S-K 1300 is the SEC's mineral disclosure regime (Regulation S-K Subpart 1300, adopted 2018, mandatory from fiscal years starting January 1, 2021), replacing Industry Guide 7. It shares CRIRSCO-based definitions with JORC 2012 (Australasia) and NI 43-101 (Canada) but keeps its own terms, its own Technical Report Summary format, and a US-securities materiality test.
Three securities regimes govern how a mining company can tell investors what is in the ground: the US SEC's S-K 1300, Australasia's JORC Code, and Canada's NI 43-101. All three sit inside the CRIRSCO family of reserve-reporting definitions, but each is a separate legal instrument with its own filing mechanics, signing professional, and failure modes when a report is converted between them. This page compares the three directly; for the older Soviet GKZ system (A/B/C1/C2/P categories) against them, see the GKZ to JORC conversion guide.
S-K 1300 is Subpart 1300 of Regulation S-K, the SEC's rule set for mineral property disclosure by registrants. The SEC adopted the final rule on October 31, 2018, rescinding the old Industry Guide 7 (unchanged since the 1980s) and folding mining property disclosure into new Subpart 229.1300, plus a mandatory exhibit requirement at 17 CFR 229.601(b)(96). Compliance became mandatory for a registrant's first fiscal year beginning on or after January 1, 2021, with early voluntary adoption permitted before that date.
The SEC built S-K 1300 to align with CRIRSCO-based international practice, but it is not itself a CRIRSCO member code. The SEC wrote its own definitions rather than incorporating JORC, NI 43-101, or CIM Definition Standards by reference, so it would not be bound to future changes in codes it does not control. That single design choice is the root of most conversion errors: a resource or reserve estimate fully compliant under JORC or NI 43-101 is not automatically compliant under S-K 1300 without a qualified person re-checking it against the SEC's own definitions.
The three codes converge on the same two-axis grid (Exploration Results / Mineral Resources / Mineral Reserves, each split by confidence level), but diverge on governance, the signing professional's independence, and the exact document that has to be filed.
| Element | S-K 1300 (US, SEC) | JORC Code 2012 (Australasia) | NI 43-101 (Canada) |
|---|---|---|---|
| Governing instrument | Regulation S-K Subpart 1300, 17 CFR 229.1300-1305 | JORC Code, incorporated into ASX Listing Rule 5.6 and Appendix 5A | National Instrument 43-101, adopted by Canadian securities regulators (CSA) |
| Adopted / effective | Adopted Oct 31, 2018; mandatory from FY beginning on/after Jan 1, 2021 | 2012 edition mandatory on ASX from Dec 1, 2013 | Original 2001, current form reflects CIM Definition Standards updates |
| Replaces / supersedes | SEC Industry Guide 7 | Earlier JORC editions (1989, 1999, 2004) | Prior CSA mining disclosure policy statements |
| Resource categories | Inferred, Indicated, Measured Mineral Resource | Inferred, Indicated, Measured Mineral Resource | Inferred, Indicated, Measured Mineral Resource (CIM Definition Standards) |
| Reserve categories | Probable, Proven Mineral Reserve | Probable, Proved Ore Reserve | Probable, Proven Mineral Reserve |
| Signing professional | Qualified Person: 5+ years relevant experience, recognized professional organization membership; need not be independent of the registrant | Competent Person: member of AusIMM or AIG, minimum 5 years relevant experience | Qualified Person: university degree plus 5+ years relevant experience, member of a recognized professional association |
| Independence requirement | Not required | Not required, but must be named and accountable | Not required for most disclosure, independence required for certain technical reports (e.g. IPOs, new mineral projects) |
| Core technical document | Technical Report Summary (TRS) | JORC Table 1 (public report annexure) | NI 43-101 Technical Report (Form 43-101F1) |
| Governing citation | 17 CFR 229.601(b)(96) | JORC Code 2012, Table 1, Sections 1-4 | NI 43-101, Form 43-101F1 |
| Materiality standard | US securities-law materiality (Securities Act Rule 405 / Exchange Act Rule 12b-2): would a reasonable investor find it important | Professional judgment of the Competent Person under an "if not, why not" disclosure test | Professional judgment of the Qualified Person, tied to what a reasonable investor would consider important |
