What Happened in 2026
On 27 April 2026 the Mining Commission directed inspections of small-scale mining projects operating under technical support arrangements. On 26 August 2026 it announced the results: of 128 projects inspected, 42 were not operating and 86 were operating without fully implementing the plans the law requires. Those 86 were given 30 days to comply under the Mining Act and the 2025 Technical Support Regulations for Holders of Primary Mining Licences, with cancellation of Technical Support Agreements among the actions threatened for those who did not.
The message for every PML holder, whether or not they were on that list, is that the paperwork is now inspected on site and enforced. This checklist sets out the documents inspectors looked for and what each one needs to show.
The Five Plans Inspectors Found Missing
1. Environmental Management Plan
- Where waste rock and tailings go, and how they are contained
- How water is sourced, used, recycled and kept out of streams
- How cyanide, fuel and other chemicals are stored and spills handled, if they are used
- Erosion control, especially for the rainy season
- How disturbed land will be rehabilitated
- What is monitored, how often, and who records it
2. Corporate Social Responsibility Plan
- The community projects committed to, agreed with the local council
- The budget and timetable for each commitment
- How the community can raise complaints, and how they are answered
- Records showing what was actually delivered
3. Technology Transfer Plan
Where a PML holder works with a technical partner, this plan shows how skills and technology pass to the licence holder and local workers.
- Which skills are being taught: machine operation, maintenance, processing, safety
- Who is being trained, and how training is recorded
- What equipment and methods are being introduced, such as mercury-free gravity recovery
4. Mining Plan
- Where and how ore will be mined: pits, shafts, benches or adits
- Expected tonnage and grade over time
- Equipment to be used for mining, hoisting, pumping and processing
- Ground support and safety measures, including for heavy rains
5. Mine Opening Plan
- The sequence for opening the site: access, infrastructure, first workings
- Where the processing area, stores, offices and tailings facility will sit
- Safety arrangements before production starts
Beyond the Five Plans
The inspections focused on those documents, but a compliant small mine also needs:
- A valid licence with annual rent paid
- Environmental approval appropriate to the scale of the operation
- Cyanide permits and storage if leaching is used. See buying and storing cyanide
- Sales records through mineral markets and buying centres, with royalty receipts. See selling gold legally
- Worker safety: PPE, safe hoisting, ventilation and gas detection in deeper shafts, and first aid
- Employee and local content records
Safety During the Rains
The Mining Commission's Executive Secretary stressed that safety must remain a priority because mining exposes workers, communities and property to significant risk, particularly during heavy rains. Shaft and pit collapses and flooding are among the most common causes of deaths in small-scale mining. Before the rains:
- Inspect ground support and shaft collars, and stop work in unstable ground
- Check dewatering pumps and standby power
- Divert surface water away from shafts and pits
- Check that winches, ropes and brakes are sound, and that nobody rides a goods winch
- Make sure tailings facilities have freeboard for heavy rainfall
A Practical Compliance Routine
- Keep one file per licence with every plan, permit, receipt and inspection record
- Review the plans every six months and whenever the operation changes, such as adding a leach circuit
- Record what you actually do: monitoring results, training, community spending. Plans without records do not pass inspection
- Buy equipment that makes compliance easier: lined tailings, water recycling, mercury-free recovery and safe hoisting
Regions We Serve
Frequently Asked Questions
What are the 2025 Technical Support Regulations?
They are regulations governing technical support arrangements for holders of Primary Mining Licences, under which a PML holder works with a partner who provides capital, equipment or expertise. The 2026 inspections checked whether projects under these arrangements were implementing the plans the law requires.
What happens if a project does not comply?
The Mining Commission stated that projects failing to meet the requirements within the deadline would face further legal action, including cancellation of their Technical Support Agreements. Licence holders should treat compliance as a condition of continuing to operate.
Do I need an environmental management plan for a small PML?
Yes. Environmental management plans were the first item on the list of deficiencies found in 2026. The plan can be proportionate to a small operation, but it has to exist, be followed and be backed by records.
Is this legal advice?
No. This page summarises published requirements and the 2026 inspection results. Regulations change; confirm your obligations with the Mining Commission, your Resident Mines Officer or a lawyer.