JORC Code vs NI 43-101: What Actually Changes When You Report in Australia or Canada?

Both regimes classify Mineral Resources and Reserves in almost the same way. The real differences are in who signs, how Resources can be totalled, when a full technical report must be filed, how early-stage economics can be disclosed, and who enforces it. For engineers and managers working on projects that report on the ASX, the TSX, or both, those differences shape study scope, budget and timeline.

By Jose Grado | 19/10/2026

Engineers moving between Australian and Canadian projects often hear that "JORC and 43-101 are basically the same thing". At the classification level, that is close to true. Both are aligned to the CRIRSCO international reporting template, both use Inferred, Indicated and Measured Resources, and both require at least a Pre-Feasibility Study before a Reserve can be declared.

Where they diverge is in the legal mechanics. JORC is a professional code, binding on AusIMM and AIG members and given force for listed companies by the ASX Listing Rules. NI 43-101 is a securities regulation, with a prescribed Technical Report when defined triggers apply, mandatory site inspection, independence tests and fixed filing deadlines. Those differences decide what your study team must produce, who has to sign it and how quickly it has to be filed.

The two regimes at a glance

Competent Person vs Qualified Person

On paper the two roles look similar. Both require a minimum of five years of relevant experience, membership of a professional body with enforceable discipline, and accountability for the technical content. The differences are in the detail.

JORC Competent Person

• Member or Fellow of the AusIMM, the AIG, or a Recognised Professional Organisation (RPO).

• At least five years of experience relevant to the style of mineralisation and the activity being undertaken (exploration, estimation or Reserves).

• No explicit degree requirement in the Code.

• Must give prior written consent to the form and context in which their work appears.

• Employment relationship and any conflict of interest must be disclosed, but there is no general independence requirement. Independence is required only in specific cases, such as a production target based solely on Inferred Resources under the ASX Listing Rules, or an independent technical assessment report for an IPO prospectus under the VALMIN Code.

NI 43-101 Qualified Person

• Engineer or geoscientist with a university degree (or equivalent accreditation) in a relevant field.

• At least five years of experience in exploration, mine development, operation or project assessment, with experience relevant to the subject of the report.

• In good standing with a recognised professional association, such as a Canadian provincial engineering or geoscience regulator. Foreign bodies are accepted only at specified grades: for the AusIMM that means FAusIMM, MAusIMM(CP) or FAusIMM(CP), and for the AIG MAIG, FAIG or RPGeo. A plain MAusIMM does not qualify.

• Signs a dated QP certificate and a consent, both filed with the Technical Report (NI 43-101 Part 8).

• Must beindependentof the issuer in defined situations (s. 5.3), including the report filed on becoming a reporting issuer, the first disclosure of Resources, Reserves or PEA results on a property material to the issuer, and a 100% or greater change in total Resources or Reserves since the last independent report.

Producing issuersget two exemptions from the independence test. They are exempt for all the s. 4.2 filing triggers. For the report filed on becoming a reporting issuer in Canada (s. 4.1), they are exempt only if their securities trade on a "specified exchange", and the ASX is one of them. An ASX-listed producer seeking a Canadian listing can therefore use its own QPs.

What this means in practice:an Australian CP who is a full-time employee can sign a maiden Resource for an ASX announcement. The same estimate disclosed by a Canadian junior would usually need an independent QP. Budget for the external reviewer early, and check that each Australian signatory holds a qualifying membership grade.

Site visits

NI 43-101 requires at least one QP to have completed acurrent personal inspectionof the property before the Technical Report is filed (s. 6.2). The only deferral is narrow. All of these must apply: the property is an early-stage exploration property (no current Resources or Reserves, and no drilling or trenching proposed), seasonal weather prevents access, and the report discloses why and when the inspection will happen. It never applies to a Resource estimate, PEA, PFS or FS.