| Price assumptions | "Reasonable and justifiable" price, disclosed with time frame and reference point; no prescribed formula | Realistic, defensible long-term price, reviewed as a modifying factor under Table 1 Section 4 | Reasonable price assumptions, documented and defensible, per CIM best-practice guidelines |
| Inferred resources in economic analysis | Allowed only in an initial assessment (PEA-equivalent), with mandatory cautionary language; excluded from pre-feasibility and feasibility studies and cannot convert to a reserve | Allowed in scoping-level studies with explicit caution; not sufficient for pre-feasibility or feasibility conclusions | Allowed in a Preliminary Economic Assessment with prescribed cautionary disclosure; excluded from pre-feasibility study economics |
| Filing mechanism | TRS filed as an exhibit under Item 601(b)(96) with the registrant's Form 10-K or 20-F on EDGAR (Form 40-F/MJDS filers are exempt from S-K 1300) | Table 1 attached to or referenced in the ASX announcement; JORC Code compliance is a listing-rule condition, not a separate SEC-style exhibit | Technical Report filed on SEDAR+ within 45 days of the triggering disclosure |
All three codes require a named, individually accountable technical professional, but the qualification bar and the independence rule are not identical. Under S-K 1300 a Qualified Person needs at least five years of relevant experience in the type of mineralization and activity being reported, plus membership in a recognized professional organization, and does not have to be independent of the company. JORC's Competent Person must belong to the Australasian Institute of Mining and Metallurgy (AusIMM) or the Australian Institute of Geoscientists (AIG) and, again, needs at least five years of relevant experience; independence is not mandated but the Competent Person's name and organization are published, creating personal accountability. NI 43-101's Qualified Person needs a relevant university degree plus five years of experience and membership in a recognized association; independence is only mandatory in specific situations such as an IPO technical report or a report supporting a new mineral resource for the first time.
In practice, a Competent Person under JORC or a Qualified Person under NI 43-101 is not automatically a Qualified Person under S-K 1300. The SEC requires its own assessment of whether that individual's specific experience matches the commodity and deposit type in question, which is why cross-border technical reports usually carry separate sign-offs per jurisdiction rather than one signature covering all three regimes.
Materiality is the sharpest legal divergence. S-K 1300 borrows its materiality test directly from US securities law (Securities Act Rule 405, Exchange Act Rule 12b-2): would a reasonable investor consider the information important to a buy/sell decision, with no prescribed numeric threshold. JORC and NI 43-101 instead lean on the named professional's judgment: JORC's "if not, why not" convention in Table 1 asks the Competent Person to address every listed criterion or explain its omission, while NI 43-101's Qualified Person applies a similar reasonable-investor standard without direct SEC rule incorporation.
Price assumptions follow the same pattern: convergence without identical wording. S-K 1300 requires a "reasonable and justifiable" commodity price, disclosed with its time frame and reference point, but mandates no specific averaging methodology. JORC requires a realistic, defensible long-term price as a modifying factor under Table 1, and NI 43-101 relies on CIM best-practice guidance for the same judgment call. None of the three prescribes a fixed trailing-average formula; all three put the burden on the signing professional to justify the number and disclose how it was derived.
This is the point where the three regimes have converged almost completely, despite reading like a classic conversion trap. Under S-K 1300, an inferred mineral resource cannot be used to demonstrate economic viability and cannot convert to a reserve, except that a Qualified Person may include inferred resources in an initial assessment's economic analysis if the report states with equal prominence that the study is preliminary, that inferred resources are too speculative to be treated as reserves, that there is no certainty the assessment will be realized, and discloses the percentage of inferred resources plus the results with inferred resources excluded. Pre-feasibility and feasibility studies must exclude inferred resources entirely.
