Boring Omnibus; $12B for critical minerals; What it takes to make CDP A-List

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Read time: 5-7 minutes

Today we cover:

• Omnibus I is official, starting the era of irrelevant regulations
• LME launches methodology for calculating sustainability premium
• How to get into CDP A-list
• US launches $12b critical minerals reserve
• GBA: beSirius selected by Tesla, Panasonic, Rio Tinto

KEY UPDATES

Omnibus I is official. The saga ends (sort of)

The EU Council approved Omnibus I on 24 February, the last formal step before publication in the Official Journal. CSRD now applies only to companies with 1,000+ employees and €450M+ turnover. CSDDD rises to 5,000 employees and €1.5B, delayed to July 2029 (and who knows what the world will look like then). Mandatory data points cut from 1,073 to 320, climate transition plan obligation deleted. 

The Commission's response to procedural concerns pointed to the geopolitical context and implementation difficulties, reasons generic enough to justify virtually any piece of legislation (or any political decision). 

I’d say everything that was groundbreaking and scary for companies has been cut, so, to me, it seems like an uninteresting regulation to follow. From now on, if you see software companies or consultants posting about CSDDD being just around the corner, ignore them. 

CDP 2025: fewer disclosures, more A-Lists

The CDP 2025 results show a growing paradox. Fewer companies disclosed, while more reached A-List status. The overall number of disclosers declined, yet the share of A-Listers more than doubled over two years.

This points to selection effects, methodology changes, and a shrinking participant pool. Many companies invested months of effort only to see flat or declining scores. Others opted out because the value exchange no longer justified the work. The CDP Climate score distribution chart shared by Vincent Manier, tracking scores rated A to B- across the US and Europe, shows the downward pressure on results again this year, including among long-standing reporters.

It could be a self-selection bias, meaning that companies that score better keep doing CDP and keep scoring better. It could also be that CDP is more lenient in handing out A scores to well-performing companies (we did spot some anomalies in the grading of publicly available submissions). 

If you’d like to understand why your near-perfect submission received a “C” instead of a glorious A, check out our free CDP scoring assessment. It cross-checks your responses one by one against the CDP methodology, tells you exactly where you lost points, and builds a detailed improvement roadmap to the A-list. It’s awesome. We’ve received amazing feedback already, and even Trellis spotlighted our tool as a practical way to prioritize improvements this year. 

We made it available for one more week!

button "Analyze your CDP score" - https://www.besirius.io/analyze-your-cdp-scores - #5F5DDF

US launches Project Vault: a $12B critical minerals reserve

As critical minerals are in fashion now, the U.S. hosted its largest Critical Minerals Ministerial, gathering 55 countries, and announced Project Vault. Backed by a $10 billion EXIM loan and nearly $2 billion in private-sector investment, Project Vault establishes the U.S. Strategic Critical Minerals Reserve, an independently governed public-private partnership that will store essential raw materials in secure facilities across the United States. Manufacturers will decide which materials they need, at what grades and volumes, and commit financially to secure access during disruptions. Minerals will initially come from global markets, including China, where necessary. G7 finance ministers have already expressed interest in partnering.

The key question is whether this will be enough to incentivize producers to pay a premium for less vulnerable supplies. EXIM's largest financing to date moves critical minerals security from policy papers to actual capital deployment. The bet is that it will.

LME launches methodology for sustainable premium

LME published its pricing methodology for sustainable metal premiums, now available on the newly launched "LME Insight" website. The most exciting part, the pricing itself, is expected later this year. As sustainable premiums for copper, nickel, and aluminum have lacked a transparent benchmark, producers struggled to assess whether sustainability practices were appreciated by the market. LME Insight aims to establish the reference benchmark to price the incentives, if they, of course, exist.

Nominate your fave: Women in Mining 100

Women in Mining UK has opened nominations for the WIM100, recognising women working across the mining and minerals sector at all career stages and disciplines. As a proud WIM100 myself, I encourage nominating women whose work is often under-recognized yet materially moves the industry forward. Nominations close on 31 March 2026. Nominate your WIM 100 candidate already today.

KEY REPORTS

State of AI 2026

Most Al pilots fail.

You've probably already seen the infamous finding of Deloitte's State of Al in the Enterprise 2026 report. It shows that 60% of employees have access to AI tools, but only 25% have moved from pilots into production.

Deloitte argues that the reason for that is using AI as a layer on top of the existing operations instead of embedding it in processes and changing the way decisions are made.

It's remarkable that Deloitte, with its extensive experience in corporate engagements, considers it surprising that for most large organizations, changing the way things are done takes time. A lot of time.