The JORC Code 2012 treats site visits through Table 1. The Competent Person reports whether a visit was undertaken and, if not, why not. A missing visit must be explained, but it does not by itself make the report non-compliant.

For engineers, the NI 43-101 rule has logistics consequences. On a remote or international project, schedule the QP visit early in the study, not at sign-off.

The disclosure document: Public Report vs Technical Report

This is the largest practical difference between the two regimes.

Under JORC, the disclosure is the company's Public Report, usually an ASX announcement. For significant projects, first-time or materially changed Resources and Reserves must be supported by JORC Table 1, reported on an "if not, why not" basis. There is no standard full-length technical report that must be lodged with the exchange. The detailed study report sits behind the announcement as supporting documentation. The closest Australian equivalent to a Canadian Technical Report is the independent technical assessment report prepared under the VALMIN Code for an IPO prospectus.

Under NI 43-101, the obligations sit at two levels.

Every disclosure:

• All scientific or technical disclosure on a property material to the issuer must be prepared by, or approved by, a QP (s. 2.1).

• Written disclosure must name the QP and their relationship to the issuer (s. 3.1), and state whether and how the data was verified, including any limitations (s. 3.2).

• Written disclosure of Resources or Reserves must give the effective date, the key assumptions, parameters and methods, and any known risks (s. 3.4).

A Technical Report under Form 43-101F1 is needed only when a filing trigger in s. 4.1 or s. 4.2 applies. Typical triggers are becoming a reporting issuer, a prospectus, and written disclosure that, for the first time, reports Resources, Reserves or PEA results on a property material to the issuer that are a material change for the issuer, or a change to them that is a material change (s. 4.2(1)(j)). In that last case the report must be filed on SEDAR+ within45 daysof the disclosure, or earlier if a short form prospectus or directors' circular is involved. A news release of drill results does not by itself trigger a Technical Report.

The form prescribes 27 items, with Items 15 to 22 required once a property is "advanced" (it has Reserves, or a PEA, PFS or FS). The items cover everything from property description and history through geology, drilling, sampling, data verification, metallurgy, Resource and Reserve estimates, mining methods, recovery, infrastructure, environmental studies, capital and operating costs and economic analysis.

What this means in practice:the Canadian deliverable is a structured, public, signed document. Study managers should plan the Technical Report as a deliverable with its own schedule, sign-off chain and QP sections, not as an afterthought to the study.

Resource and Reserve classification

The classification framework is effectively the same, because both regimes follow the CRIRSCO template. The biggest practical difference is in how the numbers can be totalled.

Adding Inferred to the total.JORC allows a "Total Mineral Resource" that includes Inferred, provided each category is also reported separately. NI 43-101 s. 2.2(c) prohibits adding Inferred Resources to the other categories at all. A Canadian table can show Measured plus Indicated as a subtotal, with Inferred reported on its own line. Every Australian Resource table with a single grand total has to be restated before it is used in Canadian disclosure.

Other differences:

• Terminology:JORC usesOre ReserveandProved. CIM usesMineral ReserveandProven. Canadian regulators also consider the word "ore" potentially misleading when used about Resource estimates, because it implies economic viability that has not been shown. Use the correct terms for the market you are reporting to.

• Study level:both require at least a Pre-Feasibility Study with Modifying Factors applied before a Reserve is declared. A Scoping Study or PEA cannot support a Reserve under either regime.

• Inclusive or exclusive reporting:both allow Resources to be reported inclusive or exclusive of Reserves, provided it is clearly stated (NI 43-101 s. 2.2(b)). Australian practice is mostly inclusive. Read Canadian tables carefully before comparing.

Early-stage economics: Scoping Study vs PEA

Both regimes allow economic analysis that includes Inferred Resources. The headline difference isExploration Targets. The ASX allows them in a production target under strict conditions, but never as its sole basis. NI 43-101 never allows them in an economic analysis, even in a PEA.

