CMRT 2025: everything you need to know about conflict minerals reporting

Staying compliant with conflict minerals reporting requirements is becoming more complex every year. For many organisations in the metals, mining and industrial sectors, completing the CMRT means coordinating suppliers across continents, keeping pace with changing smelter information and reconciling multiple data sources under tight timelines. In 2025, responsible sourcing is no longer a "nice to have", it is a core part of doing business. Here’s what companies need to know to navigate it in 2025.

TL;DR: CMRT reporting in 2025

The Conflict Minerals Reporting Template (CMRT) is the industry standard for disclosing tin, tantalum, tungsten and gold (3TG) sourcing, and for identifying smelters and refiners in global supply chains.

Accurate CMRT reporting is essential for meeting RMI expectations, avoiding smelter-list inconsistencies and demonstrating responsible sourcing.

Traditional CMRT completion relies on manual supplier outreach, data consolidation and smelter validation - a process that is slow, error-prone and difficult to scale.

AI-powered platforms like beSirius automate the CMRT population, consolidate supplier responses, validate smelters against the latest RMI lists and maintain a single source of truth. This article covers the CMRT template, common reporting challenges, best practices and how automation dramatically improves speed, accuracy and audit readiness

Understanding CMRT essentials

The Conflict Minerals Reporting Template (CMRT) is the industry’s standard questionnaire developed by the Responsible Minerals Initiative (RMI) for tracing the sourcing of tin, tantalum, tungsten, and gold (3TG). 

These minerals often originate from conflict-affected and high-risk areas (CAHRAs) such as the Democratic Republic of Congo (DRC) and nearby countries, where the mineral trade has historically been linked to armed conflict and human rights abuses.

The purpose of the CMRT is simple: improve supply-chain transparency and reduce the risk of accidentally sourcing conflict-linked minerals.

But translating that purpose into reliable reporting is where many companies struggle. CMRT data depends heavily on supplier inputs, smelter verification and version control. And when any part of that chain breaks down, gaps appear quickly. Those gaps can have real consequences for compliance, audits and customer relationships. 

Incomplete or inaccurate CMRT reporting can expose companies to:

• Regulatory questions
• Customer concerns
• Reputational and investor pressure
• Contract delays or loss
• Deeper audits and compliance reviews

And these risks are not abstract, they happen in real life. For example:

• When traceability systems break down, and when minerals tagged as “conflict-free” are later found to have been mixed with material from high-risk or unverified sources.
• When a supplier reports unknown smelters and a customer flags the company for insufficient due diligence.
• When journalists or NGOs publish reports showing a manufacturer used 3TG from a high-risk smelter not on an approved list.
• When a major buyer asks for a clean CMRT for contract renewal and discovers gaps or inconsistencies in the company’s data.
• When investors see a company listed in an NGO report for weak supply chain controls, leading to public statements or internal reviews.

In many cases, all of this traces back to the same issue: a CMRT submission that was incomplete, inconsistent or not backed by verified supplier data.

This is why accurate CMRT reporting matters. Strong data protects the business, builds trust with customers and suppliers, reassures investors and compliance teams, and shows that responsible sourcing practices can withstand real scrutiny.

What is the Critical Minerals Reporting Template?

Over the past decade, the CMRT has evolved from a simple spreadsheet into a globally recognized due diligence standard.

Early releases focused on formatting fixes and building out the smelter list. Later versions aligned with IPC-1755, the EU Conflict Minerals Regulation, and expanded due diligence requirements.

The 6.x series introduced clearer instructions, stronger validation logic, and continually updated RMI smelter reference data.

The latest version available from the RMI website is CMRT 6.5 (April 2025). This version includes updated smelter reference data and minor refinements intended to improve consistency and reduce common reporting errors.

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RMI announced that the next version will be released in Spring 2026.