Al moves at an enormous speed. Quite literally, in 1 or 2 weeks, the technology can move from "it's not possible" to "give me 5 minutes." However, processes, procedures, approaches, and people's thinking in organizations do not change that quickly (unfortunately so). It has been like this forever, but for the first time in history, the volume of lost productivity, efficiency, and opportunities is no longer marginal - it's 10x.

So that means that companies that have an experimental approach to AI, an open mind, and are good at change management will move exponentially faster than competitors. And if you are wondering what would be the most needed capability in the AI world, well, you've got your answer.

EU DD in practice in mineral-producing countries

Our friends at Levin Sources published a new study looking at how EU Due Diligence regulations land in practice in Indonesia, Zambia, Mexico, and Brazil. The most interesting finding is that establishing DD knowledge hubs in those countries can significantly improve the readiness and implementation. What a great and efficient way to improve DD by pooling resources together for operating companies in the region. Worth reading for anyone working across mineral supply chains.

REGULATORY UPDATES

CBAM's first implementation data and cost structure

CBAM's first week generated over 12,000 authorization applications, 4,100 approved declarants, and 10,483 validated import declarations covering 1.66 million tonnes of goods, with Iron and steel accounting for 98% of declared volumes. The mechanism is functioning technically, though the cost impact remains invisible because certificate purchases don't start until February 2027. 

Default emission values are set conservatively high. Companies without verified supplier emissions data must use these defaults, which means they pay for more emissions than may actually exist. Companies that built supplier tracking during the transition period can report actual emissions and pay less. The difference in preparation now translates directly into cost differences.

OECD self-assessment DD tool

The OECD has launched a set of due diligence checkers that give companies a structured way to assess where gaps exist across their value chains. The tools are available across multiple sectors, including cross-sectoral, agriculture, minerals, and garment and footwear.

They are designed as a practical entry point: a short set of questions, the option to go deeper, and an instant, shareable PDF report. The checkers are free, anonymous, and fully online.

The next step is acting on the results. Identifying gaps is the starting point. As disclosure and enforcement increase, progress will be judged on how effectively risks are addressed and prioritized in practice.

If you want to see how to stop chasing suppliers for responses and integrate all your bespoke DD practices in one place, spending a quarter of the time you spent before, test run our DD tool. Build your own assessment, access the beSirius data network to get immediate analysis of suppliers with a full evidence trail and report. Free trials are available until mid-March.

button "Start free trial" - https://www.besirius.io/solutions/due-diligence-trials - #5F5DDF

GRI standards now in effect for biodiversity and mining

Two GRI standards became effective on 1 January 2026. GRI 101 (Biodiversity) requires organizations to report on their most significant impacts on ecosystems and species across operations and supply chains. GRI 14 (Mining Sector) covers 25 material topics from emissions to community impacts and tailings management. Both are mandatory for GRI reporting organizations where relevant. GRI is also consulting on its 2026-2028 work programme, with public comments open until 27 March.

BESIRIUS UPDATES

GBA Benchmark: beSirius x Tesla x Panasonic x Rio Tinto

The GBA Battery Passport is establishing a shared foundation for how sustainability data is defined, exchanged, and evaluated across battery value chains. With benchmarks in place and operational trials starting in 2026, sustainability performance is now assessed against a common, scored framework, serving as preparation for companies ahead of the EU Battery Regulation.

We have followed GBA's work closely for many years, and as soon as it was released, we built the GBA benchmark as one of the available frameworks for our clients to use. Companies can evaluate themselves or their value chain partners against the GBA benchmark in a matter of hours, with detailed grading, evidence, and an audit trail supporting further verification.

We are proud to work with Tesla, Panasonic, Rio Tinto, and others in demonstrating how data can move freely across the value chain to feed into battery passports and strategic decision-making. Read the official GBA press release with details.

Sustainability information will soon no longer live in spreadsheets. The next generation of battery supply chains will run as an interoperable network of sustainability twins, sharing verified data on demand and at scale.

Mining Indaba 2026 recap

While Galina and Sergey were at Mining Indaba in Cape Town, I was stuck with FOMO and a LinkedIn feed full of photos. Their top takeaway was CMSI. After years of negotiation, the Consolidated Mining Standard is moving into independent governance. Final version expected in the first half of 2026. 

For a broader and very honest read on what Indaba felt like this year, I'd recommend John Mulligan's reflections. 

Other events we are attending 

Ping us for a meeting if you are around these events:

🇨🇦 PDAC (March 1-4) 

🇩🇪 Wire & Tube (April 13-17)

🇪🇸 Cobalt Congress 2026 (May 12-13)

🇧🇪 EIT Raw Materials ( May 19-22)