rule. Mines often change plans after initial consent from Indigenous Peoples is given. For example, they expand the mine site, add new roads or pipelines, or alter tailings and water use. If those changes occur, Indigenous Peoples’ ability to influence decisions is materially undermined and consent may no longer be valid.
RECOMMENDATION: Make it a clear, binding rule that consent is stage‑ and scope‑specific. IRMA can list simple triggers that require renewed FPIC, for example, a major expansion, any new associated facility like a road or pipeline, redesign or relocation of tailings, or a significant change in water use or risk. Add a one‑page yes/no decision tree to provide clarity for auditors.Transparency with safeguards: Disclosure duties lack community-defined confidentiality rules. Without safeguards, public documents can expose sacred knowledge or personal data, discouraging participation and putting Indigenous Peoples at risk.
RECOMMENDATION: Co‑design disclosure and redaction rules with the Indigenous Peoples. Keep promises and performance visible while protecting sensitive knowledge. Require secure storage, permission rules for sharing, and an independent review if confidentiality is breached.FPIC scope and other collectivities: The term “customary rights” can be confused with FPIC, which is the collective right to consent. Without clarity, auditors may apply FPIC too broadly or too narrowly, reducing legitimacy and causing disputes.
RECOMMENDATION: In the Glossary, cross-reference Customary Rights and state that it is distinct from FPIC; reaffirm that binding FPIC in chapter 2.2 applies to Indigenous Peoples; where national law or jurisprudence recognizes consent rights for other collectivities, e.g., Afro-descendant, the Entity must comply; and, encourage consent-based engagement as good practice throughout the standard.Downstream leverage: In Draft 2, there is no requirement that buyers and lenders be notified when FPIC is withheld, withdrawn, or in dispute. If they do not know, material and human rights risks travel down the supply chain.
RECOMMENDATION: Require the site to notify buyers and lenders within a set time when FPIC status changes. Require contract tools such as pausing new purchases or financing, a defined cure period, and suspension or exit if the problem is not addressed. These could also be procurement specifications, supplier agreements and financial agreements with defined timeframes for corrections and suspension or exit if unresolved. Draft 2 should incentivize suppliers to commit these terms in contracts and reflect them in public reporting.