JORC and ASX (Scoping Study)

• Production targets and forecast financial information are governed by ASX Listing Rules 5.15 to 5.19 and ASX Guidance Note 31, not just the JORC Code.

• Inferred Resources may be included, with prescribed cautionary statements and the proportion and sequencing of Inferred material disclosed.

• Production targets can include Exploration Targets, with strict cautionary language, disclosure of the proportion they represent and a demonstrated reasonable basis. A production target cannot be based solely on an Exploration Target, or solely on a combination of Exploration Target and Inferred Resources (Listing Rule 5.15).

• A production target based solely on Inferred Resources carries extra conditions, including a supporting technical report prepared by an independent Competent Person and released to the market.

• The company must show it has reasonable grounds for the funding assumptions behind the financial forecast.

NI 43-101 (Preliminary Economic Assessment)

• A PEA is a defined term. Its first disclosure on a property material to the issuer will usually trigger a Technical Report and an independent QP.

• Inferred Resources may be included only if the disclosure meets all of s. 2.3(3) and s. 3.4(e):

• an equally prominent statement that the PEA is preliminary, includes Inferred Resources too speculative geologically to have economic considerations applied that would allow them to be categorised as Reserves, and there is no certainty the PEA will be realised;

• the basis for the PEA and any qualifications and assumptions made by the QP;

• the impact of the PEA on the results of any PFS or FS for the property;

• an equally prominent statement that Mineral Resources that are not Mineral Reserves do not have demonstrated economic viability.

• Economic analysis based on exploration targets or historical estimates is not permitted (s. 2.3(1)(b)).

• The terms pre-feasibility and feasibility study may only be used when the study meets the CIM definitions (s. 2.3(4)).

• A PEA cannot be used to support Reserves.

What this means in practice:an ASX Scoping Study and a Canadian PEA cover the same stage of work, but they cannot always use the same mine plan. Any tonnes sourced from an Exploration Target must come out of the Canadian economics. The compliance focus also differs. In Australia it is the market announcement and ASX scrutiny of the production target. In Canada it is the cautionary wording and, usually, the 45-day Technical Report.

Exploration Targets, historical estimates and value disclosure

• Exploration Targets:both allow a target to be expressed as ranges of tonnage and grade, with a cautionary statement that the potential quantity and grade is conceptual and that further exploration may not result in a Resource.

• Historical and foreign estimates:both allow them, with conditions. Under ASX Listing Rules 5.10 to 5.12, a foreign or historical estimate requires a prescribed cautionary statement, and the Competent Person must explain what work is needed to report it under JORC. NI 43-101 allows historical estimates with similar caution (s. 2.4). Issuers incorporated outside Canada, and Canadian issuers reporting on properties outside Canada, may use an acceptable foreign code such as JORC, provided the Technical Report reconciles any material differences to the CIM categories (s. 7.1).

• Gross or in situ value:both regimes prohibit it. JORC Clauses 28 and 51 do not allow "in situ" or "in ground" values to be reported, and the ASX applies the same position to offer documents. NI 43-101 s. 2.3(1)(c) bans disclosing the gross value of metal in a deposit or intersection. Metal-equivalent grades are allowed in both, but only with the individual grades and assumptions shown.

Enforcement and liability

• JORC:the Board is responsible for the Public Report. ASX enforces the Listing Rules, ASIC enforces continuous disclosure and misleading-conduct provisions under the Corporations Act, and the AusIMM or AIG handles complaints about the Competent Person's professional conduct.

• NI 43-101:provincial securities regulators enforce the instrument directly and run continuous disclosure reviews of mining issuers. Regulators can require a Technical Report to be refiled, or a news release to be retracted. QPs are exposed to statutory civil liability as experts in some disclosure documents.

Both codes are being rewritten

Engineers should be aware that both regimes are in transition.