The CMRT is structured into several tabs, including:

• Declaration – Core due diligence questions
• Smelter List – Required smelter and refiner disclosures
• Checker – Validation logic for data completeness
• Instructions – Guidance for suppliers and reporting companies

Companies are expected to use the most recent version for each reporting cycle to avoid inconsistencies with smelter IDs, outdated lists or incompatible declarations.

How to complete CMRT: traditional approach

1. Identify all relevant suppliers
   Prepare a complete list of suppliers that use or may supply tin, tantalum, tungsten or gold (3TG), including tier-one and high-risk upstream suppliers.
2. Distribute the latest CMRT version
   Send the current CMRT template (e.g., CMRT 6.5) to all suppliers.
   Ask them to complete sourcing information, smelter details and due diligence fields.
3. Collect supplier declarations
   Gather all completed CMRT files.
   Expect mixed formats, versions and varying data quality across responses.
4. Validate smelters and refiners
   Check each smelter ID and name against the RMI Standard Smelter List and Smelter Reference List.
   Flag unknown, invalid or outdated entries.
5. Review due diligence answers
   Ensure supplier responses align with your company policies, sourcing practices and risk-assessment procedures.
6. Resolve inconsistencies and missing data
   Follow up with suppliers to correct incomplete fields, conflicting answers, outdated template versions or unverifiable smelters.
7. Consolidate all supplier CMRTs
   Merge smelter lists, declarations and due diligence information into a single master CMRT file.
   Ensure all required tabs (Declaration, Smelter List, Checker) are complete
8. Perform a final accuracy check
   Run the Checker tab, validate data consistency, confirm smelters and ensure no required fields are missing.
9. ‍Submit the final CMRT
   ‍Provide the completed CMRT to customers, auditors or internal compliance teams. Retain documentation for audits and responsible-sourcing reviews.

‍

Common CMRT challenges

CMRT compliance appears simple on the surface, but behind each submission is a chain of moving parts that rarely behave as planned. Most of the complexity comes from suppliers, data consistency, and constant updates to RMI reference information.

The most common issues include:

• Late supplier responses
• Outdated or incomplete declarations
• Smelters that cannot be verified
• Conflicting or inconsistent data
• Mixed CMRT versions submitted across the supply base
• RMI smelter lists that update throughout the year
  

As reporting season approaches, these problems tend to multiply, and teams spend weeks chasing corrections, clarifications and updated forms.

Across the industry, several deeper pain points consistently appear:

• Supplier data quality and version control
• Smelter verification against evolving RMI lists
• Regulatory shifts in responsible-sourcing expectations
• Pressure from customers, auditors and investors for faster answers
• High data volumes — sometimes hundreds or thousands of CMRTs

The result is a time-sensitive reporting rush with very little margin for error.

CMRT reporting with beSirius AI platform

beSirius automates the process by collecting data from different documents and sources, combining it into the latest RMI CMRT template, resolving alignment issues and managing everything in one workflow. 

Teams receive validated, auditable data without repetitive manual consolidation.

How it works: step-by-step workflow

1. Enter basic reporting inputs
Select CMRT, choose scope, set minerals and (optionally) add suppliers/refiners.

2. Auto-populate CMRT fields
beSirius fills declaration tabs, company details, policies and due diligence fields from the Sustainability Twin.

3. Pull products and suppliers automatically
The platform identifies relevant products and suppliers using BOMs, sourcing data and supplier hierarchies.

4. Upload and consolidate supplier CMRTs
beSirius validates template versions, normalises fields and merges all supplier responses into one clean dataset.

5. Validate smelters and facilities
Entries are checked against the latest RMI lists; unknown or duplicate smelters are flagged automatically.

6. Generate consistent due diligence answers
Policies, CAHRA methodology and risk assessments are reused and adapted to the CMRT question wording.

7. Collaborate in one place
Assign tasks, track supplier progress, store documents, and capture comments without spreadsheets or emails.

