ESG due diligence in mining and metals: how companies assess risk in 2026

In 2026, ESG due diligence in mining and metals is no longer driven by regulatory clarity. It is driven by uncertainty shaped by real events.

Geopolitical tensions, ongoing wars, trade restrictions, and instruments such as CBAM have reshaped how metals and critical materials move across borders. At the same time, sustainability regulation across Europe has lost its original predictability. Some initiatives are suspended, others postponed, and several supply-chain requirements have been weakened or reinterpreted.

Despite this, customers, partners, and financiers continue to ask mining and metals companies for sustainability and risk information, often in bespoke formats aligned to their own exposure and priorities.

For companies sourcing or producing critical materials, the challenge is no longer which framework applies. The challenge is how to assess value chain risk in a credible, consistent way when political, regulatory, and commercial signals keep shifting.

What ESG due diligence means in mining and metals today

In practice, ESG due diligence in mining and metals functions as value chain risk assessment.

It brings together environmental, social, and governance risk signals that directly affect business continuity, supplier reliability, and long-term access to materials. This goes beyond disclosure. The objective is to understand where risks sit, how material they are, and what action is required under current conditions.

In the metals and mining context, this typically includes:

• Human rights risks such as child labor, forced labor, and exposure to artisanal mining, often concentrated in politically sensitive regions
• Climate and energy intensity risks in steel, aluminum, and nickel production, increasingly exposed to carbon pricing, CBAM, and energy market volatility
• Environmental impacts related to water use, tailings, and land rehabilitation
• Governance and transparency gaps across multi-tier supply chains operating across jurisdictions with diverging rules.

The output of due diligence is often a basis for business decisions influencing many operations within the company. 

Why due diligence is in focus in 2026

Value chains are under pressure from geopolitics and trade

Wars, sanctions, and trade measures have materially changed metals supply chains over the past few years. Energy markets have been disrupted. Critical minerals sourcing has become politically sensitive. Tariffs and carbon border measures now affect where materials are produced and how they are priced.

As a result, companies need clearer visibility into supplier risks across regions and materials. Sustainability-related risks are assessed alongside cost, availability, and operational reliability because they increasingly influence whether production can continue at all.

Regulatory clarity has not materialized

A few years ago, many organizations expected sustainability due diligence to converge into a single, stable regulatory model. That expectation has not been met. In our recent newsletter, we covered regulatory changes and trends in more details.

Key examples illustrate this reality:

• Germany’s Supply Chain Due Diligence Act (LkSG) has been suspended in practice
• The EU’s Corporate Sustainability Due Diligence Directive (CSDDD) has been postponed and may not proceed in its original form
• Supply-chain-related requirements under CSRD have been softened compared to earlier drafts

This has not reduced expectations from customers or partners. Instead, it has shifted responsibility onto companies themselves. Requests for sustainability information continue to arrive, often based on bespoke internal frameworks rather than shared regulatory standards.

Bespoke frameworks are becoming standard

In response, buyers increasingly design their own sustainability and risk frameworks. They define which topics matter, how thresholds are set, and what evidence is required, often influenced by geopolitics, trade exposure, and customer commitments rather than regulation alone.

This creates friction across the value chain.

Buyers face high assessment costs and inconsistent information. Suppliers face repeated, overlapping requests that differ in structure and depth, with limited clarity on how responses are used or prioritized.

Without a shared risk logic, both sides spend time responding to volume instead of addressing material risks.

Key risk areas across the metals value chain

While risk profiles vary by material and geography, several areas consistently drive due diligence efforts in mining and metals.

— Human rights risks

Exposure to child labor, forced labor, and unsafe working conditions remains a critical concern, particularly in artisanal and small-scale mining linked to cobalt, gold, and other critical minerals.

To establish an initial evidence base, companies often use Responsible Minerals Initiative (RMI) templates, such as the CMRT, EMRT, and AMRT, which beSirius supports as part of supplier due diligence workflows.

— Climate and energy intensity

Primary steel, aluminum, and nickel production face growing exposure to energy prices, carbon costs, and CBAM-related scrutiny, with direct implications for margins and supplier selection.

— Environmental impacts

Water management, tailings safety, and land rehabilitation continue to shape operational and reputational risk, especially in regions affected by climate stress.

— Governance and transparency

Limited visibility into policies, processes, and decision-making across suppliers complicates risk assessment in fragmented regulatory environments.

The real challenge behind ESG due diligence

The core challenge in 2026 is not the number of requests or the lack of data. It is the absence of a shared, adaptable risk logic that works under real-world conditions.

A single checklist cannot capture human rights exposure in artisanal mining and climate intensity in aluminum production in the same way. Risks differ by material, region, customer exposure, and geopolitical context.

Effective due diligence requires the ability to define risk parameters, apply them consistently, and adjust them as conditions change.

What an effective approach looks like

Leading companies are moving toward sustainability intelligence.

This approach starts with:

• Defining bespoke risk frameworks aligned to business priorities and exposure
• Using publicly available evidence such as policies, reports, and disclosures as a baseline
• Identifying gaps before engaging suppliers
• Asking targeted questions only where additional clarity is needed
• Supporting decisions with traceable, auditable evidence

This reduces duplication, improves focus, and supports more constructive supplier relationships.

How beSirius supports sustainability due diligence

beSirius is purpose-built for metals, mining, and industrial companies operating under geopolitical and regulatory uncertainty.

On the platform, companies define their own risk frameworks, with custom parameters and thresholds. Regulatory or customer requirements can be embedded where relevant, without relying on a single external framework.

Using Sustainability Twins, beSirius analyzes publicly available sustainability policies, reports, and disclosures at scale. This creates an immediate evidence base for risk assessment.

Suppliers are engaged only where gaps or risks are identified. They can complement existing information through focused requests, supporting targeted follow-up and corrective action plans rather than broad questionnaires.

Every decision is supported by traceable evidence, creating a clear audit trail and allowing teams to focus on material risks rather than hundreds of generic checks.

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Due diligence as a strategic capability

In 2026, ESG due diligence in mining and metals is shaped by wars, trade measures, carbon borders, and regulatory uncertainty, not by stable rulebooks.

Companies that treat due diligence as a strategic intelligence capability are better positioned to manage supplier risk, protect operations, and maintain credibility across complex value chains.

This is the role sustainability intelligence plays, and where beSirius fits.

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ESG due diligence FAQs

— What is ESG due diligence in mining and metals?

ESG due diligence in mining and metals is the assessment of sustainability-related risks across extraction, processing, and manufacturing to support informed decisions on suppliers, sourcing, and operations.

— Why is ESG due diligence important for metals supply chains?

Human rights exposure, climate and energy intensity, and geopolitical disruption directly affect value chain stability, customer relationships, and long-term access to materials.

— How do companies assess supplier sustainability risks today?

Leading companies start with public policies and disclosures, identify gaps, and engage suppliers with targeted questions rather than blanket questionnaires.

— What are the biggest ESG risks in mining and metals?

Key risks include human rights exposure, climate and energy intensity, environmental impacts, and limited transparency across multi-tier supply chains operating under fragmented rules.