• JORC:the review of the 2012 Code began with an industry survey in 2020–21, and the exposure draft of a new Code was released for consultation on 1 August 2024. JORC's most recent update (20 August 2026) does not give a firm release date. After release, the ASX must consult on Listing Rule changes and a transition period will apply. Draft proposals include stronger disclosure of material ESG factors, a more formal "reasonable prospects" assessment, and a clearer split between mandatory requirements and guidance. JORC 2012 remains in force until then.

• NI 43-101:the CSA published a proposal in June 2025 to repeal and replace NI 43-101, its Companion Policy and Form 43-101F1. The comment period closed in October 2025. Proposals include renaming the PEA as a "scoping study", removing the option to report under foreign codes such as JORC, removing the site-inspection deferral, and expanding environmental, permitting and Indigenous Peoples disclosure. No final instrument or effective date has been announced, so the current NI 43-101 still applies.

Dual-listed projects

For companies listed on both the ASX and a Canadian exchange, the practical answer is to design the work to the stricter requirement on each point:

• Engage a Competent Person who also meets the QP definition, including the degree and membership-grade tests.

• Plan for independence where the Canadian triggers apply, and check whether a producing-issuer exemption is available.

• Complete a current site inspection regardless of Australian practice.

• Prepare a Canadian Resource table that reports Inferred separately and never adds it to the total.

• Keep Exploration Targets out of any economics that will be disclosed in Canada.

• Structure the study report so it can be issued as a Form 43-101F1 Technical Report and support the JORC Table 1 in the ASX announcement.

• Run the Australian and Canadian disclosure on one timeline so the 45-day filing does not lag the ASX release.

There is also a forward risk. Today, a foreign-incorporated issuer can report in Canada under JORC with a reconciliation to CIM. If the CSA proposal takes effect as drafted, that option disappears and all Canadian disclosure would have to use the CIM categories directly. Dual-listed companies relying on JORC reporting in Canada should plan for that change now.

The key takeaway

Classification:essentially the same. Inferred, Indicated and Measured Resources feed Probable and Proved/Proven Reserves, and both need at least a PFS. Canada does not allow Inferred to be added to the total.

Process:JORC relies on a Competent Person and a market announcement supported by Table 1. NI 43-101 relies on a Qualified Person behind every disclosure, a mandatory site visit, independence tests and, when a trigger applies, a prescribed Technical Report filed within 45 days.

Planning:the differences show up in study budget, schedule and sign-off, not in the geology. Decide early which regime, or both, the project will report under.

About Go Engineering

Go Engineering provides mining engineering consulting, contracting and training from Perth, Western Australia. Our team supports studies from Scoping through Feasibility, Resource-to-Reserve conversion, independent technical reviews and Competent Person services.

Need support preparing a JORC-compliant Ore Reserve, reviewing a Technical Report, or planning a study that reports in both Australia and Canada? Go Engineering can help.

Sources

• JORC,Australasian Code for Reporting of Exploration Results, Mineral Resources and Ore Reserves(The JORC Code), 2012 Edition.

• ASX Listing Rules, Chapter 5, and ASX Guidance Note 31: Reporting on Mining Activities.

• Canadian Securities Administrators, National Instrument 43-101Standards of Disclosure for Mineral Projects, Form 43-101F1 and Companion Policy 43-101CP.

• CIM,Definition Standards for Mineral Resources and Mineral Reserves(2014), andEstimation of Mineral Resources and Mineral Reserves Best Practice Guidelines(2019).

• VALMIN Committee,Australasian Code for Public Reporting of Technical Assessments and Valuations of Mineral Assets(The VALMIN Code), 2015 Edition.

• JORC, JORC Code Update page andUpdate on the JORC Code Reviewwebinar, 20 August 2026 (jorc.org/code-update).

• CSA Notice and Request for Comment,Proposed Repeal and Replacement of NI 43-101, 12 June 2025.

This article is general information only and is not legal advice. Check the current Code, Listing Rules and National Instrument before relying on any requirement for a specific disclosure.