Public Consultation: Responsible Gold Guidance Version 10

LBMA's Responsible Gold Guidance (RGG) is a comprehensive, evolving framework built on core due diligence principles aligned with international best practice - specifically the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and its Gold Supplement (OECD Due Diligence Guidance). It sets out a minimum baseline of expectations for LBMA London Good Delivery List (GDL) Refiners to follow.

RGG version 10 (RGG10), updated as part of a regular review cycle, draws on: implementation experience since the introduction of RGG version 9 (RGG9); developments in responsible sourcing practice; and LBMA’s commitment to continuous improvement.

The development process has been ongoing since 2024 with the collation of key areas of focus (Key Themes) identified through ongoing stakeholder engagement and feedback. This has included input from LBMA GDL Refiners, Assurance Providers, upstream and downstream trade and industry associations and actors, and civil society, gathered through regular working group, task force and committee meetings, as well as LBMA insights from past GDL Refiner Compliance and Assurance Reports.

Overview of Proposed Updates

The proposed updates are intended to clarify existing requirements, incorporate emerging expectations, and support consistent and effective implementation. All proposed amendments to the Responsible Gold Guidance remain aligned with the OECD Due Diligence Guidance as a baseline.

The proposed updates focus on four main areas:

1. Advancements in the risk-based due diligence approach for Secondary Gold through:

• change in nomenclature from Recycled Gold to Secondary Gold (with type of material sub-category definitions refined);

• recognising Investment Gold as a distinct type of material category;

• inclusion of risk-based type of material-specific due diligence requirements and updated Enhanced Due Diligence (EDD) measures for higher-risk supply chains (including independent audit requirements to support EDD).

2. Formally incorporating LBMA guidance and tools developed since RGG9, including:

• the ASM Toolkit, encompassing additional definitions for ASM supply chain actors and eligibility criteria for ASM material;

• the Disclosure Guidance updates including monthly country of origin reporting to LBMA and public reporting of the annual Country of Origin Annex;

• the Approved Assurance Provider Toolkit, including revised third-party assurance deliverables.

3. Reflecting broader developments in responsible sourcing practice including enhanced expectations relating to ESG due diligence.

4. Supporting EU alignment in implementation, recognising that RGG9 achieved full alignment as a standard¹ and the proposed updates in RGG10 are intended to support continuous improvements in programme implementation.

¹ in relation to the alignment assessment to become a recognised industry scheme under the EU Conflict Minerals Regulation

Consultation Documents

The following documents are available to view or download:

• Responsible Gold Guidance version 10
• Consultation feedback form

Consultation Timeline

Milestone	Date
Public Consultation #1 Opens	10 June 2026
Consultation Closes	10 July 2026
Review and Analysis of Feedback	July-September 2026
Public Consultation #2 and Publication of Consultation #1 Summary	Q4 2026
Publication of Final RGG10	December 2026
Effective Date	1 January 2027-31 December 2027 (implementation)
	Expectation that first audits against RGG10 are due for the annual reporting year ending 31 December 2027

Consultation Approach

LBMA is committed to a transparent and constructive consultation process. All feedback received during the consultation period will be reviewed as part of finalising Responsible Gold Guidance version 10.

LBMA encourages stakeholders to provide constructive, evidence-based feedback and implementation considerations where possible.

How to Respond

Please submit your feedback using the consultation feedback form.

Transparency and Publication of Responses

LBMA may publish consultation responses unless respondents explicitly request otherwise.

Respondents may request:

• Publication in full
• Anonymous publication
• Confidential submission (i.e. not to have the response published)

If you request redactions, please clearly indicate:

• The text proposed for redaction
• The rationale for confidentiality

LBMA reserves the right to redact confidential or commercially sensitive information where appropriate.

After the consultation closes, LBMA intends to publish a summary of the key themes raised and LBMA’s responses.

Questions?

For questions relating to the consultation process, please contact RGG@lbma.org.uk.