8. Review and export final CMRT
The fully populated, validated template is ready for review and submission.

Key advantages

• Automatic population of CMRT fields using the Sustainability Twin
• Error-proof consolidation of supplier CMRTs, regardless of version or format
• Smelter validation against the latest RMI reference lists
• One unified workflow with no spreadsheet versioning or manual handovers
• Real-time collaboration across procurement, ESG, legal and compliance teams and suppliers
• Full traceability from suppliers to smelters to due diligence records
• Reusable data, making each CMRT cycle significantly faster and more reliable

Because everything lives within the Sustainability Twin, updates to suppliers, smelters or internal policies flow automatically into all future CMRT cycles, turning reporting into a predictable, accurate and far less manual process.

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Integrating CMRT into ESG

CMRT compliance is not an isolated task; it's an integral part of your broader environmental, social, and governance strategy. By centralizing your CMRT data within the beSirius platform, you can gain a holistic view of your supply chain sustainability performance. This enables you to identify opportunities for improvement, track progress towards your sustainability goals, and communicate your achievements to stakeholders. Because beSirius supports over 25 sustainability frameworks, you can seamlessly integrate CMRT reporting with other ESG initiatives, creating a cohesive and impactful sustainability program.

CMRT Reporting: Best Practices

To make your CMRT reporting more efficient and easier, consider these best practices:

• Centralize data management: Utilize a platform like beSirius to consolidate all ESG data in one place.
• Automate data collection: Leverage AI to automate the collection and validation of supplier data.
• Regularly update policies: Stay informed about regulatory updates and incorporate them into your reporting process.
• Conduct supplier risk assessments: Identify and mitigate potential risks in your supply chain.
• Use standardized templates: Employ the latest CMRT template version (e.g., v6.5) to ensure consistency.
  

Ready to automate your process?

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Would you like to know more about RMI Templates and how to complete ARMT and ERTM as well?

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Frequently Asked Questions

What is CMRT?‍

The Conflict Minerals Reporting Template (CMRT) is a standardized reporting tool created by the Responsible Minerals Initiative (RMI) to help companies disclose the use and origin of tin, tantalum, tungsten and gold (3TG) in their supply chains.

‍Why is CMRT required?

‍The CMRT supports conflict minerals due diligence requirements by increasing supply-chain transparency and helping companies identify whether their 3TG sourcing may be linked to armed conflict or human rights risks.

Which minerals are covered by CMRT?

‍The CMRT covers four minerals known as “3TG”: tin, tantalum, tungsten and gold. These materials may originate from high-risk regions such as the Democratic Republic of Congo (DRC) and adjoining countries.

What is the latest CMRT version?

‍The most recent release is CMRT 6.5 (April 2025), which includes updated smelter reference lists and minor refinements to improve consistency.

How often should companies update their CMRT?

‍Most companies update their CMRT annually, though updates may be needed sooner if supplier sourcing changes, smelter data shifts or new risk information emerges.

What information does CMRT collect?

‍The CMRT gathers details on:

• supplier 3TG sourcing
• smelters and refiners used
• country-of-origin information
• supply-chain due diligence practices
• policies, controls and risk-assessment procedures
  

Why is CMRT reporting often challenging?

‍Common difficulties include inconsistent supplier declarations, mixed CMRT versions, missing or outdated smelter data, and manual cross-checking against RMI reference lists. Large companies may need to consolidate hundreds or thousands of supplier responses.

How is smelter information validated?
Companies verify smelter names and IDs against the RMI’s Standard Smelter List and Smelter Reference List. These lists are updated regularly, which can create alignment issues when suppliers use older template versions.

How can companies improve CMRT accuracy and efficiency?
By using centralized data, maintaining consistent documentation, aligning template versions, engaging suppliers early, and validating smelters against the latest RMI lists. Automation tools can significantly reduce manual consolidation and errors.

How does beSirius support CMRT reporting?
beSirius automates CMRT population, validates supplier and smelter data against the latest RMI lists and consolidates all inputs into one clean template, reducing manual work and improving accuracy.