A mineral asset changes hands. Somewhere in the first week of diligence, someone asks whether the technical report is NI 43-101 compliant, and the seller discovers that the study they commissioned two years ago (perfectly competent, professionally prepared) is in the wrong format for the buyer in front of them.
This happens constantly, and it happens because the choice of reporting code is widely misunderstood as a technical question about the deposit. It is not. It is a question about the counterparty.
The family resemblance
The three codes are less different than their separate names suggest.
JORC is the Australasian code, maintained by a joint committee of the Australasian Institute of Mining and Metallurgy, the Australian Institute of Geoscientists, and the Minerals Council of Australia. It is the oldest of the three in continuous use and the most direct ancestor of the modern approach.
NI 43-101 is the Canadian instrument, administered by the Canadian Securities Administrators. It was introduced after the Bre-X scandal, and its character reflects that origin: it is a securities regulation first and a technical standard second.
S-K 1300 is the United States regime, adopted by the SEC and replacing the long-outdated Industry Guide 7. It brought US disclosure broadly into line with international practice, most significantly by permitting the disclosure of mineral resources, which the previous US regime effectively did not.
All three sit within the CRIRSCO family and share the same architecture: the same fundamental split between resources and reserves, the same confidence categories beneath each, and the same principle that a named professional puts their name to the estimate and is accountable for it.
If you understand one properly, you understand roughly eighty per cent of the other two.
Where they actually diverge
The differences are procedural rather than conceptual, and there are three that matter in practice.
Who signs. JORC relies on a Competent Person; NI 43-101 and S-K 1300 on a Qualified Person. The definitions differ in their detail: the professional bodies recognised, the nature and length of experience required, and the relationship of that experience to the specific deposit type and the specific activity being reported. A geologist qualified to sign in one regime is not automatically qualified in another. This is the single most common practical obstacle in a cross-border transaction and the one most often discovered late.
What must be disclosed, and when. Each regime attaches disclosure obligations to different triggers, and each specifies its own report form and content requirements. The technical work may be identical; the document is not interchangeable.
How economic studies are framed. The study tiers (scoping, preliminary economic assessment, prefeasibility, feasibility) carry meaning that is broadly comparable across the codes, but the constraints on what may be said about each, and on which categories of material may be included in an economic analysis, are regime-specific.
The rule that actually decides it
Which code applies is determined by where your counterparty is listed or regulated, not by where the deposit is.
A Brazilian iron ore asset does not have a native reporting code. Sold to a TSX-listed acquirer, it is reported under NI 43-101. Sold to an SEC registrant, S-K 1300. Sold to an ASX-listed buyer, JORC. Sold to a private fund with no listing obligation, whichever code that fund's own investors and lenders expect to see, which in practice means one of the three anyway.
The corollary is uncomfortable for sellers: if you do not know who the buyer will be, you do not yet know which report you need. Commissioning a full technical report before that is settled risks paying for the wrong document.
What this means for how you hold the evidence
Here is the part that changes how an asset should be prepared for market.
The three codes demand different documents. They largely do not demand different *evidence*. Drill results, assay data, QA/QC procedures, survey and topography, metallurgical testwork, tenure and concession status, environmental and social baseline, infrastructure and logistics, water access. This material underlies all three regimes.
The expensive failure mode is treating the report as the artefact and the evidence as scaffolding thrown away afterwards. Then every new counterparty means starting over: reassembling records from consultants' archives, chasing the provenance of a number nobody can now source, and paying for work that has already been done once.
The alternative is to treat the evidence base as the asset and the report as a rendering of it. Hold the underlying material structured, sourced, and current, and producing a report in a given format becomes an assembly problem rather than an investigation. That is also what makes an asset genuinely diligence-ready: the questions arrive in a predictable order, and the answers either exist in retrievable form or they do not.
Three practical cautions
Do not confuse resources with reserves in marketing material. A resource is material with reasonable prospects for eventual economic extraction. A reserve is the portion a study has shown to be economically extractable under stated assumptions. Conflating them is the fastest way to lose technical credibility with a serious buyer, and in a disclosure context it is considerably worse than embarrassing.
Treat historical estimates as historical. An estimate prepared under a superseded regime, or under none, does not become current by being restated. Every code has explicit rules about disclosing historical estimates, and they exist because this is a recurring source of misleading disclosure.
Check thresholds against the current rules, not against an article. Disclosure triggers and materiality thresholds are revised. Nothing here should be relied on as a current numeric threshold: this piece deliberately quotes none. Read the instrument as it stands today.
The underlying problem
Most of the difficulty in mineral-asset transactions is not geological. It is that the evidence supporting a valuation lives scattered across consultants' reports, government registries, gazette notices, historical filings, and spreadsheets, in several languages and formats, with no single view of what is known, how confidently, and on what authority.
Global Miner AI ingests and normalises that material from official concession and geospatial sources (ANM SIGMINE is the first data region) alongside gazette monitoring and commodity price tracking, then scores each asset across ESG, water, infrastructure, and market layers so the layers stay separable rather than collapsing into one opaque number. Feasibility is framed across NI 43-101, JORC, and S-K 1300, so a conversation with a counterparty starts from structured evidence rather than a document pile.