JORC applies the identical logic through its scoping-study language: inferred resources may support a scoping-level study with explicit caution, but confidence is not sufficient for pre-feasibility or feasibility conclusions. NI 43-101 uses the same PEA carve-out, near-identical cautionary wording included, while barring inferred resources from a pre-feasibility study's economics. A converted report that carries PEA-level inferred-resource economics into an S-K 1300 pre-feasibility disclosure is one of the more common flags in SEC comment letters.
Check which study level the source report's inferred-resource economics support. PEA-equivalent (Initial Assessment / Scoping Study) is fine across all three codes with the right cautionary language. Anything at pre-feasibility or feasibility level must have the inferred component stripped out first.
The core disclosure document differs in name, structure, and filing venue even though the underlying content overlaps heavily. S-K 1300 requires a Technical Report Summary under 17 CFR 229.601(b)(96), filed as an exhibit to the registrant's annual report (Form 10-K or 20-F) on EDGAR (Form 40-F/MJDS filers are exempt from S-K 1300). A TRS covering an initial assessment must, at minimum, address the specific paragraphs listed in 229.601(b)(96)(iii)(B), covering property description, geology, exploration data, sampling and verification, mineral processing, resource and reserve estimates, mining methods where applicable, infrastructure, market assessment, environmental status, and cost and economic analysis, each signed by the Qualified Person responsible.
NI 43-101's equivalent is the Technical Report under Form 43-101F1, filed on SEDAR+ within 45 days of the news release, prospectus, or other document that triggered the disclosure obligation. It covers substantially the same ground (property description, geology, exploration, resource and reserve estimates, mining and processing where applicable) but is structured around Form 43-101F1's item list, and it is a stand-alone filing rather than an exhibit bundled into an annual report. JORC has no equivalent stand-alone report: Table 1 is completed once, on an "if not, why not" basis, and referenced or attached to the ASX announcement itself rather than filed as a separate periodic exhibit.
Filing obligations attach to where a company is listed or registered, not to where its mine sits. An SEC registrant that files Form 10-K or 20-F with a mining operation material to its business must comply with S-K 1300 and file a Technical Report Summary as an exhibit. Canadian issuers eligible to file Form 40-F under the Multijurisdictional Disclosure System (MJDS) are exempt from S-K 1300's mining disclosure requirements entirely, though NI 43-101 qualified-person consents still have to be filed as exhibits to the 40-F. An ASX-listed company must comply with the JORC Code under Listing Rule 5.6 for any public statement about exploration results, mineral resources, or ore reserves, regardless of SEC status. A TSX or TSX Venture company must have an NI 43-101 Technical Report on file with Canadian regulators, prepared by or under a Qualified Person's supervision, before making resource or reserve disclosure.
Dual-listed companies (ASX-and-SEC, or TSX-and-SEC) end up with two separate technical documents: a JORC Table 1 or NI 43-101 Technical Report for the home exchange, and a separate S-K 1300 Technical Report Summary for the US filing, because none of the three regulators accepts the other's document as a substitute. Tonnage and grade usually agree, since the underlying geological model does not change, but categorization, the signing professional's statement, and cautionary language have to be independently re-checked against each code's own definitions. See the jurisdiction rundown in the CRIRSCO codes by country reference.
Most conversion failures cluster around five recurring issues rather than a long tail of edge cases:
S-K 1300, JORC 2012, and NI 43-101 are three of the six standards CoreElement.AI's platform maps against in a single pipeline, alongside SAMREC (South Africa), PERC 2021 (Europe), and KAZRC. The platform runs 22 modules across that set, including a Soviet GKZ A/B/C1/C2/P conversion module that OCRs legacy archive documents, reprojects Pulkovo 1942 coordinates to WGS-84, and maps GKZ categories onto CRIRSCO-family equivalents rather than assuming a direct swap. As of May 2026 the platform had digitised 4,859 Soviet-era geological documents, with an AI-ranked drill-target hit rate of 76%. Details on the KAZRC-specific mapping are in the KAZRC standards reference. The product angle matters because the five recurring conversion errors above are exactly what a single cross-code mapping layer is built to catch, one underlying dataset checked against every target code's own definitions rather than a find-and-replace exercise between report templates.