Challenges in Preparing Feasibility Studies for Cut-Off Grades and Recalculating Reserves Discussed with Subsoil Users

During the meeting, participants discussed practical and legal issues related to the preparation and submission of feasibility studies for cut-off grades, as well as the recalculation of mineral reserves.

Business representatives expressed concern regarding the requirements being sent to mining companies by the Ministry of Natural Resources, Ecology and Technical Supervision of the Kyrgyz Republic in implementation of a submission by the Prosecutor General’s Office of the Kyrgyz Republic.

Under these requirements, companies are expected to ensure the preparation and submission of feasibility studies for cut-off grades taking into account changes in prices for mineral raw materials and products, to recalculate mineral reserves by deposit, and to update the cut-off grade level.

Subsoil users noted that the Kyrgyz Geological Service had initially set the deadline for completing the relevant work as 31 December 2026. However, in March 2026, companies received a repeated requirement under which the deadline was shortened to 1 July 2026. As a result, companies were given less than four months to carry out a complex set of geological, technical and economic works.

According to the business community, carrying out such work within such a limited timeframe may adversely affect the quality of the calculations and lead to distortions in the objective information on mineral reserves in the Kyrgyz Republic.

Participants also drew attention to the need to ensure clear and legally substantiated procedures for carrying out the recalculation. According to the position of subsoil users, the document establishing the procedure, grounds and process for carrying out the relevant work was not subject to state registration with the Ministry of Justice of the Kyrgyz Republic and was not included in the State Register of Regulatory Legal Acts. This raises questions regarding its legal force and the possibility of applying it to subsoil users.

Business representatives emphasized that they support the need to update mineral reserve data and improve the state accounting of the mineral resource base. At the same time, such work should be carried out on the basis of clear and uniform requirements, within realistic timeframes, and taking into account the technical capabilities of companies.

Following the meeting, participants emphasized the importance of continuing constructive dialogue between government agencies and subsoil users in order to develop coordinated approaches that would ensure the reliability of calculations, compliance with legislation, and preservation of the investment attractiveness of the mining sector of the Kyrgyz Republic.