But there are some clear omissions in the report. The ‘business as usual’ messaging is based in a narrow definition of impact and gives limited consideration to how environmental pressures are likely to intensify as demand for minerals increases.
A metals boom ahead
Demand for critical metals and minerals is expected to surge. In a recent keynote, ICMM CEO highlighted a convergence of powerful demand drivers: the energy transition, electrification, rising defence spending, supply-chain reshoring and the rapid expansion of digital infrastructure and data centres.

These long-term, simultaneous trends are pushing a new rapid expansion of mining, a so-called “gold rush” for critical raw materials. It’s worrying that an institution like ICMM, based on the premise of improving mining’s sustainable development, is leaving key impacts out of its assessment at such a time.
Underestimating impact: emissions and deforestation left out
The first flaw is that the ICMM report focuses only on operational emissions (the greenhouse gases released from mining activities themselves and from the energy they consume). This approach omits Scope 3, the indirect greenhouse gases produced across a company’s value chain. In many industries, these emissions make up the largest share of a company’s climate footprint, and companies often leave it out because the data is difficult to collect across complex value chains.
But the ICMM represents many of the world’s largest mining firms and has even produced guidance on these emissions. With that reach, it is one of the few organisations capable of aggregating and estimating Scope 3 impacts at an industry level. Leaving them out presents an incomplete of the sector’s climate footprint.
The clearest blind spot in the report is the omission of one of mining’s most severe environmental impacts: deforestation and ecosystem degradation. This omission is striking because mining frequently takes place in landscapes that are both nature-rich and are important carbon sinks. Clearing forests, often primary forests, to access mineral deposits affects biodiversity and releases large amounts of stored carbon.
The scale of this impact has been widely underestimated. A global inventory of 236,000 mining areas found that mining-induced deforestation from 2001-2023 resulted in the loss of nearly 20,000 km² of forest. Including these land-use emissions increases the carbon footprint of extraction by 60% on average, and nearly doubles it for some minerals.
While tree loss affects carbon, the greatest consequences are for species and habitats. Mining may contribute less to global tree loss than forestry or wildfires, but its local-level impacts are severe – especially in tropical rainforests and Indigenous territories. The extensive removal of vegetation and soil often makes full ecological recovery impossible.
Biodiversity treated as a side issue
The industry has frameworks for biodiversity, such as ICMM’s “Achieving No Net Loss or Net Gain of Biodiversity” guidance, which help companies through assessment, mitigation and restoration. But placing these impacts in separate frameworks rather than emissions accounting shows how climate change and nature loss are still treated as separate challenges. In practice, the two are deeply interconnected. Ignoring land-use emissions drafts a climate story that is technically correct but ecologically incomplete.
Other sectors are increasingly waking up to the inseverable link between nature and climate. We see this with Triodos Bank’s own recent Climate and Nature Strategy, but also in broader industry such as with Holcim integration of ecosystem restoration with decarbonisation, and Schneider Electric explicitly linking climate change and biodiversity loss in its reporting.
Nature loss as a financial risk
Against this backdrop, the continued separation of climate and nature impacts by the mining industry looks increasingly outdated. Especially as ecosystem degradation is beginning to show up on company balance sheets. A recent stress test by Barclays examined how environmental risks can affect mining and energy companies. The analysis found that mining firms could see earnings fall by around 25% over five years due to physical and transition risks (water prices, stricter pollution regulations, expansion of protected areas, droughts and flooding).
As Barclays’ group head of sustainability noted, biodiversity loss and ecosystem degradation are increasingly being recognised as systemic economic risks. In other words, nature loss is becoming a material business concern, rather than purely a sustainability topic.
The energy transition and the challenges we’re facing over the coming years will require mining. That much is clear. Now the industry and those shaping its sustainability agenda must commit to full-scale reporting that captures the true environmental picture, not just the parts that fit neatly into accounting frameworks.
